On Monday, August 24, Treasury Secretary Scott Bessent announced Washington's new campaign against Iran's regime: Operation Economic Outcast. The objective, in his words, is "to sever every economic lifeline that sustains this tyrannical regime until Tehran stands alone."
More than 60 entities, individuals and vessels were designated in the first round. But among all the institutions Bessent named, one stood out: Bank Melli, one of the Iranian state's largest banks, was the only one whose every foreign branch, he said, "must be shuttered and dark."
Bessent also issued a warning to anyone tempted to help: "Any entity that facilitates money laundering on behalf of Iran will be removed from the U.S. dollar system. The clock just started ticking."
Britain has made a narrower accusation. It designated Bank Melli's London subsidiary under its Iran nuclear sanctions regime, and nothing in the bank's UK filings alleges money laundering. Two governments reached the same bank by different legal routes.
Eleven months after Britain sanctioned it, Melli Bank plc still holds a British banking license. It still seats a board, still meets a payroll in London, still files audited accounts. Every asset frozen, every new customer barred, and it remains a bank. Shuttering it is a separate act, and Britain is the only government that can perform it.
A British bank, owned by the Islamic Republic
Bank Melli operates branches and subsidiaries in about ten countries and territories, from the United Arab Emirates to Germany. Its London operation is a company in its own right: Melli Bank plc is registered in England, with a full banking license from Britain's financial regulators, the same authorities that supervise Barclays and HSBC.
Every share of it belongs to Bank Melli Iran, which belongs to the Iranian state. Until April 2026, the chairman of its London board was simultaneously the chief executive of the parent bank in Tehran.
Being a British company comes with a British obligation: publishing audited financial statements for anyone to read. The latest set, 54 pages covering 2025, was filed with the UK corporate registry in June. It amounts to something rare: an inside view of a regime-owned bank as the walls close in.
The accounts also leave no doubt about what the bank was for. Its core business for four decades was financing trade between Iran and Europe, mainly through letters of credit, the standard instrument that guarantees payment in cross-border trade.
The bank's own filings call Iran its "niche market" and say about 92% of its revenue was earned in euros, in what it calls the Eurozone–Iran trade corridor. A €363 million institution, with €258.8 million in capital that ultimately belongs to the Iranian state, existed inside the British financial system to keep money flowing between Iran and Europe.
And business was good, right up to the end. In 2024 the bank recorded its best profit since 2014, €2.4 million. In 2025 its fee income from trade finance surged another 71%, a boom cut short in late September, when the sanctions arrived.
What a severed lifeline looks like
In August 2025, Britain, France and Germany triggered the UN "snapback." The restored sanctions took effect on September 28. The next day, Britain and the European Union sanctioned Melli Bank plc itself.
Since then, the bank has been forbidden from writing a new loan or taking a new customer. Its own accounts describe what remains as the "orderly management" of existing assets and liabilities in a controlled, non-trading environment.
The numbers show what that means in practice:
- The bank holds about €98 million in deposits that it is not licensed to repay, even as €88 million of them come due. Most of that money belongs to Iranian financial institutions that are themselves under sanctions. Sanctioned depositors, sanctioned bank: the money is simply locked between them.
- €71 million of the bank's own money is stuck at other banks that hold its accounts, unavailable "due to external restrictions." What the bank can actually reach is about €30 million.
- Iranian banks owe it €36.5 million in payments that fell overdue during 2025. A year earlier, that figure was zero.
- Nearly three-quarters of its assets, €259.9 million, are claims on Iran, mostly money owed by Iranian banks. These are the assets that have to go somewhere if the bank stops existing.
The bank's British auditor has formally warned of "material uncertainty" over whether it can continue as a going concern. Its Hong Kong staff left in January when a payment license for their salaries failed to arrive in time. Layoffs began in London in December.
The Tehran representative office is closing. Four board members have departed in little over a year; three remain. Yet seniority still pays: total board compensation rose to €905,000 in 2025, and the highest-paid director received a €615,000 package including rented housing, a company car and private health insurance, in the same year the bank booked €1.26 million in severance costs.
What keeps the lights on at all is a permission slip. A general license from the UK Treasury, issued three and a half weeks after the designation, allows exactly four kinds of payments: wages and severance for its UK-based staff and directors, their pensions, IT bills, and the accountant's fee.
Every month the bank must report every payment it makes, line by line, to the Treasury. Even its lawyers require a separate license; legal and professional costs jumped 57% last year to just over €1 million, more than five times the bank's entire 2025 profit of €181,000, itself down 92% from the year before.
Britain's decision
On August 25, the day after Bessent spoke, Britain's Chancellor John Healey welcomed Operation Economic Outcast, noting that Britain has imposed more than 240 sanctions on Iran since Labour took office in 2024 and pledging to work with Washington on economic pressure.
Britain had sanctioned Melli Bank plc eleven months earlier on grounds of its own, under a nuclear regime unrelated to the money laundering Bessent alleges. The endorsement answers a different question: on the objective, Britain is with Washington.
That question has been open since the war began, with American officials making little secret of their view that British cooperation has run behind Washington's expectations. Melli Bank plc offers a cheap way to close the gap. The bank has been barred from trading since September. Its depositors are overwhelmingly sanctioned Iranian institutions. Its staff is already leaving. Letting the license expire hands Washington a closed bank at almost no cost to Britain.
Britain sanctioned the bank in September 2025, and weeks later the Treasury granted it Interim Necessities General Licence INT/2025/7628424. Renewal followed in April 2026. Every British and European sanction on Melli Bank plc that is in force today was in force then. Washington announced Operation Economic Outcast four months later, on August 24. The license expires on October 22.
The bank expected the signature to come again. Citing legal advice, its accounts say it anticipated renewal, and it behaved accordingly: it had added a new board member weeks before snapback, signed a new Hong Kong office lease a month after being sanctioned, and planned to rehire staff there by this summer.
Its report contains no wind-down plan, no closure scenario, and not a word about what happens to the €98 million in deposits or the €258.8 million in capital if the license lapses.
If the license lapses, the bank cannot lawfully pay its staff or its auditors, and an English company that cannot pay its auditors does not remain a going concern. Insolvency would put Melli Bank plc in front of a British court, which would have to decide what becomes of €98 million owed mostly to sanctioned Iranian banks and €258.8 million of capital belonging to the Iranian state.
Neither the bank nor the Treasury has said what that process would look like. The difficulty of it is the best reason the Treasury has to sign again. Insolvency would release nothing, though: sanctioned money stays frozen whoever administers it.
A freeze is a pause, and this bank has lived through one. The European Union sanctioned Melli Bank plc in 2008. The nuclear agreement lifted those sanctions in 2016, and the bank went back to financing Iranian trade, on its way to its best year since 2014. Everything imposed on it since 2025 could come off the same way, in a deal. Closure ends that.
A surrendered license, distributed capital and a dispersed staff leave nothing to restart, and any future British government minded to have this bank back would have to authorize an Iranian state-owned bank from the beginning.
That is what makes this obscure bank in London worth watching. Operation Economic Outcast rests on a claim that a regime's financial lifelines can be cut in practice. Melli Bank plc shows the machinery running end to end: international snapback, allied designations, a frozen balance sheet, a departing staff, and one administrative decision standing between a regime-owned bank and closure.
On October 22 the Treasury has two options. It can sign the license again and keep Melli Bank plc alive, or let it lapse and close a British bank owned by the Iranian state. Bessent said the clock just started ticking. In London, it already has an alarm set.
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This report is based on Melli Bank plc's Annual Report and Financial Statements for 2025 and prior years, filed at the UK's Companies House (company no. 04152338); the Companies House register of directors; the UK Sanctions List entry for Melli Bank plc under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019; the UK Treasury's Interim Necessities General Licence INT/2025/7628424 and its Legal Services General Licence INT/2025/7323088, both published on gov.uk; Council Decision 2008/475/EC, which first listed the bank in the European Union, and the delistings of January 2016 under the nuclear agreement; Treasury Secretary Scott Bessent's remarks of August 24, 2026, announcing Operation Economic Outcast; the UK Chancellor's statement of August 25, 2026; and Iranian press reporting on the removal of Abolfazl Najarzadeh as chief executive of Bank Melli Iran.