Bank Melli, Bank Sepah and Bank Saderat

Bank Melli, Bank Sepah and Bank Saderat are three legally distinct Iranian banks. They have different histories, ownership structures, subsidiaries and sanctions records. Their appearance in common sanctions packages does not make them one institution or establish that conduct attributed to one bank applies to the others.

Bank-specific identities

Bank Melli has served as a major Iranian commercial bank with an extensive domestic and international network. Bank Sepah is a separate institution whose legal and corporate history includes later restructuring. Bank Saderat is a distinct commercial bank with its own ownership and foreign operations. Current ownership percentages, government relationships, mergers and subsidiaries require bank-specific primary evidence before publication.

The banks perform ordinary financial functions including deposits, trade finance, payments and foreign exchange. Those capabilities can support state commerce and adaptation to financial restrictions. Capability and public ownership do not by themselves establish government direction of a particular transaction.

Designation chronologies

United Nations Security Council Resolution 1747 named Bank Sepah and Bank Sepah International in the context of measures concerning Iran's proliferation-sensitive nuclear activities and missile development. The resolution's legal effect, annex and later UN changes must be traced separately from United States, European Union and United Kingdom measures.

The United States Treasury cut Bank Saderat off from direct access to the United States financial system in September 2006 and attributed support for named organisations to the bank. In October 2007 Treasury designated Bank Melli and Bank Mellat for proliferation-related reasons and Bank Saderat under terrorism authorities, while also addressing Bank Sepah's existing status. The November 2007 OFAC action dealt with treatment under the Trade Sanctions Reform and Export Enhancement Act.

In November 2018 Treasury announced the reimposition of sanctions on more than 700 individuals and entities following the United States withdrawal from the Joint Comprehensive Plan of Action. Current status cannot be inferred from that announcement alone. Each bank and alias must be searched in live lists.

OFAC's current Specially Designated Nationals data contained separate records for Bank Melli Iran, Bank Sepah and Bank Saderat Iran when checked on 29 July 2026. The records carried different programme tags and related entries, so presence in the same dataset does not make the legal bases or consequences identical.

Attribution and statecraft significance

A designation is an official legal act with stated reasons. It is not independent proof of every underlying allegation. Alleged proliferation support, terrorism financing or evasion must remain attributed to the designating authority unless admitted or adjudicated. Annulment, delisting, relisting, settlement and conviction are different events.

The three banks belong in the main sequence because financial restrictions against systemically connected banks can deny payment access, pressure trade and induce adaptation. The analytical unit remains the individual bank and legal measure. Collective descriptions, current operational reach and sanctions effectiveness require precise evidence. Unsupported cyberattack claims are excluded.

Licensing and exceptions also matter. A bank's appearance on a list does not mean every transaction involving it is prohibited under every jurisdiction or on every date. Humanitarian trade, wind-down arrangements and other permissions can alter legal treatment. The applicable programme, ownership rule, licence and transaction date must be checked before describing access or exclusion.

See also

Central Bank of Iran · United States-led financial pressure campaign against Iran (2006-2015) · United States maximum-pressure sanctions campaign against Iran (2018-2021) · SWIFT disconnection of EU-designated Iranian banks (2012) · JCPOA sanctions relief and snapback (2015-2018) · Türkiye Halk Bankası A.Ş. (Halkbank) · Correspondent banking and Nostro/Vostro architecture

Sources

• United Nations Security Council, 'Resolution 1747' (24 March 2007), including the Bank Sepah annex.
• United States Department of the Treasury, 'Treasury Cuts Iran's Bank Saderat Off from the United States Financial System' (8 September 2006).
• United States Department of the Treasury, 'Fact Sheet: Designation of Iranian Entities and Individuals for Proliferation Activities and Support for Terrorism' (25 October 2007).
• Office of Foreign Assets Control, 'Trade Sanctions Reform and Export Enhancement Act Notice Concerning Bank Sepah, Bank Melli and Bank Saderat' (20 November 2007).
• United States Department of the Treasury, 'Reimposition of Sanctions on More than 700 Individuals and Entities' (5 November 2018), reconciled with current OFAC list records for each bank.
• Office of Foreign Assets Control, 'Sanctions List Service', current Specially Designated Nationals data for Bank Melli Iran, Bank Sepah and Bank Saderat Iran, checked 29 July 2026.
• Juan C. Zarate, Treasury's War: The Unleashing of a New Era of Financial Warfare (PublicAffairs, 2013).