HM Treasury issued an advisory notice to the financial sector on 11 March 2009 advising that
“All UK businesses regulated under the Money Laundering Regulations 2007 whether financial institutions or other regulated persons should treat transactions associated with Iran as situations that by their nature can present a higher risk of money laundering or terrorist financing, and which therefore require increased scrutiny and enhanced due diligence. Other persons authorised by the Financial Services Authority should also take this advice into account in their systems and controls to counter financial crime, and take appropriate actions to minimise associated risks.”
Other advisories were issued by the Treasury regarding the risks posed by Iran on 20 October 2008 and 3 July 2009.
HM Treasury used the powers under schedule 7 to the Counter Terrorism Act 2008 on 12 October 2009 to require all UK financial and credit institutions to cease transactions and business relationships with two Iranian entities—Bank Mellat and the Islamic Republic of Iran Shipping Lines—on the basis of identified activities of concern that these entities were carrying out. HM Treasury will consider further use of the powers in schedule 7 to the Counter Terrorism Act 2008 where they are a proportionate response to a risk to the UK’s national interests.
As the Prime Minister has set out, the UK is prepared to implement sanctions against Iran beyond the UN and EU measures already in place as appropriate if it does not engage meaningfully with the international community.