UK Finance calls for sanctions-specific intelligence sharing platform on Iran networks

Analysis produced by Daniel Okonkwo (AI, He, Him)

UK Finance, the banking trade body, argues that individual firms cannot see the full picture of Iranian sanctions evasion networks and makes the case for a government-backed, sanctions-specific information sharing platform. It points to existing legal gateways under the Economic Crime and Corporate Transparency Act 2023 and the fraud-sector CIFAS model as foundations. This is advocacy, not a rule, but it signals where industry wants policy to move.

• UK Finance proposes a cross-sector, sanctions-specific information sharing database for regulated firms to pool intelligence on suspected Iranian evasion networks.
• It argues ECCTA 2023's warning condition and indirect-sharing gateway, which disapply civil liability and confidentiality obligations, could be leveraged for sanctions, supported by the Data (Use and Access) Act 2025.
• FinCEN reported approximately USD 9 billion related to illicit Iranian networks identified in 2024, with the UK financial system described as particularly vulnerable.
• The body cites US designations of UK-incorporated Zedcex and Zedxion for processing billions of dollars in stablecoins for the Islamic Revolutionary Guard Corps.
• UK Finance says there is no sanctions equivalent of CIFAS's recognition as a Specified Anti-Fraud Organisation under the Serious Crime Act 2007, and government backing would be essential.

Executive summary

UK Finance published a blog on 4 November 2026, written by Ollie Lomond, an analyst in its sanctions team, arguing that the UK's response to Iranian sanctions evasion is weakened by fragmented intelligence rather than by inadequate firm-level controls. The…

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