The Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin, German Federal Financial Supervisory Authority) has ordered the winding-up of Bank Saderat Iran Zweigniederlassung Hamburg (BaFin, administrative decision dated 11 June 2026). The supervisory authority had previously revoked the institution’s authorisation to conduct banking business. The revocation of authorisation became final on 8 December 2025.
Authorisation to Conduct Banking Business Revoked
Bank Saderat Iran Zweigniederlassung Hamburg had held a banking licence since 1 January 1962. On this basis, it was permitted to conduct banking business in Germany through its branches in Hamburg and Frankfurt am Main.
By administrative order dated 5 November 2025, BaFin revoked the authorisation. According to the authority’s findings, several requirements for authorisation were no longer met. The institution had persistently breached statutory requirements and was unable to remedy the identified violations.
Special Audit Revealed Serious Organisational Deficiencies
During a special audit in 2023, BaFin identified numerous serious deficiencies in the proper organisation of business operations pursuant to § 25a Kreditwesengesetz (KWG, German Banking Act). In addition, the branch had ceased conducting its business operations for more than six months.
As the institution is subject to sanctions, the statutory presumption under § 1b KWG also applies. Under this provision, the managing directors of a sanctioned institution are deemed not to be fit and proper, irrespective of any personal misconduct. This provision is intended to provide the financial supervisory authority with swift and straightforward means of intervening against individuals who manage a sanctioned institution.
BaFin Orders the Branch to Be Wound Up
By its decision dated 11 June 2026, BaFin ordered the winding-up of Bank Saderat Iran Zweigniederlassung Hamburg. The institution initially challenged the decision but subsequently withdrew its legal remedy. The winding-up order is final.
On 30 September 2026, the Amtsgericht Hamburg (Hamburg Local Court) appointed Berlin-based FUW Treuhand Projekt Management GmbH as liquidator. Its task is to carry out the winding-up of the branch.
Focus on Iran-Related Export Transactions
The bank’s business model was primarily focused on financing and processing export transactions relating to Iran. These activities included in particular:
- maintaining accounts,
- processing payments,
- letters of credit,
- granting loans,
- providing guarantees, and
- financial investments.
As at 31 December 2025, the institution’s total assets amounted to EUR 62.4 million. Most recently, it employed 13 members of staff.
No Compensation Event Under the German Deposit Guarantee Scheme
The revocation of the banking licence does not directly affect the existing customer deposits totalling approximately EUR 200,000. According to BaFin, no compensation event has currently occurred under the German deposit guarantee scheme. Instead, the deposits will be dealt with as part of the winding-up of the entire branch.
Payments Require Authorisation
Access to existing balances is currently restricted. This is due to the European Union sanctions to which the bank is subject.
The court-appointed liquidator may therefore make payments only if the Servicezentrum Finanzsanktionen (Financial Sanctions Service Centre) of the Deutsche Bundesbank has first granted authorisation under sanctions law. The customer deposits thus remain part of the winding-up proceedings but are not available without this authorisation.
Requirements for Revoking a Banking Licence
If a credit institution no longer meets the conditions of its authorisation, BaFin may revoke it. The relevant requirements include, in particular, compliance with the provisions of the KWG and the Geldwäschegesetz (GwG, German Money Laundering Act).
Furthermore, the managing directors must be fit and proper and possess the professional competence required to manage the institution. The institution must also actually conduct the business operations covered by the authorisation.
Legal Bases for the Supervisory Measures
The revocation of the authorisation is based on:
- § 35(2) no. 1 KWG,
- § 35(2) no. 6 KWG,
- § 35(2) no. 3 in conjunction with § 33(1), sentence 1, no. 4 KWG,
- § 35(2) no. 3 in conjunction with § 33(1), sentence 1, no. 7 KWG, and
- § 35(2) no. 3 in conjunction with § 33(1), sentence 1, no. 2 KWG.
If BaFin revokes a bank’s authorisation, it may simultaneously order the bank to be wound up. If the persons ordinarily responsible for the winding-up do not provide sufficient assurance that it will be conducted properly, the competent Amtsgericht (Local Court) will appoint a liquidator at BaFin’s request. The legal basis for the winding-up order and the court appointment is § 38 KWG.
Publication of the supervisory measure is governed by § 60b(1) KWG.
Banking Law Assessment for Affected Parties
The case illustrates the interaction between banking supervisory law, winding-up law, deposit protection and European financial sanctions. Companies, investors and private individuals with legal questions relating to a regulatory winding-up or restricted bank balances can contact MTR Legal Rechtsanwälte. Further information is available from its banking law advisory service.
