On 28 August 2025, France, Germany, and the United Kingdom (the “E3”) formally triggered the “snapback” mechanism under the Joint Comprehensive Plan of Action (“JCPOA”), citing Iran’s continued non-compliance with its nuclear-related commitments. This move has been followed by weeks of unsuccessful negotiations at the United Nations aimed at extending the JCPOA framework. As a result of the snapback, and the failure to reach an agreement, all UN sanctions previously lifted under the JCPOA have…
There have been a number of fluctuating developments in the UN and EU’s approach to Iran over the past few weeks, with a further attempt to salvage negotiations in an agreement on 10 September. We set out further details herein, including consideration of the sanctions implications. Political Developments At the end of August, amid concerns regarding Tehran’s continued resistance to international nuclear oversight and Russia’s upcoming presidency of the United Nations Security Council, the E3…
On April 16, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) re-issued and updated its Advisory for Shipping and Maritime Stakeholders on Detecting and Mitigating Iranian Oil Sanctions Evasion (“the Advisory”), originally issued in September 2019. The updated Advisory is part of OFAC’s implementation of the February 4, 2025 National Security Presidential Memorandum (NSPM-2), which directs the Treasury Department to enact “maximum pressure” on Iran. The Advisory expands on the red flags…
On February 4, 2025, the White House issued a National Security Presidential Memorandum (“NSP Memo”) outlining President Trump’s intention to impose maximum economic and political pressure on the government of the Islamic Republic of Iran (“Iran”), including by enhancing enforcement efforts and modifying or rescinding any existing general license or guidance that provides Iran with “any degree of economic or financial relief.” In addition, on February 6, 2025, the US Treasury Department’s Office of Foreign…