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 now been reinstated. These measures, originally imposed prior to 2015, are once again binding on all UN Member States, who are now required to reimpose the full suite of sanctions on Iran. We previously covered the background and developments surrounding the JCPOA framework in this earlier post. Further steps have also been taken by the EU and UK to reintroduce sanctions measures that went beyond those imposed by the UN.
EU Response
On 29 September, the Council of the European Union announced that it has agreed to reintroduce a number of restrictive measures targeting Iran’s nuclear proliferation activities. Prior to the JCPOA, the EU maintained a broader sanctions regime than mandated by the UN, including a range of autonomous measures, which are now reintroduced through three main legal acts. Outlined below is a summary of key points arising from the reintroduction of the measures.
Reimposed sanctions against individuals and entities:
Effective as of 29 September, the EU Designated Party controls have been expanded to include a significant number of previously sanctioned individuals and entities, who have now been relisted. Notably, this includes both parties that were previously listed pursuant to the UN listings as well as the EU autonomous listings. Therefore, the EU’s actions have gone well beyond what was strictly required under the UN sanctions in the context of the snapback.
The now listed parties include several major Iranian banks and financial institutions, including the Central Bank of Iran, as well as several parties connected to or supporting the government of Iran, including the Ministry of Energy, Ministry of Petroleum, and various companies active in the oil and gas sector in Iran.
These measures mean that all funds and economic resources belonging to, owned, held, or controlled by such relisted parties shall be frozen. Furthermore, no funds or economic resources shall be made available, directly or indirectly, to or for the benefit of these relisted parties.
The revised lists of individuals and entities are set forth in the annexes to respective legal acts referenced below:
- Council Implementing Regulation (EU) 2025/1982 (UN listings)
- Council Implementing Regulation (EU) 2025/1980 (EU autonomous listings)
Trade restrictions:
The EU has also reimposed various trade restrictions as part of its sectoral sanctions against Iran effective, as of 30 September. The reimposition of these sectoral sanctions has been effectuated through Council Regulation (EU) 2025/1975. Key measures from the sectoral trade restrictions are summarized below.
Product control restrictions
Although the EU already maintained export-related product controls restrictions in the context of the pre-existing Iran sanctions regime, these controls have now been extended. The extended controls among others restrict the sale, supply, transfer and export and, commonly, the provision of related ancillary services to any Iranian person, entity or body (“Iranian Person”) or for use in Iran of the following products:
- Designated dual-use items (also including restrictions on the purchase, import or transport from Iran).
- Designated items that could contribute to Iran’s enrichment-related, reprocessing or heavy-water-related activities, the development of nuclear weapon delivery systems or other activities of concern as identified by the IAEA (also including restrictions on the purchase, import or transport from Iran).
- Designated key naval equipment or technology, including items used for shipbuilding, maintenance, or refit, including for the construction of oil tankers.
- Designated key equipment and technology for key sectors of the oil and gas industry in Iran, including exploration of crude oil and natural gas, production of crude oil and natural gas, refining, liquefaction of natural gas, as well as for the petrochemical industry in Iran.
- Designated Enterprise Resource Planning software, designed specifically for use in nuclear, military, gas, oil, navy, aviation, financial and construction industries.
- Designated graphite and raw or semi-finished metals, such as aluminum and steel.
- Designated gold, precious metals and diamonds to the Government of Iran or related parties (also including restrictions on the purchase, import or transport from Iran).
The product controls also include import-related product controls, including in relation to the import, purchase or transport of designated crude oil or petroleum products involving Iran.
Financial restrictions
The EU also reimposed various restrictions of a financial nature. Notably, these restrictions include controls on transfers of funds between EU banks and credit instructions and credit and financial institutions and bureaux de change (including branches and subsidiaries thereof) that are domiciled in Iran or are controlled by parties domiciled in Iran. Other transfer of funds between (to and from) EU operators and Iranian Persons are now also subject to controls. In general, these controls impose a notification or authorization requirement for transfers with a value from EUR 10,000 or equivalent, depending on the nature of the transaction. These restrictions do not only apply to transfers that are executed in a single operation, but also those in several operations which appear to be linked.
Furthermore, the investment restrictions on financing of certain enterprises prohibit EU operators to grant financial loans or credit to, acquire or extend a participation in, or create a joint venture with certain Iranian persons, entities and bodies. These include parties that are engaged in the manufacture of designated military items, dual-use items or items contributing to Iran’s nuclear activities, exploration or production of crude oil and natural gas, the refining of fuels or the liquefaction of natural gas or in the petrochemical industry. This prohibition is subject to limited exceptions or authorization grounds.
In addition to the listings of commercial banks, the EU also introduced other banking-related restrictions. As part of these, EU credit and financial institutions are prohibited from opening accounts, forming banking relationships, or establishing offices, branches, subsidiaries, or joint ventures with credit and financial institutions and bureaux de change (including branches and subsidiaries thereof) that are domiciled in Iran or are controlled by parties domiciled in Iran.
Other financial restrictions related to the provision of (re-)insurance to Iranian persons, restrictions on the trade of Iranian-denominated banknotes and coinage, as well as of certain public or public-guaranteed bonds of the Iranian government and other Iranian entities have also been reintroduced.
Transport-related restrictions
As part of the transport-related restrictions, the EU introduced prohibitions on the provision of services (including classification services) in respect of oil tankers and cargo vessels flying the Iranian flag, or that are owned, chartered, or operated, directly or indirectly, by any Iranian Person. Furthermore, EU operators are prohibited from making vessels designed for transporting or storing oil and petrochemical products available to Iranian Persons, unless adequate measures have been taken to prevent their use for carrying or storing Iranian-origin oil or petrochemical products.
UK Response
Reimposed sanctions against individuals and entities:
On 29 September and 2 October, the UK took necessary steps to reimpose financial sanctions imposed under the UN sanctions on Iran (in accordance with its obligations as a UN member state) and autonomous financial sanctions measures which the UK previously imposed when a member state of the EU. In total the UK has re-designated nearly 200 entities and individuals under its Iranian sanctions regime, aligning with the EU. The relisted entities and individuals are once again subject to financial sanctions in the UK and, as a result, it is prohibited to (i) make funds or economic resources (directly or indirectly) available to a listed person or for the benefit of those listed, and (ii) deal in funds or economic resources owned, held or controlled by those listed.
Alongside the reimposition of these financial sanctions measures the UK has introduced four General Licences permitting the wind-down of certain transactions and the maintenace of certain support for the Shah Deniz gas project.
Trade restrictions:
The UK has also amended the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 to ensure alignment with UN trade sanctions. These trade sanctions measures – which came into force on 1 October – are focussed on Iran’s nuclear programme. Accordingly, these trade sanctions measures do not yet cover the full scope of the broader trade sectoral sanctions that were in force in the UK prior to its exit from the EU, and which the EU has reintroduced. The UK government has, however, made a commitment to adopt such measures, targeting the finance, energy, shipping and software sectors in particular.
Swiss Response
As a UN member state, Switzerland has reintroduced UN listings and sanctions. Prior to 2016, Switzerland had imposed sanctions mirroring the EU unilateral measures. These have not been automatically reimposed in Switzerland. Should the Swiss government decide to reimpose the additional EU unilateral sanctions, this will take time to be implemented.
Implications for Companies Following the Reinstatement of UN, UK and EU Sanctions on Iran
Companies are advised to assess their exposure to the newly relisted individuals and entities. In addition, the financial restrictions now in force impose significant limitations on the movement of funds to and from Iran. Transfers between EU-based financial and credit institutions and Iranian-domiciled institutions – including branches, subsidiaries, and entities controlled by Iranian persons – are prohibited, subject to limited exemptions. Additionally, fund transfers involving Iranian persons or entities that fall outside the scope of interbank transactions may still require prior notification or authorization, depending on the transaction’s value and purpose. Companies should also be aware of the increased enforcement risk that could arise from the diversion of controlled items to Iran.
Companies are encouraged to review their internal compliance frameworks, particularly those relating to financial operations, counterparties, and due diligence procedures. While these measures do not constitute a blanket prohibition on all dealings with Iran, they do require heightened vigilance and a clear understanding of the applicable legal obligations. For companies operating in Iran, a renewed comprehensive approach is required regarding how operations should proceed both practically and in accordance with applicable regulations.
