On August 24, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) launched Operation Economic Outcast, a campaign that OFAC has characterized as an “economic D-Day” against Iran. The action follows OFAC’s earlier “Economic Fury” campaign against Iran, on which we have previously reported here and here. OFAC stated these actions “mark the beginning of a sustained and systematic campaign to close every financial resource that supports the leading state sponsor…
In Japan, there were two major updates to its export control and sanction regime announced in the past few weeks. 1. Reimposition of Sanctions Against Iran On 29 September 2025, Japanese government announced the reimposition of the following measures under the Foreign Exchange and Foreign Trade Act, in response to United Nations Security Council Resolution 2231based on which sanctions against Iran concerning its nuclear issue under United Nations Security Council Resolutions 1737, 1747, 1803, and…
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…