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 October 8, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) identified the Iranian financial sector as subject to Executive Order (“EO”) 13902 and, based on such identification, designated 18 Iranian banks. Our previous blog post on EO 13902 is available here. OFAC also issued a general license and Iran-related Frequently Asked Questions, as further described below. The action represents a significant escalation of the sanctions targeting Iran’s financial sector, yet many…
In a judgement of 7 April 2020 (ECLI:NL:HR:2020:623), the Dutch Supreme Court confirmed that the EU Blocking Regulation (“EUBR”) does not prevent extradition of an Iranian national to the United States for their alleged involvement in US export controls and sanctions violations. With this judgement, the Supreme Court upheld the judgement of the District Court of Rotterdam of 5 July 2019 (ECLI:NL:RBROT:2019:5338). This case was triggered by an extradition request for an Iranian national…