The UK, France and Germany (the European signatories to the Joint Collective Plan of Action (“JCPOA“) nuclear deal with Iran in 2015, referred to as the “E3“) have decided to retain certain sanctions previously imposed upon Iran. The press release published by the E3 announcing this decision is available here.

The JCPOA was agreed in 2015 between the E3/EU+3 (China, France, Germany, the Russian Federation, the United Kingdom and the United States, with the EU’s High Representative for Foreign Affairs and Security Policy) and Iran. Under the terms of the JCPOA, a range of sanctions against Iran were initially scheduled to be lifted on 18October 2023 as part of a sunset clause, focusing on nuclear proliferation-related measures, and also arms and missile embargoes.

The statement from the E3 notes that the decision follows attempts “to resolve Iran’s non-compliance through the JCPoA’s Dispute Resolution Mechanism“, which was triggered in January 2020. The statement also notes that Iran “has refused opportunities to return to the JCPoA twice and has continued to expand its programme beyond JCPoA limitations and without any credible civilian justification“, with its enriched uranium stockpile now standing at more than 18 times the amount permitted under the JCPOA.

A recent EU press release following a meeting between EU High Representative/Vice President Josep Borrell and Iran’s Foreign Minister (available here) notes the “importance of following a path of de-escalation” regarding the JCPOA, and notes the High Representative’s “conviction on the need to find a diplomatic solution to the Iran nuclear issue in the framework of the JCPOA“.

Recently, a joint statement by 63 countries via the International Atomic Energy Agency (“IAEA“) expressed the “urgent need for Iran to clarify and resolve issues in a manner satisfactory to the IAEA“.


Julian Godfray is a senior associate in Baker McKenzie's Competition, Trade and Foreign Investment Department in London. Julian works in particular in the Firm's market-leading International Trade and Compliance & Investigations practices. Julian joined the Firm as a trainee in September 2014, and qualified in September 2016. Julian has been seconded to two FTSE 100 clients during his time at the Firm, including in the ethics and compliance team of one client. Julian has also completed secondments to the Firm's European and Competition Law Practice in Brussels in 2016, and more recently to the Firm's Madrid office in 2020, working as part of the Firm's trade compliance practice in Spain.