The "Snapback" Of Sanctions On Iran

This post summarises the potential impact of the reimposition of sanctions on Iran following the "snapback" triggered under the Joint Comprehensive Plan of Action.

United Nations sanctions in relation to Iran's nuclear proliferation activities came back into force on 28 September 2025 following a decision by the UN Security Council not to prevent the "snapback" of sanctions under the Joint Comprehensive Plan of Action (the "JCPOA").

As set out in our previous blog, the E3 (UK, France and Germany) initiated the "snapback" process on 28 August 2025. This triggered a 30-day period in which the E3 could withdraw the "trigger" or the UN Security Council could pass a resolution to maintain the JCPOA. A proposed resolution to extend the suspension of sanctions was rejected by the Security Council and so UN sanctions on Iran were reimposed. By way of reminder, the reintroduced UN restrictive measures include:

• asset freezes and travel bans for designated persons;
• a ban on the export/ transfer of goods and technology to be used in nuclear enrichment, and the provision of related technical assistance or financing;
• restrictions on Iranian vessels and aircraft; and
• restrictions on certain Iranian banks (including the establishment of correspondent banking relationships).

A joint statement issued by the E3 on 28 September noted that member countries would seek to swiftly reimpose relevant UN sanctions but stressed that the E3 could continue to seek to engage diplomatically with Iran.

On 29 September 2025, the Council of the EU announced that, in addition to the UN restrictive measures, it would be reimposing a number of autonomous EU sanctions which include:

• an asset freeze in respect of the Central Bank of Iran and other major Iranian banks;
• a ban on the sale or supply of gold, precious metals and diamonds to Iran; and
• a ban on the import, purchase and transport of crude oil, natural gas, petrochemical and petroleum products and services, and the provision of related technical assistance and financing.

The United Kingdom has re-designated 71 persons under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 in line with the snapped back UN sanctions. It remains to be seen whether the UK will follow the EU and introduce additional sectoral restrictions or whether it will make any autonomous designations..

Companies with links to Iran will wish to consider how the reintroduced sanctions, and particularly the asset freezes, might impact their current operations and ensure that they are not dealing with any designated persons. EU companies in particular may wish to consider the impact on payment routes given the EU's designation of the Iranian Central Bank and other major banks. As always, companies should continue to monitor the situation and be aware of the potential for new restrictive measures to be introduced.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.