Snap-Back Of Iran Sanctions: Re-Imposition Of Broad Eu / Un Sanctions Against Iran

On 29 September 2025, the Council of the EU reimposed its sanctions in relation to Iran's nuclear proliferation activities across the EU (with all EU member states collectively implementing related UN obligations). Such sanctions had been suspended in 2015 with the entry-into-force of the Joint Comprehensive Plan of Action (JCPOA or Iran nuclear deal). The Snap-Back was triggered after Iran was found to have violated its commitments under the JCPOA. 

EU sanctions against Iran had not been fully lifted in 2015 and the EU has already started imposing additional sanctions against Iran over the last three years in the context of Iran’s alleged support of Russia’s war efforts. However, the re-imposition of EU sanctions under the JCPOA’s snap-back mechanism now re-targets key Iranian economic sectors:

Asset freeze sanctions

The newly designated entities and organisations include key actors of the Iranian economy. EU sanctioned entities and organisations now include inter alia 

• the Central Bank of Iran, 
• most Iranian banks such as Bank Melli, Bank Saderat, Trade Capital Bank, Bank Mellat, Europäisch-Iranische Handelsbank, Sina Bank, Tejarat Bank, Arian Bank, Bank Kargoshaie, 
• the Ministry of Energy, Ministry of Petroleum, 
• key Iranian energy companies such as National Iranian Oil Company, Petro Suisse, National Iranian Oil Refining and Distribution Company, Iran Liquefied Natural Gas Co., National Iranian Oil Company International Affairs Limited, Iranian Oil Terminals Company, West Oil & Gas Production Company; and 

• the Iran Insurance Company. 

Further, entities which had remained designated under the JCPOA continue to be subject to asset freeze sanctions, including e.g. Ansar Bank, Mehr Bank, Ministry Of Defense And Support For Armed Forces Logistics, Iran Aircraft Manufacturing Company, Iran Electronics Industries, Parchin Chemical Industries, or Ghani Sazi Uranium Company. 

As a result, any commercial dealings with these entities and organisations are prohibited.

Finance-related restrictions

Notably, there is 

• an investment ban and a prohibition to provide financing in relation to key sectors of the Iranian economy; 
• a prohibition to purchase Iranian government (and financial institution) bonds; and
• a prohibition to provide insurance or re-insurance to any Iranian person (including the government).

In addition, the processing of payments or transfer of funds between EU and Iranian financial institutions is generally restricted (and in any event requires a license).

Product-related trade restrictions

The reimposed EU product-related restrictions on Iran cover a wide range of import and export limitations, prohibiting the 

• purchase, import, or transport of certain restricted products into the EU if they originate in Iran, are located in Iran, or are exported from Iran; 
• sale, supply, transfer or export of restricted products to natural or legal persons in Iran, or for use in Iran; and 

• provision of certain services ancillary to the restricted products (such as providing financing or financial assistance, technical assistance, or brokering services related to the restricted products).

The group of restricted products includes:

• crude oil, natural gas, petrochemical and petroleum products;
• equipment / technology for the Iranian energy sector;
• gold, precious metals, diamonds, graphite, raw or semi-finished metals;
• arms / defence goods;
• items / technology that could contribute to Iran’s (i) enrichment-related; and (ii) reprocessing activities and (iii) ballistic missile programmes.

Impact on EU businesses

Against this background, EU businesses with any potential direct or indirect Iran nexus should

• take stock of any Iran-related business activities;
• assess any Iran exposure against the restrictions described above; and
• evaluate their sanctions compliance procedures to mitigate legal and operational risks going forward.

Our EU sanctions team continues to monitor sanctions developments and is happy to support. Please reach out if you would like to discuss any of the topics discussed above.