In September 2025, the so-called “snapback” sanctions against Iran came back into force. These are based on UN Security Council Resolution 2231 of 2015, which endorsed the nuclear agreement with Iran (JCPOA) and lifted certain sanctions for as long as Iran complied with its obligations under that agreement. The snapback mechanism allows the parties to the agreement to automatically reinstate the previously lifted sanctions once Iran breaches material obligations under the agreement. Once the mechanism is triggered, UN member states have 30 days to adopt a resolution continuing the suspension of sanctions; absent such a resolution, the sanctions automatically come back into force.
On 28 August 2025, France, the United Kingdom, and Germany (the E3) triggered the snapback mechanism. They justified this on the ground that Iran was in breach of the JCPOA on material points, such as uranium enrichment and cooperation with the International Atomic Energy Agency (IAEA). Since no resolution suspending the sanctions was adopted within the prescribed period, the sanctions came back into force at the end of September 2025. The sanctions include, among other things, an arms embargo, a prohibition on certain uranium enrichment activities, the freezing of assets, and travel restrictions on individual persons and organisations. The EU has announced that it will transpose these UN sanctions into its own legal system and, where appropriate, supplement them with additional measures.
We find ourselves, then, transported back to the era of the Iran embargo in its strictest form. In the meantime, legislators have become considerably more “creative” when it comes to embargo rules. The various obligations to act and prohibition rules familiar from the Russia embargo go far beyond the level found in the Iran embargo. However, the following rules from the Iran embargo are significant, since they are specific to that regime:
- The sanctions also target Iranian persons, that is, natural or legal persons who either reside or are domiciled in Iran, or who, as legal persons, have their seat there. This also includes legal persons owned, or directly or indirectly controlled, by Iranian persons. This means that the Iran embargo can also cover transactions taking place outside Iran, where an Iranian person is involved.
- Money transfers are once again subject to significant restrictions. Among many other specific features, payments of €10,000 or more must be reported, and payments of €40,000 or more require authorisation.
- Transitional rules apply to many provisions, provided the contract was concluded before 30 September 2025 and is performed by the end of the year.
Trade relationships involving Iranian persons, or intended for use in Iran, must be subjected to heightened scrutiny at every stage of the supply chain, including deliveries to Turkey or other countries. We would be glad to assist you.
