Snapback sanctions on Iran: Understanding the impact on your business

On 28 September 2025, all United Nations sanctions targeting Iran that had been lifted since 2015 under the Joint Comprehensive Plan of Action (JCPOA; also known as the "Iran Nuclear Deal"), were reinstated. Since then, the European Union and United Kingdom have taken steps to implement these UN sanctions targeting Iran in addition to reimposing broader measures which were lifted.

Businesses which resumed activities in or with Iran or Iranian businesses since 2015 should thoroughly assess their exposure to these sanctions and remain vigilant to further developments in the coming weeks.

If you would like to discuss how these developments affect your business, please contact the authors or your trusted DLA Piper contact. DLA Piper's International Trade and Government Affairs teams advise on all aspects of sanctions compliance, risk management, licensing and engagement with authorities.

 

Snapback of UN Sanctions

The snapback has restored the sanctions imposed by the UN targeting Iran with effect from 28 September 2025. As a result, all UN Member States are required to:

• reinstate asset freezing measures and travel bans on 121 individuals and entities; and
• reintroduce trade measures targeting:
• uranium enrichment and reprocessing;
• ballistic missile development;
• transfers of major arms systems, including aircraft and tanks; and
• the Islamic Republic of Iran Shipping Lines and the broader Iranian shipping sector.

UN Member States are required to adopt national implementing measures and ensure that persons within their jurisdiction comply with those measures. It is unlikely that Russia and China, permanent members of the UN Security Council which voted against the snapback initiated by the E3 and have strongly condemned the move since subsequently, will comply with their obligations to implement the restrictions in the short-term. Russia and China have publicly challenged the legal legitimacy of the snapback decision of the E3, threatening the broader legitimacy of and observance of multilateral sanctions.

 

Snapback of Unilateral Sanctions

European Union

The EU has introduced legislation to both implement the snapback and reinstate all unilateral nuclear-related restrictive measures which were lifted following implementation of the JCPOA. These measures, which went significantly further than the UN sanctions, include:

• Asset freezing measures targeting the Central Bank of Iran and all major Iranian commercial banks;
• Restrictions on the import, purchase, and transport of Iranian crude oil, natural gas, petrochemicals, petroleum products, and related services;
• Restrictions on the export of key equipment used in the energy sector;
• Restrictions on the export of gold, precious metals and diamonds;
• Restrictions on the export of certain naval equipment;
• Restrictions on the transport of certain software; and
• Denial of access to EU airports for Iranian cargo flights and prohibitions on providing maintenance services to Iranian aircraft and vessels carrying prohibited goods.

Certain of the trade-related measures, including the prohibition on the importation, purchase or transport of Iranian crude, petroleum products, gas and petrochemical products, are subject to wind-down periods which permit the execution until 1 January 2026 of contracts concluded prior to 30 September 2025. By contrast, the reimposed asset freezes take immediate effect.

United Kingdom

On 29 September, the UK sanctioned 71 individuals and entities with links to Iran’s nuclear programme and introduced legislation to reinstate UN-derived measures. As at the date of this publication, the UK Government has not reimposed wider financial and trade restrictions on Iran equivalent to the EU measures but is expected to do so in the coming days and weeks.

General licences have been issued HM Treasury's Office of Financial Sanctions Implementation (OFSI) which permit the winding-down of or divestment from transactions involving certain asset freezing targets. Firms considering relying on a general licence should carefully assess the specific activity and expiry dates (which differ across the licences issued) to ensure that they fall within the scope of permissions.

Guidance published by OFSI confirms that any specific licences held prior to the lifting of sanctions under the JCPOA are no longer valid. So, following the end of wind-down periods, otherwise prohibited activity will need to be subject to new applications for specific licences.

 

State of play and further developments

While the E3 have been clear that further negotiation with Iran remains on the table, Iran has responded to the snapback decision by repeating its threat to withdraw from the Nuclear Non-Proliferation Treaty. Should it take such a step, the US, EU and UK may feel compelled to impose further rounds of sanctions targeting Tehran. International firms which continue to trade with Iran will therefore need to assess and respond to the developments of recent days and remain vigilant to the potential of a further tightening of restrictive measures targeting Iran.