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ARTICLE · 06 OCTOBER 2025

EU Reintroduces Sanctions Against Iran Following UN Snapback

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Following the activation of the snapback mechanism set forth in United Nations Security Council's ("UNSC") Resolution 2231 (2015) by the E3...

GlobalInternational Law
Edouard Gergondet
Edouard Gergondet
Paulette Vander Schueren
Paulette Vander Schueren
Nikolay Mizulin
Nikolay Mizulin
Sarah Bakchi
Sarah Bakchi
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Following the activation of the snapback mechanism set forth in United Nations Security Council's ("UNSC") Resolution 2231 (2015) by the E3 (France, Germany and the United Kingdom), all nuclear-related sanctions on Iran imposed by the UNSC that had been lifted under the 2015 Joint Comprehensive Plan of Action ("JCPOA") were reinstated effective September 27, at 8 p.m. Eastern Daylight Time.

Consistent with commitments made back in October 18, 2015, the Council of the European Union ("EU") reimposed both UN-based and autonomous sanctions that had been suspended as part of the JCPOA.

Such sanctions were reimposed through amendments to the EU's proliferation-related regime targeting Iran, as contained in Regulation 267/2012. Designations under asset-freeze measures were reinstated by Regulation 2025/1980 and Regulation 2025/1982, effective as of September 29, 2025, while sectoral sanctions were reinstated by Regulation 2025/1975, effective as of September 30, 2025.

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