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ARTICLE · 07 OCTOBER 2025

The EU And UK Act To Implement The Iran Sanctions "Snapback"

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The snapback of UN sanctions on Iran took effect on September 27, 2025, after the E3 (France, Germany, UK) triggered the mechanism under UN Security Council Resolution 2231 and the Security Council failed to extend sanctions relief.

GlobalInternational Law
Erik Woodhouse
Erik Woodhouse
Sophie Davis
Sophie Davis
Tim Laderach
Tim Laderach

The snapback of UN sanctions on Iran took effect on September 27, 2025, after the E3 (France, Germany, UK) triggered the mechanism under UN Security Council Resolution 2231 and the Security Council failed to extend sanctions relief. Please see our previous Alert on the snapback process and what this could mean for global businesses.

The EU and UK have begun to re-impose on Iran their respective sanctions pre-dating the Joint Comprehensive Plan of Action (JCPOA).

  • EU Actions: On September 29, the EU announced the re-imposition of a broad array of restrictive measures on Iran:
    • Council Regulation 2025/1975: Amends Council Regulation 267/2012, restoring sectoral and trade sanctions, including:
      • bans on the supply to Iran of nuclear and ballistic missile-related items, gold, precious metals, diamonds, certain software, and key equipment for the energy sector;

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