The "Snapback" Of Sanctions On Iran

This post summarises the potential impact of the reimposition of sanctions on Iran following the "snapback" triggered under the Joint Comprehensive Plan of Action.

United Nations sanctions in relation to Iran's nuclear proliferation activities came back into force on 28 September 2025 following a decision by the UN Security Council not to prevent the "snapback" of sanctions under the Joint Comprehensive Plan of Action (the "JCPOA").

As set out in our previous blog, the E3 (UK, France and Germany) initiated the "snapback" process on 28 August 2025. This triggered a 30-day period in which the E3 could withdraw the "trigger" or the UN Security Council could pass a resolution to maintain the JCPOA. A proposed resolution to extend the suspension of sanctions was rejected by the Security Council and so UN sanctions on Iran were reimposed. By way of reminder, the reintroduced UN restrictive measures include: