Iran sanctions - snapback of UN sanctions with additional autonomous measures imposed by the EU and UK
Recent developments have resulted in the full reinstatement of UN sanctions against Iran, targeting the country's nuclear and ballistic missiles programmes. This, in turn, has triggered the EU and UK to adopt even broader restrictions against certain sectors in Iran and against persons and individuals connected with Iran.
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This Sanctions Alert provides a brief overview of recent key developments following the re-entry into force of sanctions on Iran.
Background and Key Developments
On Friday 19 September 2025, the UN Security Council (UNSC) rejected a proposal for continued sanctions relief for Iran under the JointComprehensive Plan of Action (JCPOA), due to Iran's reportedly persistent breach of its nuclear commitments under the JCPOA. The UNSC's decision has triggered a so-called snapback mechanism in the JCPOA, resulting in the automatic reimposition of all nuclear related UN sanctions against Iran.
The reimposed UN sanctions on Iran include:
- 121 designations of persons involved in Iran's nuclear and ballistic missiles programme;
- Travel bans on the listed individuals;
- An embargo on transfers of conventional arms to and from Iran; and
- Comprehensive trade restrictions on nuclear and ballistic missile related transfers and activities, including prohibitions on the sale, supply and transfer of listed goods and technologies, as well as on the provision of related technical, financial and other services.
National and multinational frameworks of UN Member States are being adjusted accordingly.
Within the EU, the Iran sanctions are reintroduced through Decision 2010/413/CFSP and Regulation (EU) No 267/2012 concerning restrictive measures against Iran. Effective 29 September 2025, the EU regime was also amended to include autonomous measures targeting, amongst other things, trade in natural gas, crude oil and petroleum products and gold and other precious metals, as well as supplies of equipment to Iran's energy sector . Certain restrictions are also imposed on naval equipment and software.
In the UK, the reimposed UN sanctions have been implemented in the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019. The framework also sets forth UK autonomous measures, including the listing of 70 individuals linked to Iran's nuclear programme.
Failure to adhere to these requirements may result in enforcement action or criminal proceedings as set out in relevant national legislation.
International Context and Political Reactions
Iran has strongly objected to the snapback action, labelling it as 'unfair, unjust, and illegal'. Iranian officials have specifically challenged the legal basis for the snapback, arguing that the mechanism cannot be validly triggered by parties to an agreement that the United States withdrew from in 2018. Iranian authorities have warned that the reimposition of sanctions will provoke a 'firm and appropriate response', and their parliament has considered measures such as reviewing Iran's commitment to the Nuclear Non-Proliferation Treaty. Despite these threats, Iran's president has stated that the country does not intend to pursue nuclear weapons or withdraw from the Treaty, but insists that it needs security guarantees from the international community.
Russia and China have also expressed strong opposition to the snapback, including endorsing Iran's argument that the mechanism lacks legal validity since it was triggered by parties to an agreement that the US had already withdrawn from. Both countries continue to maintain economic ties with Iran, particularly in the energy sector, and have signalled that they may not fully implement all aspects of the renewed sanctions.
Internationally, the snapback increases the risk of Iran's further isolation from global financial and trading systems. Market uncertainty has been reflected in currency volatility and fluctuating commodity prices. At the same time, Western officials have stressed that the reimposition of sanctions is not the end of diplomatic engagement and have urged Iran to avoid any escalatory actions.
WR Sanctions Alerts provide you with updates on material developments in the country-specific sanctions programmes implemented by the US, the UN, the UK, the EU and Norway. We will not provide updates on mere prolongations, without material changes, of existing sanctions programmes, nor on any listings or de-listings of individuals/entities placed on implemented sanctions lists. Please note that the WR Sanctions Alerts are provided as general information and do not constitute legal advice.