EU Reintroduces Sanctions Against Iran Following UN Snapback

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.

1. ASSET-FREEZE MEASURES REIMPOSED

Going beyond UN-based designations, the EU has reinstated asset-freeze measures against more than 50 natural persons (“individuals”) and close to 200 legal persons, entities or bodies (“entities” and, collectively with individuals, “persons”), as listed in Annexes VIII and IX of Regulation 267/2012.

Targeted persons, which are located both inside and outside Iran, notably comprise major financial institutions, companies operating in the energy sector and shipping companies.

While most existing and/or standard exemptions or derogations have been maintained, limited additional exemptions and derogation grounds have been introduced.

2. TRADE CONTROLS MEASURES REIMPOSED

2.1 Scope of Trade Controls Measures

Export-related restrictions refer to prohibitions targeting the sale, supply, transfer or export of specific items, as well as—in most cases—ancillary services related to such items (technical assistance, brokering services, financing or financial assistance) to Iranian persons, entities or bodies (“Iranian persons”) or for use in Iran;

Import-related restrictions refer to prohibitions targeting the import, purchase or transport of specific items, as well as—in some cases—ancillary services, if they originate in, have been or are exported from and/or are located in Iran.

2.2 Export- and Import-Related Restrictions Dual-Use Items and Proliferation Items

Export- and import-related restrictions, which had been relaxed under the JCPOA, have been fully reintroduced as regards:

• Dual-use items, as listed in Annex I of the EU’s dual-use Regulation, excluding a subset of items specified in part A of Annex I of Regulation 267/2012 (“Dual-Use Items”).
• Goods and technology which could contribute to Iran’s nuclear proliferation-related activities, as listed in Annex II of Regulation 267/2012 (“Proliferation Items”).

Limited exemptions and derogations have been introduced, including a wind-down exemption until January 1, 2026 for contracts concluded before September 30, 2025 as regards Dual-Use Items listed in Part C of Annex I of Regulation 267/2012.

The measures reimposed are without prejudice to export- and import-related restrictions, as well as investment prohibitions in respect of items that could contribute to the development of nuclear weapon delivery systems, as identified in Annex III of Regulation 267/2012, which continue to apply.

2.3 Export-Related Restrictions on Energy Equipment, Naval Equipment, Industrial Software, Graphite & Metals

Export-related restrictions have also been reimposed as regards:

• Equipment and technology for the oil and gas industry (exploration or production of crude oil and natural gas, refining, liquefaction of natural gas) or petrochemical industry, as listed in Annexes VI and VIA of Regulation 267/2012 (“Energy Equipment”).
• Naval equipment or technology for shipbuilding, maintenance or refit, including equipment or technology used in the construction of oil tankers, as listed in Annex VIB of Regulation 267/2012 (“Naval Equipment”).
• Enterprise Resource Planning software, designed specifically for use in nuclear, military, gas, oil, navy, aviation, financial and construction industries, as listed in Annex VIIA of Regulation 267/2012 (“Industrial Software”).
• Graphite and raw or semifinished metals, including aluminum and steel, as listed in Annex VIIB of Regulation 267/2012.

Limited exemptions and derogations have been introduced, including a wind-down exemption until January 1, 2026 for contracts concluded before September 30, 2025 as regards Energy Equipment (provided they relate to an investment made in Iran before September 30, 2025), Naval Equipment and Industrial Software.

2.4 Targeted Export-Related Restrictions on Gold, Precious Metals & Diamonds and Banknotes & Coinage

Targeted export-related restrictions have been reintroduced as regards:

• Gold, precious metals and diamonds, as listed in Annex VII of Regulation 267/2012, but only to the Government of Iran, its public bodies, corporations and agencies and any person acting on their behalf or at their direction, or any entity or body owned or controlled by them.
• Newly printed or unissued Iranian denominated banknotes and minted coinage, but only to, or for the benefit of the Central Bank of Iran.

2.5 Import-Related Restrictions on Energy Products

Import-related restrictions have been reintroduced as regards:

• Crude oil or petroleum products, as listed in Annex IV of Regulation 267/2012 (“Oil Items”).
• Petrochemical products, as listed in Annex V of Regulation 267/2012 (“Petrochemical Items”).
• Natural gas, as listed in Annex IVa of Regulation 267/2012 (“Gas Items”).

Prohibitions also apply to swap of natural gas (i.e., exchange of natural gas streams of different origins) originating in or exported from Iran.

Limited exemptions have been introduced, including wind-down exemptions for certain contracts concluded before September 30, 2025 as regards Oil and Petrochemical Items.

2.6 Targeted Import-Related Restrictions on Gold, Precious Metals & Diamonds

Targeted import-related restrictions have been reintroduced as regards gold precious metals and diamonds, as listed in Annex VII of Regulation 267/2012, but only from the Government of Iran, its public bodies, corporations and agencies and any person acting on their behalf or at their direction, or any entity or body owned or controlled by them.

3. INVESTMENT/FINANCING PROHIBITIONS REIMPOSED

3.1 Restrictions on investment/financing in Iranian persons

Prohibitions target (i) the granting of financial loans or credits to, (ii) the acquisition or extension of participation in and (iii) the creation of joint ventures with (“Investment/Financing”) Iranian persons engaged in the following activities:

• The manufacture of (i) items listed in the Common Military List, (ii) Dual-Use Items or (iii) Proliferation Items.
• The exploration or production of crude oil and natural gas, the refining of fuels or the liquefaction of natural gas.
• The petrochemical industry.

Investment/Financing activities are subject to authorization if the Iranian person is engaged in the manufacture of nuclear proliferation-related items listed in Annex IIA of Regulation 267/2012.

Limited exemptions and derogations have been introduced.

3.2 Prohibition on cooperation with Iranian persons

Cooperation with Iranian persons engaged in the transmission of natural gas is also prohibited. This covers (i) the sharing of investment costs in an integrated or managed supply chain for the receipt or delivery of natural gas directly from or to the territory of Iran and (ii) direct cooperation for the purpose of investing in liquefied natural gas facilities within the territory of Iran or in liquefied natural gas facilities directly connected thereto.

3.3 Prohibitions on Investment/Financing by Iranian persons

Although similar provisions were already in force, Investment/Financing by Iranian persons in the following activities cannot be accepted or approved: (i) uranium mining, (ii) uranium enrichment and reprocessing or uranium or (iii) the manufacture of goods or technology included in the Nuclear Suppliers Group or Missile Technology Control Regime lists.

4. FINANCIAL RESTRICTIONS REIMPOSED

4.1 Restrictions on Transfers of Funds

Complex restrictions on transfers of funds have been reintroduced. They depend on (i) the purpose and amount of the transaction and (ii) whether Iranian credit or financial institutions or other Iranian persons are involved.

4.1.1 Transfers of funds involving Iran-related financial institutions and bureaux de change:

Transfers of funds between EU financial and credit institutions and the following institutions are prohibited:

• Credit and financial institutions or bureaux de change domiciled in Iran.
• Their EU and non-EU branches and subsidiaries.
• Credit and financial institutions or bureaux de change outside Iran controlled by persons domiciled in Iran.

(together, “Iran-Related Institutions”)

Transfers of funds involving Iran-Related Institutions can only be authorized based on specific grounds, including, but not limited to, transfers (i) regarding foodstuffs, healthcare, medical equipment, or for agricultural or humanitarian purposes, (ii) regarding personal remittances or (iii) in connection with a specific trade contract (provided that such transfer is not prohibited under Regulation 267/2012).

4.1.2 Other transfers of funds to or from Iranian persons:

Transfers of funds to or from Iranian persons, even if they do not involve Iran-Related Institutions, are also subject to restrictions (e.g., transfers to a bank account of an Iranian person held with a bank that does not qualify as an Iran-Related Institution).

These transfers can be authorized, regardless of the purpose of the transfer of funds.

4.1.3 Authorization grounds and mechanisms

Transfers of funds will either be automatically authorized, subject to advanced notification or require a prior authorization based on value thresholds and their intended purpose:

The above thresholds apply to transfers of funds executed in a single operation or in several operations which appear to be linked.

Regulation 267/2012 further specifies who is responsible for obtaining authorizations from or making advanced notifications to the national competent authority (“NCA”).

Exemptions apply in connection with transfer of funds covered by certain derogations / exemptions under asset-freeze measures, while certain activities are specifically excluded from these restrictions.

4.1.4 Additional provisions relating to transfers of funds

Reporting obligations relating to transfers of funds have been introduced for EU branches and subsidiaries of credit and financial institutions domiciled in Iran, while provisions have been introduced to protect disclosures made in good faith from potential liability of any kind.

4.2 Enhanced Vigilance Requirements for EU Financial and Credit Institutions

EU financial and credit institutions must conduct enhanced vigilance to ensure compliance with Regulation 267/2012. This consists of (i) continuous vigilance over account activity, including through KYC, (ii) requiring all information on originator and beneficiary in payment instructions to be completed and refusing transactions otherwise, (iii) maintaining records of transactions for five years and (iv) making suspicious activity reports to Financial Intelligence Unit in case of potential breaches.

4.3 Application of Financial Messaging Services Restrictions to Re-Designated Persons

Regulation 267/2012 already provided for prohibitions to provide financial messaging services to persons designated under asset-freeze measures. Accordingly, the designations described above automatically extend the list of persons targeted by such restrictions.

4.4 Restrictions on EU Credit and Financial Institutions’ Relationships with Iran-Related Institutions  or Presence in Iran

EU credit and financial institutions are prohibited from (i) opening new bank accounts with Iran-Related Institutions, (ii) establishing new correspondent banking relationships with Iran-Related Institutions, (iii) opening new representative offices in Iran or establishing branches or subsidiaries in Iran and (iv) establishing new joint ventures with Iran-Related Institutions.

4.5 Restrictions on Iran-Related Institutions’ Presence in the EU

Prohibitions target (i) agreements pertaining to the opening of representative offices or establishment of branches or subsidiaries in the EU by Iran-Related Institutions, (ii) authorizations for taking up and pursuing businesses requiring prior authorization (e.g., credit institutions), by a representative office, branch or subsidiary of an Iran-Related Institutions that was not operational before September 30, 2025 and (iii) the acquisition or extension of a participation or other ownership interest in EU credit or financial institutions by Iran-Related Institutions.

4.6 Restrictions Targeting Certain Public or Public-Guaranteed Bonds

Prohibitions target (i) the sale or purchase of public or public-guaranteed bonds issued after September 30, 2025 to or from (a) Iran or its Government, and its public bodies, corporations and agencies, (b) Iran-Related Institutions, (c) individuals or entities acting on their behalf or at their direction and (d) entities owned or controlled by them as well as (ii) brokering services with regard to such public or public-guaranteed provided to the aforementioned persons and (iii) assisting the aforementioned persons in order to issue public or public-guaranteed bonds, by providing any service with regard to such bonds, including brokering services or advertising.

4.7 Restrictions Targeting (Re)Insurance and (Re)Insurance Brokering

Prohibitions target the provision of (re)insurance and (re)insurance brokering to (i) Iran or its Government, and its public bodies, corporations and agencies, (ii) Iranian persons other than a natural person or (iii) persons acting on behalf or at the direction of the aforementioned entities (excluding where that direction is for the purposes of docking, loading, unloading or safe transit of a vessel or aircraft temporarily in Iranian waters or airspace).

Limited exemptions and derogations have been introduced, including for the execution of contracts concluded before September 30, 2025, provided this does not involve making available funds or economic resources to asset-freeze targets. The extension or renewal of these contracts is not permitted.

5. MEASURES AFFECTING THE TRANSPORT SECTOR REIMPOSED

5.1 Prohibition of Services to Iranian Oil Tankers and Cargo

Prohibitions, which apply from 1 January 2026, target the provision of the following professional services to oil tankers and cargo flying the Iranian flag or owned, chartered or operated by Iranian persons:  (i) classification services, (ii) services related to the design, construction and repair of ships and their parts (including ancillary services), (iii) services related to inspection, testing or certification of certain equipment, materials, components or systems and (iv) services related to certificates and documents of compliance on behalf of the flag State administration.

5.2 Prohibition on making available vessels for the transport or storage of oil and petrochemical products

Prohibitions target the making available of such vessels to (i) Iranian persons and (ii) any other person, if the vessels provider has not taken appropriate action to prevent the vessel from being used to carry or store oil or petrochemical products originating in or exported from Iran.

Limited exemptions apply.

6. BROAD SCOPE OF RESTRICTIONS TARGETING IRANIAN PERSONS

Export-related restrictions, Investments/Financing restrictions, transfer of funds restrictions, (re)insurance and (re)insurance brokering restrictions and transport-related restrictions target, in broad terms, Iranian persons.

EU operators should be mindful that, pursuant to Article 1(o) of Regulation 267/2012, Iranian persons encompass not only (i) the State of Iran or any public authority thereof, (ii) any individual in, or resident in, Iran, (iii) any entity having its registered office in Iran but also (iv) any entity, inside or outside Iran, owned or controlled directly or indirectly by one or more of the above mentioned individuals or entities.

Accordingly, beyond asset-freeze designations targeting parties located outside Iran and/or circumvention risks associated with the reimposition of sanctions against Iran, such sanctions may also apply to transactions which prima facie do not present any link to Iran but involve parties that are owned or controlled by Iranian persons.