Iran sanctions snapback: Council reimposes restrictive measures
Today, the Council agreed to reimpose a number of restrictive measures in relation to Iran’s nuclear proliferation activities, that had then been suspended with the entry into force of the Joint Plan of Action (JCPoA or Iran nuclear deal) in 2015.
The decision was taken after the reintroduction of the UN sanctions, following of the UN Security Council’s decision not to extend the lifting of sanctions on Iran. This occurred after the E3 (France, Germany and the United Kingdom) invoked the “snapback” mechanism foreseen in the JCPoA.
The measures reintroduced today include both those adopted by the UN Security Council since 2006 with successive UNSC resolutions and automatically transposed into EU law, and EU autonomous measures. They concern:
- travel bans for individuals, asset freezes for individuals and entities and, in line with this, the prohibition on making funds or economic resources available to those listed
- economic and financial sanctions, covering the trade, financial and transport sectors.
Trade
In addition to the arms export ban to Iran and the ban on transfer of any items, materials, good and technology that could contribute to Iran’s enrichment-related and reprocessing activities and ballistic missile programmes, the measures also include bans on:
- imports purchase and transport of crude oil, natural gas, petrochemical and petroleum products and related services
- the sale or supply of key equipment used in the energy sector
- the sale or supply of gold, other precious metals and diamonds
- certain naval equipment
- a ban on certain software
Financial sector
The EU is reimposing the freezing of assets of the Central Bank of Iran and of major Iranian commercial banks.
Transport sector
Lastly the EU is reinstating measures to prevent access to EU airports of Iranian cargo flights, and to prohibit the maintenance and service of Iranian cargo aircraft or vessels carrying prohibited materials or goods.
Background
On 14 July 2015, the five permanent members of the UN Security Council (China, France, the Russian Federation, the United Kingdom and the United States) plus Germany, supported by the EU High Representative for Foreign Affairs and Security Policy, reached an agreement with Iran on a long-term comprehensive solution to the Iranian nuclear issue. The plan set out a series of successive steps to ensure that Iran’s nuclear programme would exist exclusively for civilian and peaceful purposes.
The UNSC consequently adopted resolution 2231(2015) endorsing the JCPoA in July 2015. The resolution also defined the schedule and commitments to be undertaken by all parties to lead to the termination of sanction against Iran on 16 January 2016 (implementation day).
In October 2015 the Council adopted declaration 2015/C 345/01 lifting all EU nuclear-related sanctions in accordance with the JCPoA and stressing that the EU would reintroduce sanctions in case of significant non-performance by Iran of its commitments under the agreement, upon joint recommendation to the Council by the High Representative and the E3.
On 28 August 2025, the E3 notified to the UN Security Council their assessment that Iran was in significant non-performance of its commitments under the JCPoA, therefore triggering the “snapback” process providing for the re-introduction of UN sanctions, after a 30-day period. On August 29, the High Representative, France and Germany sent a joint recommendation to the Council calling for the reintroduction of all EU nuclear-related sanctions that had been suspended or terminated (2015/C 345/01 of 18 October 2015). In absence of a new resolution from the UN Security Council regarding the prevention of the ‘snapback’ of UN sanctions on Iran on September 17, 2025, the sanctions regime is re-imposed.