France, Germany and the UK have invoked the “snapback” mechanism under the Iran nuclear deal, and the Council has agreed to reinstate suspended sanctions on Iran. The measures include restrictions on trade, finance, transport, and listings of individuals and entities, thereby significantly tightening the regulatory environment for businesses engaged in Iran-related activities. Any Iran-related activities should only take place following a thorough sanctions compliance assessment.
Significant UN and EU trade sanctions against Iran have been reimposed – 10 years after all nuclear-related sanctions against Iran were lifted under the Joint Comprehensive Plan of Action (“JCPoA”). Recent assessments by three of the European participants in the agreement, France, Germany and the UK, indicate Iran to be in significant non-performance of its commitments undertaken as part of the JCPoA. Consequently, on 29 September 2025, the EU Council agreed to reimpose the nuclear-related sanctions against Iran that had been suspended or terminated.
The measures are set out in several regulations and decisions accessible in the Official Journal here. The main restrictions are set out in Council Regulation (EU) No 267/2012, as amended by Regulation (EU) 2025/1975, which is accessible here.
Below, we have summarized the most significant sanctions against Iran.
The EU is reinstating measures that freeze the assets of the Central Bank of Iran and major Iranian commercial banks. This means that it is prohibited to directly or indirectly make funds and economic resources available to these entities.
Another notable measure is the prohibition against transferring funds to or from Iranian credit or financial institutions. The prohibition contains a de minimis exemption for fund transfers below EUR 10,000. For transfers above this threshold, either a prior notification or authorisation is required to the national competent authority depending on the size of the transfer and to what the transfer relates.
It is also prohibited to sell, supply, transfer or export newly printed or unissued Iranian denominated banknotes and minted coinage. Further, it is prohibited to grant any financial loan or credit, or otherwise participate financially in any Iranian entity, body, or person involved in exploration or production of crude oil, natural gas, the refining of fuels, the petrochemical industry or the manufacture of goods or technology listed in the Common Military List. The same financial restrictions apply to the financing of Iranian enterprises engaging in uranium-related activities.
The sanctions include a broadly scoped import ban. It is prohibited to import crude oil, natural gas, petrochemicals and petroleum products originating from Iran. In addition, the import restrictions cover goods and technology listed in Annex I (dual-use items) and Annex II (goods and technology which could contribute to Iran’s nuclear program). For companies that have concluded contracts before 30 September 2025, or of ancillary contracts for the execution of such contracts, transitional provisions have been adopted. The restrictions will not apply to those contracts until 1 January 2026.
Several export restrictions are now applicable. This includes an arms export ban to Iran. Exports of goods, nuclear-related equipment and technology that could contribute to Iran’s enrichment, reprocessing or ballistic missile programmes are prohibited. The restrictions also extend to the supply of key equipment for the energy sector, as well as naval equipment and specified software. Providing technical assistance or services in relation to the prohibited goods and technology is also prohibited. Furthermore, the export of gold, precious metals and diamonds to Iran is banned, thereby closing off additional sources of financial support to the regime.
The measures impose limitations on both air and maritime transport. EU operators must not supply Iranian vessels with bunkers, provide ship supply services, or any other services, where there are reasonable grounds to determine that the vessel is carrying prohibited goods. In relation to cargo aircrafts, EU operators must not provide engineering and maintenance services, where there are reasonable grounds to determine that the aircraft is carrying prohibited goods. The prohibitions apply until the cargo has been inspected and, if necessary, seized or disposed of.
Further, vessels designed for the transport or storage of oil and petrochemical products must not be made available to Iranian persons, entities, or bodies. Additionally, those vessels must not be made available to any other person, entity, or body, unless the provider of the vessels has taken appropriate action to prevent the vessel from being used to carry or store oil or petrochemical products that originate in Iran or have been exported from Iran. Consequently, companies should have clear, risk-based due diligence measures in place to verify counterparties and confirm the origin of any oil or petrochemical products carried.
A number of individuals and entities associated with Iran’s nuclear and military programmes have been added to the EU’s sanctions list. These listings impose travel bans and asset freezes for individuals. Entities are subject to asset freezes. EU individuals and entities are prohibited from making funds or economic resources available to the listed persons and entities. The asset freeze designations include several members of the Islamic Revolutionary Guard Corps. Therefore, companies that operate in Iran or countries with close geographic, economic, military or political ties to Iran should implement due diligence measures to screen their business partners to ensure that they are not sanctioned, or owned or controlled by sanctioned parties.
Companies with exposure to Iran-related trade or financial activities are encouraged to review their operations carefully to ensure compliance with the reinstated EU sanctions. Gorrissen Federspiel closely follows the developments of export controls and sanctions, and we can assist with interpretation of and compliance with applicable sanctions as well as the implementation of measures to ensure that sanctions are observed. If you have any questions, please feel free to contact a member of our Compliance & Sustainability team.