On 29 September 2025, United Nations (“UN”) nuclear-related sanctions against Iran, which were suspended in 2015, were reimposed following action at the UN Security Council by France, Germany, and the United Kingdom. In parallel, the European Union (“EU”) and United Kingdom (“UK”) also reintroduced autonomous sanctions measures against Iran that were eased in 2015.

This alert summarizes the reintroduced UN and European sanctions.

Certain nuclear-related sanctions mandated by the UN Security Council against Iran were suspended in 2015 pursuant to the Joint Comprehensive Plan of Action (“JCPOA”), an agreement between Iran and the permanent members of the UN Security Council, together with Germany and the European Union. The JCPOA provided for certain UN and autonomous national sanctions against Iran to be eased in return for commitments on Iran’s part to limit the scope, and allow for external monitoring, of its nuclear program. The agreed suspension of UN sanctions was implemented pursuant to UN Security Council Resolution 2231 (“Resolution 2231”).

Resolution 2231 included a mechanism allowing any JCPOA “participant state” to trigger reimposition of the UN sanctions eased pursuant to the JCPOA—i.e., to “snap back”—if that state determined that Iran was not meeting its JCPOA commitments. Germany, France and the United Kingdom submitted a notification to the Security Council on 28 August 2025 of their intention to cause the snap-back of the suspended UN sanctions. Submission of that notice triggered the automatic snap-back of relevant UN sanctions on Iran—without requiring approval from other UN Security Council members (such as China, and Iran’s ally, Russia)—following a 30-day consultation period. Because no agreement was reached with Iran in the intervening 30 days, the UN sanctions were reimposed on 29 September.

Consequently, all members of the UN are now required to reintroduce the previously-suspended Iran sanctions measures under their national laws. Those sanctions are set out in UN Security Council Resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008), 1929 (2010) and 2224 (2015), and include a range of export control provisions (largely focused on military and nuclear-sector goods, software and technology), and asset-freezing sanctions. The UN asset-freezing sanctions focus on persons and entities involved in Iran’s nuclear and/or military sectors, but include several entities that also have wider commercial sector activities— such as, for instance, a major Iranian bank, Bank Sepah.

The EU’s nuclear-related sanctions regime concerning Iran is set out in Council Regulation (EU) No. 267/2012. That regulation had included, prior to the implementation of the JCPOA in 2015, both UN-mandated sanctions as well as autonomous EU sanctions against Iran that extended well beyond the UN measures.

On 29 September 2025, the Council of the European Union adopted three regulations reintroducing both the UN-mandated and the autonomous EU sanctions.

Asset Freezing Designations

The EU has reintroduced asset-freezing sanctions against a wide range of Iran-affiliated persons and entities. These include both UN-mandated designations, reinstated through Council Implementing Regulation (EU) 2025/1982, and EU autonomous designations, reinstated through Council Implementing Regulation (EU) 2025/1980.

The EU designations include the Central Bank of Iran and a number of other Iranian financial institutions that were not designated by the UN, such as Bank Melli, Bank Mellat, Bank Saderat, Sina Bank, and the Europäisch-Iranische Handelsbank (EIH) in Germany. The designations also extend to certain Iranian government entities and affiliated organizations, including the Ministry of Energy and the National Iranian Oil Company (and affiliates thereof).

Persons subject to EU sanctions jurisdiction are broadly restricted from dealing, directly or indirectly, with the newly-listed persons and entities, or with any entity in which designated parties own a 50% or greater interest or that they otherwise control.

Sectoral Sanctions

Council Regulation (EU) 2025/1975 (“Regulation 1975”) reinstates UN-mandated and autonomous EU trade, financial, investment, and transport restrictions under Regulation 267/2012, including the following key measures:

• Export/import and associated services restrictions: Regulation 1975 reinstates prohibitions on exports to Iran—and, for certain restricted goods, imports from Iran—covering a broad range of goods and technology, including dual-use items, nuclear sector goods (Annexes II, IIA), and oil and gas industry equipment (Annexes VI,VIA) (among other items).
    
  The restrictions also extend to the provision of technical assistance, brokering services, and financial support related to restricted items. Many of these restrictions are subject to narrow exemptions and licensing provisions, including a wind-down exemption allowing the performance of contracts concluded before 30 September 2025, provided these are completed by 1 January 2026.
   
  Regulation 1975 also imposes heightened customs declaration requirements for exports to Iran, requiring the declarant to represent that the goods in question are not subject to Iran-related export restrictions.
• Iranian energy import restrictions: Regulation 1975 reintroduces restrictions against the import, purchase, and transport of Iranian crude oil, petroleum products (Annex IV), natural gas (Annex IVA), and petrochemicals (Annex V), as well as any financing, insurance, or related services concerning the foregoing. These restrictions are subject to narrow exemptions, including for the execution of pre-existing contracts entered into before 30 September 2025, which may be carried out until 1 January 2026.
• Investment restrictions: The reintroduced measures also include prohibitions—subject to narrow exemptions and licensing provisions—on investments in Iranian entities operating in the military or energy sectors, as well as investments by Iranian persons in companies that are engaged in uranium mining, enrichment, and processing.
• Funds transfer restrictions: Regulation 1975 reintroduces broad restrictions—set out in Articles 30 and 30a of Regulation 267/2012—on funds transfers to and from Iranian banks or persons/entities in Iran. Those restrictions are subject to notification and/or prior licensing requirements, depending on the purpose of a given funds transfer and its amount: the regulation includes higher licensing/notification monetary thresholds for funds transfers focused on food, healthcare, medicines, or other humanitarian purposes.
    
  The new Articles 30 and 30a will be of particular relevance for EU healthcare companies that operate in Iran or supply goods or services to Iran. Such companies faced only limited EU-Iran sanctions restrictions under the JCPOA framework, but now may be required to submit periodic notices to competent Member State regulators, and/or seek and obtain prior licensing, in connection with routine funds transfers to and from Iran.
• Other financial services restrictions: Regulation 1975 prohibits EU financial institutions from opening new accounts for Iranian banks, establishing subsidiaries or representative offices in Iran, entering into correspondent banking relationships with Iranian banks, or forming joint ventures with Iranian banks. Transactions involving public or publicly guaranteed bonds issued by the Iranian government or Iranian entities after 30 September 2025 are also restricted, along with the provision of insurance and reinsurance services to Iranian entities or the Iranian government.
    
  The new measures also restrict exports of newly printed or unissued Iranian banknotes and coinage for the Central Bank of Iran.
• Transport restrictions: Regulation 1975 restricts the provision of vessels for transporting Iranian oil and petrochemical products, as well as certain classification services for Iranian vessels.

UK Sanctions

In parallel with the EU, the United Kingdom too has taken steps to reintroduce sanctions on Iran following the activation of the UN “snap-back” mechanism. On 1 October 2025, the Iran (Sanctions) (Nuclear) (EU Exit) (Amendment) Regulations 2025, which amend the existing Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019, entered into force. Those amendments reinstate UN-mandated trade controls restrictions relating to Iran. The UK has also acted to reintroduce asset-freezing measures against Iran, including UN-mandated designations as well as autonomous EU designations that were eased under the JCPOA in 2015 (and which the UK had applied prior to 2015, as a Member State of the EU).

The UK government has not yet fully implemented the autonomous EU export/import controls and services restrictions against Iran, but it has announced its intention to introduce further measures in the near future, targeting key sectors such as finance, energy, shipping, and software. Those sanctions ultimately may closely track the EU autonomous trade sanctions that were eased in 2015—and which the EU has now reintroduced, as per the summary above.

To facilitate an orderly wind-down of pre-existing transactions, the Office of Financial Sanctions Implementation (“OFSI”) has issued four general licences. The licences authorise, subject to certain conditions, the following activities for a limited period:

• the wind-down of transactions with certain UK-based Iranian banks;
• the wind-down of transactions with certain Iranian banks established both inside and outside Iran;
• the wind-down or divestment of transactions involving the Iran Insurance Company and the National Iranian Oil Company (NIOC) International Affairs Ltd.; and
• the continued provision of goods, services and financing in connection with the Shah Deniz gas project.

President Trump announced in 2018 that he was withdrawing the United States from the JCPOA and that virtually all U.S. sanctions with respect to Iran that were in place prior to adoption of the JCPOA would be re-imposed. The re-imposition of those sanctions took effect on November 4, 2018.

Those sanctions have remained in place since 2018, and have been augmented over time by additional sanctions announcements by the U.S. government. The Biden Administration offered to ease those sanctions if Iran would agree to a negotiated return to compliance with the JCPOA by both Iran and the United States, but no agreement was ever reached with Iran to do that. Especially since President Trump returned to office and directed in February 2025 the restoration of a “maximum pressure” policy toward Iran, the pace of sanctions designations directed toward Iran and entities doing business with Iran has intensified. Many of these announcements have focused on entities involved in the export of Iranian oil in defiance of U.S. secondary sanctions on Iran.

As a consequence of the existing architecture of U.S. sanctions targeting Iran, no action was required of the United States in order to implement the snapback of UN sanctions on Iran. The Trump Administration used the occasion of the UN snapback to announce on October 1 the imposition of an additional round of weapons-related sanctions “in support of the ‘snapback’ of U.N. sanctions”, but, like the other sanctions that the United States has imposed in the years since 2018, those were autonomous U.S. sanctions going beyond the requirements of UN Security Council-mandated sanctions on Iran.

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We continue to closely monitor developments concerning the U.S., UK, and EU sanctions against Iran, and will issue further updates in the event of material developments. In the meantime, we would be happy to address any questions you may have.

Covington’s International Trade Controls team, which includes lawyers in the firm’s offices in the United States, London and the European Union, regularly advises clients across business sectors concerning the full range of U.S. and European export controls and sanctions regulations. Our trade controls lawyers work regularly with Covington's Global Public Policy team—consisting of over 120 former diplomats and policymakers in the United States, Europe, the Middle East, Latin America, Africa, and Asia—many of whom have had substantial government experience in sanctions and export controls matters, and who regularly advise our clients on emerging sanctions policy matters and related engagements with government stakeholders.