Jurisdiction(s):
United Kingdom

Iran sanctions snapback: UN re‑imposes measures; EU widens restrictions; UK designations—heightened compliance and secondary sanctions risks for UK and multinational businesses

Published on: 21 October 2025

Published by a Law360 reporter

Legal News

Article summary

This package of measures spans financial penalties, travel prohibitions, asset freezes and bans on exporting materials, goods and technologies that aid Iran’s nuclear and ballistic missile programmes. Paused by the UN under the Joint Comprehensive Plan of Action (JCPOA) brokered in 2015 by the Obama administration alongside China, France, Germany, Russia and the UK, these restrictions are now being revived by the relevant authorities. The Office of Foreign Assets Control (OFAC) has already unveiled two waves of new entries to its Specially Designated Nationals and Blocked Persons (SDN) list to underpin the snapback. On 29 September 2025, the European Commission likewise moved to reinstate all of these measures—and additional ones beyond the prior scope. On 30 September 2025, the UK named 71 individuals as part of a staged approach to reimpose UN sanctions. It would be a mistake to regard the snapback as merely symbolic or harmless to US companies, given over four decades of US sanctions that have sharply curtailed US trade with Iran. Since returning to office, the Trump administration has been methodically intensifying sanctions on Iran, and this latest step may shift OFAC’s compliance expectations and its broader enforcement posture overall...

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