Iranian Sanctions “Snapback”: Implications for Businesses of the Reimposition of EU and UK Sanctions

On 29 September 2025, the United Kingdom (“UK”) and the European Union (“EU”) reimposed Iran-related sanctions that were lifted in 2016 following the Iran nuclear deal. The UK and EU have made clear that these steps follow Iran’s failure to comply with its obligations under the Iran nuclear deal (the “Nuclear Deal”), as endorsed by United Nations (“UN”) Security Council Resolution 2231 (2015) (“UNSCR 2231”). This change marks an abrupt end to a period when Europe took a more open approach to doing business with Iran, while the United States (“U.S.”) had maintained a comprehensive sanctions program against Iran. We discuss below some of the key restrictions that have been reimposed and the practical implications this is likely to have for businesses.

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