Re-Imposition Of Un Sanctions On Iran – What Does The “Snapback” Mean For Operators?

On 28 August 2025, the “snapback” mechanism built into United Nations Security Council Resolution (UNSCR) 2231 was activated by the UK, France and Germany (together, the E3).

This resulted in the automatic reimposition on 27 September 2025 of the UN’s package of nuclear and weapons related measures that were previously suspended under the 2016 Joint Comprehensive Plan of Action (the JCPOA). The EU and the UK have moved to re-apply parallel sanctions measures and national designations, with the UK already issuing general licences to allow for limited wind-down activity. The snapback has wide ranging consequences for Iran’s international trade, banking, logistics, and presents a significant compliance risk for global operators.

Published by Holman Fenwick Willan

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