Overview
Guy Soussan, Algirdas Semeta, and Ana Amador recently authored an article that appeared in Law360, "What To Know About EU's Reimposition of Sanctions on Iran." The article discusses the European Union's decision to reimpose a comprehensive set of restrictive measures against Iran, following the snapback of nuclear-related sanctions at the United Nations level. These measures, which took effect on September 29 and 30, 2025, span six legal instruments and include both previously adopted UN sanctions transposed into EU law and additional autonomous EU sanctions.
The reinstated sanctions target key sectors of Iran's economy – trade, finance, and transportation – through bans on dual-use goods, oil and gas equipment, and financial services. The EU has redesignated 54 individuals and 178 entities, including major Iranian financial institutions and energy companies, subjecting them to asset freezes and prohibitions on economic resource transfers.
The article outlines the implications for EU operators, emphasizing the need for enhanced due diligence, reassessment of contractual obligations, and awareness of circumvention risks. Transitional provisions allow certain pre-existing contracts to be executed until January 1, 2026, under strict conditions.
Read the full article at Law360.
