“E3 Snaps Back: Why Europe’s Tougher Stance on Iran Increases Risk for Global Business,” Global Investigations Review

Partners Rachel Alpert and Rob Dalling co-authored an article for Global Investigations Review examining the E3's reimposition of UN sanctions against Iran and the compliance implications for global businesses navigating the newly aligned EU, UK, and US sanctions regimes.

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In late September 2025, the UK, France, and Germany invoked the "snap-back" mechanism under the Joint Comprehensive Plan of Action (JCPOA), reversing years of more lenient European sanctions policy. The E3 acted after Iran's uranium enrichment program reached 48 times the JCPOA limit and the country failed to cooperate with IAEA inspectors.

The reimposed sanctions include asset freezes targeting major Iranian entities and embargoes on conventional weapons and dual-use goods. While the UK government issued general licenses to permit limited wind-down activities, Rob and Rachel note these "carve-outs are a pragmatic nod to reality, but they won't shield unprepared compliance teams from OFSI scrutiny."

The authors emphasize that companies must act swiftly to assess exposures, wind down where needed, and strengthen compliance programs in response to the heightened sanctions landscape.

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© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

“E3 Snaps Back: Why Europe’s Tougher Stance on Iran Increases Risk for Global Business,” Global Investigations Review

Partners Rachel Alpert and Rob Dalling co-authored an article for Global Investigations Review examining the E3's reimposition of UN sanctions against Iran and the compliance implications for global businesses navigating the newly aligned EU, UK, and US sanctions regimes.

Read More

In late September 2025, the UK, France, and Germany invoked the "snap-back" mechanism under the Joint Comprehensive Plan of Action (JCPOA), reversing years of more lenient European sanctions policy. The E3 acted after Iran's uranium enrichment program reached 48 times the JCPOA limit and the country failed to cooperate with IAEA inspectors.

The reimposed sanctions include asset freezes targeting major Iranian entities and embargoes on conventional weapons and dual-use goods. While the UK government issued general licenses to permit limited wind-down activities, Rob and Rachel note these "carve-outs are a pragmatic nod to reality, but they won't shield unprepared compliance teams from OFSI scrutiny."

The authors emphasize that companies must act swiftly to assess exposures, wind down where needed, and strengthen compliance programs in response to the heightened sanctions landscape.

Related Capabilities

Related Locations

© 2026 Jenner & Block LLP. Attorney Advertising. Jenner & Block LLP is an Illinois Limited Liability Partnership including professional corporations. This publication, presentation, or event is not intended to provide legal advice but to provide information on legal matters and/or firm news of interest to our clients and colleagues. Readers or attendees should seek specific legal advice before taking any action with respect to matters mentioned in this publication or at this event. The attorney responsible for this communication is Brent E. Kidwell, Jenner & Block LLP, 353 N. Clark Street, Chicago, IL 60654-3456. Prior results do not guarantee a similar outcome. Jenner & Block London LLP, an affiliate of Jenner & Block LLP, is a limited liability partnership established under the laws of the State of Delaware, USA and is authorised and regulated by the Solicitors Regulation Authority with SRA number 615729. Information regarding the data we collect and the rights you have over your data can be found in our Privacy Notice. For further inquiries, please contact dataprotection@jenner.com.

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