Global Trade & Foreign Policy Insights

As Russia’s military aggression against Ukraine continues, the European Union (EU) has maintained its commitment to increasing economic and legal pressure on Russia. In 2025, the EU adopted its 16th, 17th, 18th, and now 19th sanctions packages, each introducing new measures and expanding existing restrictions. 

On September 27, 2025, the United Nations reimposed sanctions and other restrictions based on Iran’s continuing “significant non-performance” of its nuclear commitments. Today, September 29, following the UN resolution, the European Union formally reimposed a broad range of sanctions on Iran, citing the same “significant non-performance” of its nuclear commitments under the Joint Comprehensive Plan of Action (JCPOA). These actions follow the invocation of the JCPOA’s snapback mechanism by the E3 (France, Germany, and the United Kingdom) on August 28, 2025, and mark a major shift in the international legal and commercial landscape for entities engaged with Iran. 

In light of the recent wave of sanctions against Russia issued by the United States (see Winston & Strawn’s post here), the European Union (“EU”) issued a tenth package of Russia sanctions on February 25, 2023.