Global Trade & Foreign Policy Insights

In this episode of Cari's Legal Exchange, Cari Stinebower, chair of Winston's International Trade Practice, is joined by Dainia Jabaji, of counsel and member of Winston’s International Trade Practice, to discuss the current state of play with respect to U.S. sanctions on Iran and the implications for global trade.

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.