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. 

Last month, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) order providing exemptive relief for covered investment advisers from certain anti-money laundering and combating the financing of terrorism  program and other Bank Secrecy Act-related reporting, recordkeeping and information-sharing obligations (IA AML Rule) until January 1, 2028. The IA AML Rule, published by FinCEN as a final rule on September 4, 2024, is currently set to become effective on January 1, 2026. 
On September 22, 2025, FinCEN published a notice of proposed rulemaking to amend the IA AML Rule to delay its effective date by two years, from January 1, 2026 to January 1, 2028.