As of October 18, 2025, Iran has declared it is no longer bound by the terms of the 2015 nuclear agreement, known as the Joint Comprehensive Plan of Action (JCPOA), following the deal’s expiration. The JCPOA’s “termination day” was set for October 18, 2025, a decade after the United Nations Security Council passed Resolution 2231 to endorse the agreement.

[September 3 2025 new UN snapback letters ]

The UK, France and Germany, known as the E3, took the step in a letter to the Security Council on Thursday. The council now has 30 days in which to decide whether to continue sanctions relief or allow it to lapse.

The letter said Iran’s non-compliance with the 2015 nuclear deal was “clear and deliberate”. It declared that Iran had “no civilian justification” for its high enriched uranium stockpile – uranium purified to near military grade – and that its nuclear program “remains a clear threat to international peace and security”.

The snapback provision was built into the 2015 accord and allows for a participant to initiate the process to bring back sanctions if they believe Iran has significantly failed to fulfil its nuclear commitments by notifying the UN Security Council.

[February 19 2021 “snapback” of U.N. sanctions letters withdrawn ]

Acting U.S. Ambassador Richard Mills sent a letter to the U.N. Security Council on behalf of President Joe Biden saying the United States “hereby withdraws” three letters from the Trump administration culminating in its Sept. 19 announcement that the United States had re-imposed U.N. sanctions on Tehran. The Trump administration’s decision to invoke a provision in the 2015 council resolution allowing the “snapback” of sanctions because Iran was in “significant non-performance” with its obligations under the accord was ignored by the rest of the Security Council and the world.

[January 15 2021 Last Pompeo sanctions? ]

Hoopad Darya Shipping Agency Company,

Mohammad Reza Modarres Khiabani, the Chief Executive Officer of IRISL

Jiangyin Mascot Special Steel Co.,

Iran Transfo Company, 

Zangan Distribution Transformer Company, 

Accenture Building Materials,

Iran’s Mobarakeh Steel Company,

Sapid Shipping,

Hamidreza Azimian, 

Last Pompeo sanctions

https://www.state.gov/imposing-sanctions-related-to-the-islamic-republic-of-iran-shipping-lines-and-iranian-shipping-entities/

[December 14 2020]

The U.S. sanctioned two Iranian officials over the disappearance and probable death of Robert Levinson, a retired FBI agent who went missing in Iran in 2007 during an unauthorized mission for the CIA.

The Treasury Department said Mohammad Baseri and Ahmad Khazai, high-ranking officials with Iran’s Ministry of Intelligence and Security, were involved in Levinson’s abduction, detention and probable death.

Mohammad Baseri and Ahmad Khazai

Mohammad Baseri is a high-ranking MOIS officer involved in counterespionage activities in and outside of Iran, who has been involved in sensitive investigations related to Iranian national security issues. Baseri has worked directly with intelligence officials from other countries in order to harm U.S. interests. Ahmad Khazai is a high-ranking member of the MOIS who, in his role as a senior official of the MOIS, has led MOIS delegations to other countries to assess the security situation.

Mohammad Baseri and Ahmad Khazai, acting in their capacity as MOIS officers, were involved in the abduction, detention, and probable death of Mr. Levinson.

[October 23 2020]

AL-BAGHDADI, Hassan (Arabic: حسن بغدادي) (a.k.a. AL-BAGHDADI, Sheikh Hassan; a.k.a. BAGHDADI, Sheikh Hassan; a.k.a. “AL-BAGHDADI, Sheikh”), Lebanon; MASJEDI, Iraj, Iraq; QAOUK, Nabil (Arabic: نبيل قاووق) (a.k.a. KAWOUK, Nabil; a.k.a. QAWOOK, Sheikh Nabil; a.k.a. QAWOUK, Sheikh Nabil; a.k.a. QAWUQ, Nabil Yahy), Ebba, Nabatieh, Lebanon;
https://home.treasury.gov/news/press-releases/sm1158

[October 8 2020 U.S. Sanctions on 18 major banks ]

https://home.treasury.gov/news/press-releases/sm1147

[November 9 2019 Khamenei nine sanctioned ]

WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today against nine individuals who are appointees of, or have acted for or on behalf of, Ali Khamenei,

Treasury’s previous additions of Supreme Leader Khamenei and the Iranian regime’s Foreign Minister, Javad Zarif, to OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).

1) Ebrahim Raisi, the head of Iran’s Judiciary,

2) Mojtaba Khamenei, the second son of the Supreme Leader,

3) Mohammad Mohammadi Golpayegani, the Supreme Leader’s Chief of Staff

4) Vahid Haghanian is being designated for having acted or purported to act for or on behalf of, directly or indirectly, the Supreme Leader of Iran.

5)Ali Akbar Velayati, a senior advisor to the Supreme Leader

6) Gholam-Ali Hadad-Adel, father-in-law of Mojtaba Khamenei,

7) IRGC General Mohammad Bagheri as the chief of AFGS.

8) IRGC Brigadier General Hossein Dehghan was appointed by Ali Khamenei as his military aide for the Defense Industries and Armed Forces Logistics.

9)Gholam Ali Rashid, an IRGC commander, who was appointed by the Supreme Leader of Iran as the commander of the Khatam al-Anbia Central Headquarters,

https://home.treasury.gov/news/featured-stories/treasury-designates-supreme-leader-of-irans-inner-circle-responsible-for-advancing-regimes-domestic-and-foreign-oppression

[August 7 2019 Foreign Minister sanctioned ]

Javad Zarif 2013

July 31, 2019
WASHINGTON – The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action today against the Iranian regime’s Foreign Minister, Mohammad Javad Zarif (Javad Zarif), pursuant to Executive Order (E.O.) 13876 because Zarif acted or purported to act for or on behalf of, directly or indirectly, the Supreme Leader of the Islamic Republic of Iran.

All property and interests in property of this individual that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons.
https://home.treasury.gov/news/press-releases/sm749

The same day the White House sanctioned Zarif, it quietly renewed sanctions waivers that will let other nations cooperate with Iran on civilian nuclear projects. Renewing the waivers upholds part of the nuclear deal, and is somewhat of a break from the U.S. maximum pressure campaign that has repeatedly jettisoned previous parts of the agreement and levied harsh sanctions against Tehran

[January 31 2019 SPV for payments avoiding SWIFT ]

https://twitter.com/eu_eeas/status/1091033899738820610
France, Germany and the United Kingdom created a state company, known as a “special purpose vehicle,” to allow Iran to continue to trade vital goods like medicine and food, according to German media reports. INSTEX will be based in Paris and will be managed by German banking expert Per Fischer, a former manager at Commerzbank. The UK will head the supervisory board. EU foreign ministers were set to meet January 31 2019 in Bucharest, Romania. There was no immediate announcement acknowledging the creation of the trade vehicle. “What is relevant in this case is to see that the EU is doing something despite the position of the US, and in opposition to the US. This is something new.” Esfandyar Batmanghelidj, founder of a Europe-Iran business forum.

[September 25 2018]

The U.K., Germany, France, Russia and China have agreed to establish a special payments system to circumvent U.S. sanctions on Iran stemming from President Trump’s unilateral withdrawal from the 2015 nuclear deal. The payments channel would be an alternative to SWIFT, the backbone of the global financial system that allows Iran to get paid for oil, pay for its imports and finance its activities abroad.
A Special Purpose/Project Vehicle (SPV) is a legal entity that undertakes a project. All contractual agreements between the various parties are negotiated between themselves and the SPV. An SPV is a commercial company established under the relevant Act of a country through an agreement (also known as memorandum of association) between the shareholders or sponsors. The shareholders agreement sets out the basis on which a company is established, giving such details as its name, ownership structure, management control and corporate matters, authorized share capital and the extent of the liabilities of its members. The creation of a Special Purpose/Project Vehicle (SPV) is a key feature of most PPPs[Public Private Partnerships]. The SPV is a legal entity that undertakes a project. All contractual agreements between the various parties are negotiated between themselves and the SPV. SPVs are also a preferred mode of PPP project implementation in limited or non-recourse situations, where the lenders rely on the project’s cash flow and security over its assets as the only means to repay debts. The next figure shows a simplified PPP structure. However, the actual structure of a PPP depends on the type of partnerships.