Westminster Policy News & Legislative Analysis

E3 snapback restores UN Iran sanctions; US warns 25% tariffs

Iran’s security apparatus has contained another wave of unrest with lethal force and mass arrests, as internet restrictions complicate verification. Reuters reporting and rights groups describe widespread detentions and the use of live fire by state forces, including IRGC units and police, in late December and January. Authorities deny excessive force but acknowledge fatalities. Independent counts vary from dozens to several hundred deaths in the early phase, with far higher figures now cited by HRANA; all are difficult to confirm amid blackouts. ([reuters.com](https://www.reuters.com/world/middle-east/irans-traders-frustrated-by-economic-losses-turn-against-clerics-2026-01-12/?utm_source=openai))

The IRGC remains the decisive instrument of regime control. It answers directly to the Supreme Leader, operates in parallel to the regular military, and oversees the Basij militia frequently deployed against street protests. Open-source estimates put the IRGC at roughly 125,000–190,000 personnel, while Basij membership runs into the hundreds of thousands, with far larger claimed numbers on mobilisation. The Guards also hold significant commercial interests across construction, energy and transport, reinforcing both political and economic leverage. ([reuters.com](https://www.reuters.com/world/middle-east/irans-revolutionary-guards-military-operations-business-empire-2023-01-19/?utm_source=openai))

Sanctions pressure intensified in 2025. On 28 August, the UK, France and Germany (the E3) formally triggered the JCPOA “snapback” mechanism, citing Iran’s significant non‑performance. With no Security Council resolution to block it, previously lifted UN sanctions were reinstated from 27 September 2025 (00:00 GMT), as the E3 confirmed in their government statement and letter to the UN. ([gov.uk](https://www.gov.uk/government/news/e3-joint-statement-on-iran-activation-of-the-snapback?utm_source=openai))

The Council of the EU then reimposed corresponding EU sanctions on 29 September 2025, reviving restrictions across trade, finance and transport. Measures include bans on crude oil, gas, petrochemical and petroleum product imports, asset freezes (including the Central Bank of Iran), and prohibitions on supplying specified energy, naval and software items, alongside ballistic‑missile‑related controls. These provisions mirror the renewed UN framework and EU autonomous measures under Regulation 267/2012 as amended. ([consilium.europa.eu](https://www.consilium.europa.eu/en/press/press-releases/2025/09/29/iran-sanctions-snapback-council-reimposes-restrictive-measures/))

The UK followed by reapplying UN‑related sanctions and extending domestic listings. On 1 October 2025, the Foreign, Commonwealth & Development Office confirmed the reimposition of UN measures and 121 designations tied to nuclear and ballistic activity, after announcing 71 further UK sanctions the previous day on entities and individuals linked to Iran’s programme. London has urged all UN members to implement the restored resolutions in full. ([gov.uk](https://www.gov.uk/government/news/uk-reimposes-un-sanctions-on-iran?utm_source=openai))

Nuclear oversight remains strained. The EU’s statement to the IAEA Board in September 2025 noted Iran’s enriched‑uranium stocks at 48 times the JCPOA cap, including more than 440 kg at 60%-over ten IAEA “significant quantities”-with monitoring gaps that prevent reliable accounting. The E3 reiterated that such levels have no credible civilian justification and pressed for restored access for inspectors. ([eeas.europa.eu](https://www.eeas.europa.eu/delegations/vienna-international-organisations/eu-statement-iaea-board-governors-iran-10-september-2025_en?utm_source=openai))

Macroeconomic stress has deepened. The rial repeatedly hit record lows through late 2025-around 1.25–1.38 million per US dollar on the open market-while official data show headline inflation above 40% and food and beverage prices running at roughly two‑thirds higher year‑on‑year in November. The combination has eroded purchasing power and fuelled protest triggers. ([reuters.com](https://www.reuters.com/world/middle-east/irans-currency-sinks-new-record-low-2025-12-08/?utm_source=openai))

US policy has shifted beyond sanctions signalling. On 12 January 2026, President Donald Trump announced a 25% tariff on “any country doing business with Iran,” framed as a response to the crackdown. No implementing order or detailed legal basis accompanied the post, and the White House had not published guidance at time of writing. Markets and trade partners are treating the statement as a material risk pending clarification. ([reuters.com](https://www.reuters.com/world/middle-east/trump-says-countries-doing-business-with-iran-face-25-tariff-2026-01-12/?utm_source=openai))

The tariff gambit lands amid court scrutiny of the administration’s wider use of emergency statutes for trade policy. A Federal Circuit ruling in August 2025 held that sweeping IEEPA‑based tariffs exceeded delegated authority, with Supreme Court review now pending; a decision could define how far the White House can extend tariff tools to pursue foreign‑policy aims. ([hklaw.com](https://www.hklaw.com/en/insights/publications/2025/09/court-of-appeals-strikes-down-ieepa-tariffs-setting-stage?utm_source=openai))

International responses underscore potential spillovers. China has publicly objected to unilateral US measures and warned of countersteps, a signal with implications for oil flows and secondary exposure for firms in Asia, the Gulf and Europe. Compliance teams should assume tighter US scrutiny of Iran‑linked transactions while EU and UK snapback rules bite at the same time. ([reuters.com](https://www.reuters.com/world/middle-east/trump-says-countries-doing-business-with-iran-face-25-tariff-2026-01-12/?utm_source=openai))

Security dynamics remain volatile after mid‑2025 strikes. The IAEA confirmed that US and Israeli attacks hit Iranian nuclear sites at Esfahan, Natanz and Fordow in June, though assessments differ on the extent of underground damage. The episode has hardened Tehran’s stance while leaving the technical picture opaque pending fuller verification. ([iaea.org](https://www.iaea.org/newscenter/pressreleases/update-on-developments-in-iran-5?utm_source=openai))

Negotiation channels have not fully closed. While Tehran and Western capitals trade accusations, both the E3 and Washington say diplomacy remains available if Iran restores cooperation with the IAEA; reports of back‑channel contacts persist even as the White House threatens further steps. For now, loyalty within Iran’s security forces and the IRGC’s economic reach suggest the state can continue to suppress protests, but external economic pressure is rising and policy risk has escalated for any entity connected to Iranian trade. ([gov.uk](https://www.gov.uk/government/news/e3-joint-statement-on-iran-activation-of-the-snapback?utm_source=openai))