Germany: Sanctions Against Iran – What’s Next?

Current Status of Sanctions

1. Background

On 30 October 2025, the EU reinstated and strengthened sanctions against Iran that had previously been suspended under the Joint Comprehensive Plan of Action (JCPOA) in 2016, following significant violations by Iran of the Vienna nuclear agreement.

As a result, the following sanctions regulations are currently in force:

2. Restrictive measures relating to the nuclear programme

Regulation (EU) No 267/2012

Prohibitions on the sale, delivery, transfer, and export to Iranian persons and entities (including outside Iran):

• Listed dual-use items set out in Annex I of Regulation (EU) 2021/821 (extended scope covering all dual-use items)
• Nuclear-related goods
• Key equipment and technology in the energy sector
• Marine equipment
• Enterprise software
• Gold, precious metals, diamonds, graphite, and other metal products

Prohibitions on import, acquisition, and transport:

• Listed dual-use items
• Nuclear-related goods
• Petroleum products
• Petrochemical products
• Natural gas

Licensing requirements for sale, delivery, transfer, and export:

• Nuclear-related goods

Financial sanctions:

• Freezing of economic resources (assets of any kind) belonging to listed persons or entities
• Prohibition on the direct or indirect provision of funds or economic resources to listed persons or entities
• Authorization requirements for certain transfers of funds to an Iranian person, entity, or body

3. Restrictive measures relating to the human rights situation

Regulation (EU) No 359/2011

• Prohibition on the sale, export, transfer, or transport of goods that may be used for internal repression
• Licensing requirement for the export of telecommunications surveillance software
• Financial sanctions

4. Restrictive measures relating to military assistance to Russia

Regulation (EU) 2023/1529

• Prohibition on the sale, export, transfer, or transport of goods used in the manufacture of drones
• Prohibition on technical assistance, intermediary services, and related services
• Prohibition on the provision of funding or grants
• Prohibition on disclosure of intellectual property in this context
• Transaction bans involving certain ports
• Financial sanctions

5. Arms embargo

§§ 74 para. 1 no. 8 German Foreign Trade and Payments Ordinance (AWV)

• Prohibition on the sale, export, transit, import, acquisition, and transport of armaments to or from Iran
• Prohibition on related services (Art. 5 Regulation (EU) 2025/1975)

6. Current political and military context

Since 28 February 2026, the United States and Israel have conducted military strikes against targets in Iran. The precise strategic objectives remain unclear, although publicly stated goals have included limiting Iran’s nuclear capabilities and reducing military capacity.

At present, it cannot be conclusively determined to what extent nuclear and military capabilities have been affected.

Iranian political leadership remains in place, and there are indications that the United States may seek to limit the duration of the conflict due to domestic political and economic considerations, including rising energy and food prices.

Reports also indicate the possibility of temporary relaxation of certain sanctions relating to Iranian oil exports.

If the current political situation in Iran remains unchanged and the United States reduces its involvement, potential consequences may include:

• Increased security risks affecting the Strait of Hormuz
• Potential short- to medium-term increases in oil, gas, and fertilizer prices
• Heightened geopolitical tensions affecting Gulf states
• Increased domestic repression within Iran

7. European response

Further regulatory developments are expected.

With regard to regional security risks, Germany has recently introduced General License AGG No. 48, allowing the export and transfer of specified armaments for air and maritime defense purposes, including protection against and removal of sea mines.

Registration is required but may be completed up to 30 days after the first export. The license is valid until 15 September 2026.

Safe passage through the Strait of Hormuz remains a significant strategic concern due to its importance for global energy supply chains.

Further tightening of EU sanctions remains possible in order to increase political and economic pressure.

Possible additional measures under consideration include:

• Expansion of sanctions lists to include additional individuals in political, military, and commercial sectors
• Stricter enforcement of sanctions in the energy sector, including potential secondary sanctions affecting purchasers of Iranian oil
• Sanctions targeting transport networks, including insurers and tanker operators (including so-called “shadow fleet” operators)
• Secondary sanctions affecting foreign banks
• Additional restrictions on trading in gold and cryptocurrencies

The effectiveness of any additional measures will depend significantly on coordination between the EU, the United States, and other international partners.

By MELCHERS, Germany, a Transatlantic Law International Affiliated Firm.

For further information or for any assistance please contact germany@transatlanticlaw.com

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