Current Legal Status for Iranian Trade

1. The United States: “Secondary Tariffs” and Maximum Pressure

The U.S. has moved beyond traditional sanctions into a “Secondary Tariff” model. On February 6, 2026, President Trump signed an Executive Order that fundamentally changes the risk profile for any country or company dealing with Iran.+1

• The 25% “Doing Business” Tariff: The U.S. now authorizes a tariff of up to 25% on all imports from any country found to be “directly or indirectly” purchasing goods or services from Iran.
• Targeting the “Shadow Fleet”: As of January 2026, the U.S. Treasury (OFAC) has issued sweeping new designations against the “Shadow Fleet”—unlabeled tankers used to move Iranian oil. General License T was briefly issued to allow for limited safety and environmental offloading, but most maritime trade is now strictly prohibited.
• Legal Mechanism: These measures are enforced under the International Emergency Economic Powers Act (IEEPA). The Secretary of Commerce now monitors global trade flows to identify “supplier contamination”—where Iranian raw materials (like chemicals or metals) enter a third country’s supply chain before being exported to the U.S.+1

2. The European Union: The Return of “Snapback” Sanctions

In a significant shift that occurred in late 2025, the “E3” (UK, France, and Germany) triggered the “snapback” mechanism of the 2015 nuclear deal, citing Iran’s non-performance.

• Full Reinstatement of Nuclear Sanctions: As of January 1, 2026, all previous EU bans on Iranian oil, natural gas, and petrochemicals are back in full effect.
• Metals and Industrial Ban: A complete ban is now in place for the sale, supply, or export of graphite, raw metals, and semi-finished steel (including aluminum and steel products) to Iran.
• High-Risk Jurisdiction: On January 29, 2026, the EU officially added Iran to its list of “High-Risk Third Countries” regarding Anti-Money Laundering (AML). This requires EU banks to apply “Enhanced Customer Due Diligence” for any transaction involving Iran, making even legal humanitarian trade nearly impossible to process.

3. United Nations Status

Following the snapback triggered by European powers, UN sanctions were officially reimposed in September 2025 and remain in force throughout 2026.

International Non-Adherence: Note that while the UN has reimposed these, Russia and China have publicly stated they do not recognize the legality of the “snapback” and continue to engage in trade, leading to heightened geopolitical friction.

Arms and Missiles: The international ban on conventional arms transfers and ballistic missile technology—which had previously expired—is now legally binding again for all UN member states.