The European Hand on the Trigger... What Does the Return of UN Sanctions Mean for Iran?

Ten years after the nuclear agreement was concluded, instead of Iran receiving the prize of having its file permanently removed from the Security Council, it faces the threat of the return of all international sanctions at once. This is no surprise, as the agreement was not adhered to during most of that period, and the European parties felt they did not deserve the prize.

In 2015, Tehran concluded an agreement with the P5+1 group (the United States, China, Russia, Britain, France, and Germany), which stipulated restrictions on Iranian nuclear activities in exchange for the lifting of UN sanctions. However, after the US withdrawal from the agreement in 2018, the Iranians eased their commitments and are now closer to possessing their first nuclear bomb.

Today, the European trio (Britain, France, and Germany) are attempting to use their legal powers to restore UN sanctions to force Iran to curb its nuclear ambitions.

The Snapback Mechanism

The agreement includes a legal method for punishing Tehran if it fails to comply with its obligations, called the snapback mechanism. This means a rapid return of Security Council sanctions within 30 days of a member submitting a letter stating this.

The only way out of this is for the Security Council to adopt a resolution not to implement the sanctions. This means that if the Council fails to agree on a new resolution in Tehran's favor, no country will be able to prevent the implementation of the sanctions. In other words, Tehran will be punished and will not escape the sanctions unless the five permanent members of the Council unanimously agree to the contrary.

This formulation reveals the difficulty of halting the implementation of the snapback mechanism, as its opponents will not obstruct it without a price. Indeed, the European trio demanded that Iran cooperate with the International Atomic Energy Agency and return to negotiations with Washington in exchange for passing a new Security Council resolution postponing the snapback mechanism.

The Europeans sent their letter on August 28, 2025, justifying their move by citing Iran's stockpile of enriched uranium exceeding 8,400 kilograms—more than 40 times the maximum agreed upon in the agreement, including hundreds of kilograms at 60%, close to the level required for nuclear bombs—in the absence of any International Atomic Energy Agency (IAEA) oversight.

Tehran rejected the European demands, so the trio decided to exercise their powers under Article 11 of UN Security Council Resolution 2231 (2015), which endorsed the agreement known as the Joint Comprehensive Plan of Action (JCPOA).

Although this step could be invoked until October 18, 2025, the Europeans rushed the move ahead of Russia, Iran's ally, assuming the presidency of the UN Security Council in October. The activation process would take a full month.

This had immediate negative repercussions for the Iranian economy as soon as the letter was submitted. The currency collapsed, with one US dollar trading at more than one million rials, gold prices soared, and hopes for an economic recovery collapsed.

The Danger of UN Sanctions

A number of countries impose numerous sanctions on Iran. However, the difference between UN sanctions and other sanctions is that they are not specific to a specific country, but rather are binding on all UN member states (193 countries). Therefore, no country has the right to ignore them, as they enjoy international legitimacy because they are issued by an organization that represents the international community.

Likewise, UN sanctions can only be lifted with the agreement of the five permanent members of the Security Council (the United States, China, Russia, the United Kingdom, and France). Therefore, although the sanctions imposed by the United States, for example, are more harmful and broader in scope than UN sanctions, such as oil export embargoes and banking sector sanctions, some countries may ignore them if they do not fear political or economic repercussions from the United States. The situation is greatly influenced by political considerations, not just legal ones.

There are many unilateral sanctions imposed by the United States and other Western countries, and there are collective sanctions imposed by the European Union on Iran. Both types are not binding on the rest of the world; rather, only the country or group that issued them is bound by them, because they are not issued by the UN Security Council, but by the governments of certain countries. The agreement stipulates that the restrictions will gradually end over time until October 18, 2025, at which point the Security Council will end its consideration of the Iranian nuclear issue.

Snapback of Sanctions

The snapback mechanism operates in two stages. According to Articles 36 and 37 of the agreement and paragraphs 11 and 13 of Resolution 2231, if one participant believes that another party is violating the agreement, it refers the matter to a committee coordinated by the European Union (EU). The committee is given 35 days to resolve the dispute. If the dispute is not resolved, the participant may notify the Security Council. Once this notification is submitted, a one-month period begins during which any Council member may submit a resolution to further ease sanctions within the first ten days of the month. If no resolution is submitted, the Council President must submit it and put it to a vote. Any member with veto power can overrule the resolution, at which point all previous UN sanctions imposed between 2006 and 2010 are automatically reimposed.

This was a method for the rapid return of Security Council sanctions, designed and proposed by Sergey Lavrov, the Russian Foreign Minister, and included in the Security Council resolution.

The agreement was in effect from January 2016, but in May 2018, during President Donald Trump's first term, the United States unilaterally withdrew from the agreement and reimposed severe unilateral sanctions on Iran. In response, Iran began gradually reducing its compliance with the agreement the following year. Therefore, in January 2020, France, Germany, and the United Kingdom triggered the dispute resolution mechanism in response to Iranian violations of the agreement, but the mechanism's procedures were not completed. Other council members have widely rejected parallel US efforts to invoke the snapback mechanism. In August 2020, Washington attempted to invoke the snapback mechanism, but the Security Council rejected it because it was no longer a participant in the agreement. After President Joe Biden was elected in November 2020, he initiated indirect talks with Tehran to return to the agreement. However, these talks were unsuccessful and stalled in 2022 without reaching an agreement. Tehran enjoyed the benefits of the expiration of some restrictions on the missile program sanctions in October 2023.

Events escalated tensions. After Trump returned to the White House in January 2025, he resumed the "maximum pressure" policy against Iran, coinciding with the start of negotiations with it. In June, the Board of Governors of the International Atomic Energy Agency (IAEA) adopted a resolution declaring Iran non-compliance with its obligations. This was followed by an Israeli-American attack targeting its nuclear facilities, which suspended cooperation with the IAEA and halted negotiations.

Therefore, the European Union warned that unless Tehran returned to negotiations, the trigger mechanism would be activated, which it did.

What are the UN sanctions on Iran?

• The first of the UN sanctions imposed by the UN Security Council was Resolution 1696 of 2006, in which the Security Council expressed concern about the intentions of Iran's nuclear program and demanded the suspension of uranium enrichment.
• Then came Resolution 1737 of 2006, which imposed a ban on the supply of nuclear-related technology and froze the assets of companies and individuals involved in enrichment.
• Resolution 1747 of 2007, which prohibited the supply of arms to and from Iran and tightened the asset freeze measures included in the previous resolution.
• Resolution 1803 of 2008, which demanded that Iran suspend uranium enrichment and research and development in this field, imposed strict controls on its banking transactions, and required member states to inspect suspicious shipments to or from Iran.
• Also in 2008, Resolution 1835 was issued, condemning Iran for its continued enrichment activities and ordering it to halt ballistic missile development.
• In 2010, Resolution 1929 was the most difficult of these resolutions. It prohibited all countries from selling or buying heavy conventional weapons with Iran, such as tanks, armored vehicles, fighter aircraft, and warships, or even transiting through its territory, or even providing any technical support related to these weapons or their spare parts. It demanded that all countries take all measures to prevent the transfer of related technology to Iran, prohibited Iran from participating in any commercial activity related to uranium enrichment, and obligated all countries to prevent the entry or transit of certain Iranian individuals into their territories. It called on countries to inspect any suspected Iranian vessel and confiscate prohibited items, and urged countries not to provide financial services to Iran and to freeze its assets that could contribute to sensitive nuclear activities.

Implementation Begins

When the snapback mechanism is implemented, all resolutions will be implemented simultaneously, at the end of the 30th day, at 00:00 GMT, from the date the European countries submit their letter, according to Resolution 2231. All countries will then begin implementing the measures, including inspecting any ships or aircraft connected to Iran.

Although Russia and China cannot prevent the reimposition of UN sanctions on Iran, if they are proven to be violating the sanctions, they can veto any Security Council attempts to punish them. The most pressing Western demand remains the redrafting of a new agreement with Iran that guarantees restrictions on its nuclear program under the supervision of the International Atomic Energy Agency in exchange for the lifting of sanctions. Tehran has publicly accepted this, but the details remain a matter of ongoing dispute, which has led to the failure of all previous rounds of negotiations.

References

https://main.un.org/securitycouncil/ar/s/res/1696-%282006%29

https://main.un.org/securitycouncil/ar/s/res/1737-%282006%29

https://main.un.org/securitycouncil/ar/s/res/1747-%282007%29

https://main.un.org/securitycouncil/ar/s/res/1803-%282008%29

https://main.un.org/securitycouncil/ar/s/res/1929-%282010%29