Iran Sanctions, UN Security Council Resolution 2231, and the Path to Snapback
On March 7, President Donald Trump disclosed he had written to Supreme Leader of the Islamic Republic of Iran Ali Khamenei, offering negotiations to eliminate Iran’s nuclear program. Khamenei has publicly rejected these overtures, but Iran’s supreme leader has a track record of publicly prohibiting talks while passively permitting quiet negotiations. Yet, international diplomacy in 2025 involving Iran is highly interrelated with the fate of United Nations Security Council Resolution (UNSCR) 2231, as any deal would most likely require the United Nations Security Council (UNSC) to rescind and/or replace this resolution. UNSCR 2231, passed by the United Nations (UN) in July 2015, enshrines a parallel process to the Joint Comprehensive Plan of Action (JCPOA) negotiated by the Obama administration. While the JCPOA was a non-binding set of political commitments between Iran and the United States, France, the United Kingdom, Germany, the European Union, China, and Russia that is now dead for all practical purposes, UNSCR 2231 and its restrictions on Iran remain legally binding on all UN Member States under international law.
However, according to the terms set forth in UNSCR 2231, all remaining UN sanctions on Iran are set to expire on October 18, 2025, unless, prior to that date, the original JCPOA participants choose to exercise the “snapback” mechanism created by the resolution or supersede the resolution with a replacement. Invoking the snapback option in advance of that deadline would reimpose the full panoply of UN sanctions previously levied on Iran. Once snapback occurs, Europe is expected to then cease its formal participation in the JCPOA and move to re-impose full banking and energy sanctions against Iran. Since the default outcome, if no action is taken, will be the expiration of UN sanctions, a pre-emptive snapback is necessary to flip the negotiating table and force Iran and its allies to barter for the relief of these sanctions.
To successfully invoke snapback, timing will be everything. For tactical reasons and to maximize future leverage, the United States should encourage our European partners to exercise the snapback option in April 2025 or May 2025 at the latest. Once snapback is imposed, the United States must ensure the old UN sanctions architecture is properly revived and should build and fund a sanctions technical support partnership program to develop the enforcement capabilities and expertise of allies and partners to do so.