August 28, 2025

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Major Powers Try to Avoid Crisis Over Iran Sanctions “Snapback”

Office of the Iranian Supreme Leader via AP

Since Trump’s 2018 exit from the landmark 2015 Iran nuclear agreement (JCPOA), during his first term, it was perhaps inevitable that Iran and the six major powers (the United States, United Kingdom, France, Russia, the People’s Republic of China and Germany) would face a crisis over a key provision of the agreement — the ability of any party to “snapback” the United Nations sanctions lifted under the agreement. That crisis point has now arrived in the aftermath of the Twelve-Day War and U.S. strikes on Iranian nuclear facilities in June. The strikes were responses to key advances that brought Iran’s nuclear program within reach of acquiring an actual nuclear weapon, were the regime to decide to build one. The U.S. and its European partners see invoking the snapback as a means of keeping Iran strategically weak and unable to reconstitute the nuclear program damaged by the U.S. and Israeli strikes. Iranian leaders perceive a sanctions snapback as a Western effort to weaken Iran’s economy indefinitely and perhaps stimulate sufficient popular unrest to unseat Iran’s regime.  Whether the dispute over the snapback can be settled will likely determine whether the Iran nuclear issue might fade from the top of the regional agenda or, alternatively, set the stage for renewed warfare between Iran and Israel, with the potential further involvement of the U.S.

The snapback mechanism is included in UN Security Council Resolution 2231, which enshrined the JCPOA in international law, but the snapback provision and all other restrictions of the Resolution expire on October 18, 2025, unless extended by the UN Security Council. In accordance with the Resolution, the snapback can be invoked by any JCPOA party by accusing Iran of violating the nuclear restrictions of the JCPOA. A Security Council resolution triggering the snapback is not subject to a veto by any supporters of Iran on the Council, i.e., Russia and the PRC, because the mechanism is structured so that sanctions automatically return unless the Council affirmatively votes to continue their suspension. In the months prior to the June Twelve Day War, as U.S. talks with Iran to forge a new nuclear accord stalled, the United Kingdom, France and Germany (collectively known as the E3) publicly gave Iran until Sunday, August 31 to meet certain conditions — resume direct nuclear talks with the U.S., restore full International Atomic Energy Agency (IAEA) access to nuclear sites, and provide credible accounting of its highly enriched-uranium stockpile — or face sanctions snapback. The U.S. needed the E3 to announce this, as it cannot trigger the snapback by itself since the U.S. is no longer a party to the accord.

In a letter to the UN Security Council last week, foreign ministers of the E3 formally accused Iran of violating “the near entirety of its JCPOA commitments” and said they would invoke the snapback of sanctions. The E3 letter added: “We have made clear that if Iran is not willing to reach a diplomatic solution before the end of August 2025, or does not seize the opportunity of an extension (of the snapback provision), E3 are prepared to trigger the snapback mechanism.” The E3 set August 31 as a deadline because triggering the mechanism by that date would allow the 30-day UN snapback procedure to conclude before Russia, which is aligned with Iran, assumes the rotational presidency of the Security Council at the start of October, giving it an opportunity to raise procedural obstacles.

Reports suggest the E3 will formally trigger the snapback unless Iran avails itself of the off-ramps the E3, in partnership with Washington, has offered. In talks with Iran, most recently on Tuesday, the E3 have offered to delay any action to trigger the snapback for at least six months in exchange for a series of Iranian concessions. In response to the E3 ultimatum, Iran allowed IAEA inspectors back into Iran to resume inspections of nuclear facilities on Tuesday. The IAEA visit came as IAEA Director Rafael Grossi indicated he had made progress in talks on a new “modality” to enable the restoration of the UN nuclear watchdog’s work in the country. Speaking at a conference in the U.S. on August 26, Grossi said, “The important thing boils down to the fact that the conversation is ongoing and that inspectors, unlike [what] many were saying, are going to return to Iran." However, Iran still has not indicated it will return to talks with the Trump team. And, it has said its stockpile of enriched uranium remains buried under rubble of the facilities destroyed by U.S. and Israeli air strikes. Tehran has said it has no information "whatsoever whether [the stockpile is] safe or not" nor does it have "any plan to recover them before there is a guarantee of any more attack."

Washington and its European partners are open to delaying the invocation of the snapback to allow more time for diplomacy with Iran. Still, they insist that the authority to trigger the mechanism be preserved through an extension of Resolution 2231. Russia, which has a strategic partnership agreement with Iran, is seeking to broker a compromise that would avert the immediate triggering of the sanctions snapback but would extend the authority to do so for at least six months. The U.S. and its allies appear to be tacitly supporting Moscow’s efforts. Russia has circulated a draft resolution to extend Resolution 2231 for six months, with the provision that the snapback not be triggered during the six-month extension period. The Russian draft reportedly provides for further extensions beyond the first six-month period. The Russian draft was assembled following conversations between Russian President Vladimir Putin and his Iranian counterpart Masoud Pezeshkian, reflecting Iranian leadership appeals for Moscow’s help in countering Western pressure. The PRC, another backer of Iran, reportedly has agreed to co-sponsor the draft extension resolution. Some interpreted the Russian diplomatic initiative as a maneuver, already negotiated by Putin and Trump in their recent discussions on settling the Ukraine war, to avert an unpredictable showdown between Iran and the West.

Tehran is employing a combination of threats and diplomacy to avoid triggering the sanctions snapback. Tehran publicly rejects an extension of Resolution 2232, calling it an illegitimate alteration of the 2015 JCPOA agreement. Iranian leaders claim the E3 has upheld U.S. secondary sanctions, and therefore “in effect abandoned any claims to JCPOA participant status.” Iranian officials also accuse European leaders of supporting Israeli and U.S. military action against Iran’s nuclear program and other strategic installations in June. Iran has threatened that, if the snapback is triggered, it would withdraw entirely from the Nuclear Non-Proliferation Treaty (NPT) and would place the E3 countries on Iran’s “hostile states” list. Listing the E3 as hostile would, according to Iranian leaders, give their armed forces the authority to inspect vessels flagged, bound, or owned by European states in the Persian Gulf and the Sea of Oman.

However, Iranian officials reportedly have privately expressed they are open to an extension of Resolution 2231 and have stressed commitment to a diplomatic solution to the dispute. Foreign Ministry spokesman Esmaeil Baghaei said Tuesday, ahead of the talks with the UK, Britain, France, and Germany in Geneva, that “Our focus is on preventing actions or incidents that may be costly for the country.” He added that Tehran was “negotiating with all our might.” Foreign Minister Abbas Araghchi recently said Tehran was working with its allies, the PRC and Russia, to prevent the reimposition of sanctions. The Geneva talks produced no evident breakthroughs, and the E3 assert they will formally trigger the snapback provision on Thursday, a few days ahead of their August 31 deadline.

Iran is pursuing its dual-track strategy of diplomacy and threats because the stakes for Tehran in the outcome of the dispute are high. A sanctions snapback on Tehran would reimpose a ban on procuring nuclear-related technology, restrictions on importing conventional weapons such as combat aircraft and tanks, and a ban on ballistic missile development. The UN sanctions architecture also directs its member states to inspect Iranian vessels for contraband, blacklist Iranian shipping companies, increase scrutiny of the Iranian financial sector, and expand asset freezes or travel bans against dozens of Iranian individuals and firms. Perhaps most significantly, a UN sanctions snapback might prompt the PRC’s leaders to direct Chinese oil traders to stop buying the 1.5 million barrels of crude oil they buy from Iran each day — an amount that some experts assess is keeping Iran’s already weak economy from outright collapse.