Iran embargo: Triggering of the snapback mechanism

On August 28, 2025, Germany, France, and the United Kingdom triggered the snapback mechanism provided for in Security Council Resolution 2231 (2015). This could lead to the reinstatement of the economic sanctions imposed on Iran by the UN Security Council. The sanctions had been suspended in 2015 in exchange for Iran's commitment to dismantle its nuclear program under the Joint Comprehensive Plan of Action (JCPoA). Due to Iran's ongoing violations of its JCPOA obligations and the failure of negotiations on a possible successor agreement, sanctions could now be reinstated unless an agreement is reached within 30 days. Background: The JCPOA was negotiated with Iran by the five permanent members of the UN Security Council (China, France, Russia, the United Kingdom, and the United States), along with Germany (P5+1) and the EU, and signed in 2015. Following the agreement, Iran made comprehensive commitments to limit its nuclear program. In return, the far-reaching economic sanctions against Iran were suspended. In 2018, during President Trump's first term, the United States withdrew from the agreement, and rejoining under President Biden did not materialize. Iran has also repeatedly violated the agreement's provisions. In February 2015, Iran announced its withdrawal from the agreement. Negotiations on a new agreement also failed. Snapback Mechanism: Security Council Resolution 2231(2015), in which it endorses the JCPOA, provides for a so-called snapback mechanism (paragraph 11). According to this, UN sanctions can be reinstated in the event of serious breaches of obligations under the agreement. The mechanism can be triggered by any state participating in the JCPOA by sending a notification to the UN Security Council. The Security Council must then adopt a resolution confirming the lifting of the sanctions within 30 days of receiving the notification. Otherwise, the sanctions automatically reappear after the 30 days have expired – without the need for a further vote. If no member of the Security Council has submitted a proposal for a corresponding resolution on the continuation of the suspension of sanctions within ten days of receiving the notification, the President of the Security Council is to make such a proposal and put it to a vote within 30 days. What happens next? On August 28, 2025, Germany, France, and the United Kingdom submitted a notification to the Security Council regarding Iran's violations of its obligations under the JCPOA. The mechanism is limited to ten years after the adoption of the JCPOA and would have expired in October. The three states have thus used their last remaining means of exerting pressure on Iran. In their joint statement, the three foreign ministers announced their intention to begin negotiations with Iran within the current 30-day period to prevent the reimposition of sanctions. Should an agreement be reached, the UN Security Council would still need to adopt a resolution on continuing the existing sanctions relief. Russia and China have already submitted a draft resolution. However, it is questionable whether this will achieve the necessary majority. Furthermore, the five permanent members of the Security Council have a veto right. It remains to be seen whether an agreement with Iran can be reached in the next 30 days. However, given the tensions between Iran and the United States, there is a high probability that the sanctions will be reinstated.