Impending Deadline for UN Action on Iran: What the “Snapback” of Iran Sanctions Could Mean for Global Business

Table of Contents

• What is “snapback” and how does it work? 
• Why did the E3 initiate snapback? 
• What steps has the UN Security Council taken?
• If snapback occurs, what UN sanctions will be reimposed?
• How will snapback affect U.S. sanctions on Iran?
• How will snapback affect EU and UK sanctions on Iran?
• What does this mean for business?
  
  

What is “snapback” and how does it work?

On August 28, 2025, France, Germany, and the UK (the E3) initiated the process to reinstate (or snapback) UN sanctions on Iran. The snapback mechanism (which was set to expire on October 18, 2025) is outlined in UN Security Council Resolution 2231 (UNSCR 2231).

UNSCR 2231 implemented the 2015 Joint Comprehensive Plan of Action (JCPOA) agreement among Iran, the United States, Russia, China, and the E3. The core premise of the JCPOA was that the participating states agreed to provide substantial sanctions relief to Iran in exchange for Iran agreeing to restrict its nuclear program. However, in 2018, the United States exited the JCPOA, reimposed its previous sanctions on Iran, and started imposing additional sanctions in an effort to increase pressure on Tehran.

The snapback mechanism described in UNSCR 2231 can be initiated by any JCPOA participating state reporting to the Security Council “significant non-performance of commitments” by any other participating state. UNSCR 2231 provides that UN sanctions on Iran will be reimposed 30 days after the snapback process is initiated, unless the UN Security Council adopts a resolution to continue the suspension of the sanctions. This means that any permanent member of the UN Security Council can ensure sanctions are reimposed by vetoing any such resolution. 
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Why did the E3 initiate snapback?

The E3 initiated snapback in an August 28 joint letter to the UN Security Council declaring that Iran had “increasingly and deliberately ceased performing its JCPOA commitments,” and alleging that Iran’s uranium stockpile quantities, refusal to allow IAEA’s verification and monitoring processes, and nuclear R&D activities were evidence of non-compliance. The letter reiterated the E3’s openness to delaying the reimposition of sanctions, to provide additional time for diplomacy. The E3 stated previously that they were open to a time-limited extension to the snapback, provided that Iran restarted its negotiations with the United States regarding its nuclear program, cooperated with IAEA verification, and accounted for its high enriched uranium stockpile.
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What steps has the UN Security Council taken?

On September 19, the UN Security Council failed to adopt a new resolution to continue the sanctions relief under UNSCR 2231. As required by UNSCR 2231, this new resolution was put forward by South Korea, in its capacity as the current president of the 15-member UN Security Council.   The new resolution did not receive the nine votes required to pass, because only Russia, China, Algeria, and Pakistan voted in favor, and three members with veto power (France, the United Kingdom, and the United States) voted against. The UN Security Council could consider another resolution before the September 27 deadline.
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If snapback occurs, what UN sanctions will be reimposed?

Once snapback is completed, the sanctions on Iran imposed by other, prior UNSCRs (specifically 1696, 1737, 1747, 1803, 1835, 1929, and 2224) will take effect and would apply, as they did in 2015 prior to implementation of the JCPOA.  

Major elements of the UN sanctions on Iran include:

• Nuclear & Missile Program Ban: Prohibits Iran from activities related to its nuclear program (including uranium enrichment or reprocessing, heavy water projects, related R&D, and certain investments abroad) and ballistic missile program.
• Nuclear & Missile-Related Embargo: Imposes an embargo on Iran for “items, materials, goods, and technology” that could contribute to Iran’s nuclear or ballistic missile programs.
• Conventional Arms Embargo: Imposes an embargo on tanks, combat vehicles, artillery systems, combat aircraft, attack helicopters, warships, missiles or missile systems, and technical training.
• Banking Restrictions: Calls upon Member States to prohibit banking activities that could contribute to Iran’s activities or weaponization.
• Designated Individuals and Entities: Imposes an asset freeze and travel bans on designated individuals and entities. The list of UN-designated persons is heavily focused on individuals and entities linked to Iran’s proliferation activities.

All UN member states are obligated to implement UNSCRs, including the embargoes and other restrictions on Iran outlined above. However, significant questions remain regarding how states will implement and enforce these measures. The snapback mechanism is a novel one and this will be the first time it has been implemented (in any UN sanctions program). Further, Russia, China, and Iran have claimed that the E3’s initiation of snapback is illegitimate, arguing that the United States’ exit from the JCPOA in 2018 violated the agreement and altered the applicability of the snapback mechanism. The extent to which countries view snapback as legitimate could affect the implementation and effectiveness of the reinstated sanctions.
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How will snapback affect U.S. sanctions on Iran? 

Given that UN sanctions are less intensive than current U.S. comprehensive sanctions on Iran, the implementation of UN sanctions is unlikely to have a significant effect on U.S. sanctions or on the compliance outlook for U.S. businesses. Consistent with the Trump Administration’s resumption of “maximum pressure” on Iran, the U.S. government since February has maintained an aggressive campaign of designations targeting Iran. These actions primarily focus on Iran’s oil exports, with designations (and sometimes multiple separate rounds of designations) announced every month, including on so-called independent “teapot” refineries in China. But the sanctions focus has also covered other areas, such as the Iranian military’s ballistic missile program and unmanned aerial vehicle (“UAV”) program, as well as Iran’s financial and material support for non-state military actors including the Houthis and Sudanese Islamist groups. This aggressive posture appears likely to continue, with commensurate risks for individuals and entities associated with these targeted activities.
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How will snapback affect EU and UK sanctions on Iran? 

The European Union and United Kingdom have until now remained in the JCPOA and continued the sanctions relief they provided under the agreement. However, both jurisdictions maintained certain other sanctions on Iran, which expanded in recent years to address Iran’s military support to Russia. Thus, the reimposition of UN sanctions will lead to the EU and UK reimposing sanctions sufficient to implement the UN measures, and potentially returning to the full sanctions they had imposed prior to the JCPOA.

We would not, however, anticipate an imminent substantial change to the EU/UK “Blocking” statutes with respect to Iran. Even with the re-imposition of UN level sanctions on Iran and the potential expansion of EU/UK sanctions beyond those required by the UN, historically, both jurisdictions have remained opposed to U.S. “secondary” sanctions on Iran. Prior to the JCPOA, the EU Blocking Statute (which included the United Kingdom as it was still part of the European Union at the time) already covered certain U.S. sanctions on Iran, even while the EU maintained the most robust version of its Iran-related sanctions. Given that the European Union’s amendment of the Blocking Statute in 2018 focused on including additional U.S. “secondary” authorities, but did not add U.S. “primary” sanctions, we would not anticipate any material change to the legislation in the event of snapback. Practically speaking, however, the conflict of law risk may decline because (i) with the ramp-up of pressure on Iran by non-U.S. authorities, companies will have an increased ability to point to non-U.S. authorities when justifying decisions to decline Iran-related business; and (ii) with reduced Iran-related activity, both private litigants and public prosecutors may be even less likely to bring cases under the Blocking Statute.
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What does this mean for business?  

Many businesses already prohibit dealing with Iran or Iranian counterparties, or otherwise have little to no exposure to Iran. For these businesses, the practical effects of snapback are likely to be limited.

However, non-U.S. businesses that have dealings with Iran should carefully monitor the reimposition of sanctions in relevant jurisdictions and prepare to comply with applicable restrictions. Non-U.S. businesses should also assess their risks more generally, including exposure to U.S. sanctions. The U.S. government is likely to continue its aggressive implementation of Iran sanctions, and with the UN measures back in place, it may be easier for the U.S. government to secure cooperation from other governments in this effort.
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