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If Europe Wants to Sanction Iran, It Knows What to Do

United Nations sanctions are already on the books—they just need to be reactivated.

By , a senior advisor at the Foundation for Defense of Democracies, and , the deputy director of the nonproliferation and biodefense program at the Foundation for Defense of Democracies.
Protesters in Germany display Iranian and Kurdish flags in a rally in support of the demonstrations in Iran.
Protesters in Germany display Iranian and Kurdish flags in a rally in support of the demonstrations in Iran.
Protesters display Iranian and Kurdish flags in a rally in support of the demonstrations in Iran, near the Victory Column in Berlin on Oct. 22. JOHN MACDOUGALL/AFP via Getty Images

As Europe considers another round of sanctions targeting Iran for its deadly crackdown on protesters and the supply of arms to Russia, there is a ready sanctions tool already in place, whose activation would send an unmistakable message to Tehran. Britain, France, and Germany, as original participants in the Iran nuclear deal, have the power to take the most important step of all: the snapback of United Nations sanctions that are already on the books.

Beginning in 2006, the U.N. Security Council imposed escalating international sanctions and restrictions on Iran out of concern for its growing nuclear and missile activities. An arms embargo prohibited the transfer of arms and conventional weapons, including drones, in and out of Iran. A missile embargo restricted the same for missile-related systems and components. Multiple U.N. resolutions called on Iran to halt activities related to nuclear enrichment and banned Tehran from testing nuclear-capable missiles. Additionally, the Security Council established an international sanctions list of individuals tied to Iran’s nuclear and missile activities and encouraged the regime’s isolation on the world stage.

The 2015 Iran nuclear deal, however, upended the U.N. sanctions framework on Iran. U.N. Security Council Resolution (UNSCR) 2231, which endorsed the deal, set the arms embargo to expire in 2020 and both the missile embargo and individual sanctions to expire in 2023. In 2024, key nuclear restrictions on Iran will also begin to expire. The resolution even watered down the U.N. ban on Tehran’s missile testing.

As Europe considers another round of sanctions targeting Iran for its deadly crackdown on protesters and the supply of arms to Russia, there is a ready sanctions tool already in place, whose activation would send an unmistakable message to Tehran. Britain, France, and Germany, as original participants in the Iran nuclear deal, have the power to take the most important step of all: the snapback of United Nations sanctions that are already on the books.

Beginning in 2006, the U.N. Security Council imposed escalating international sanctions and restrictions on Iran out of concern for its growing nuclear and missile activities. An arms embargo prohibited the transfer of arms and conventional weapons, including drones, in and out of Iran. A missile embargo restricted the same for missile-related systems and components. Multiple U.N. resolutions called on Iran to halt activities related to nuclear enrichment and banned Tehran from testing nuclear-capable missiles. Additionally, the Security Council established an international sanctions list of individuals tied to Iran’s nuclear and missile activities and encouraged the regime’s isolation on the world stage.

The 2015 Iran nuclear deal, however, upended the U.N. sanctions framework on Iran. U.N. Security Council Resolution (UNSCR) 2231, which endorsed the deal, set the arms embargo to expire in 2020 and both the missile embargo and individual sanctions to expire in 2023. In 2024, key nuclear restrictions on Iran will also begin to expire. The resolution even watered down the U.N. ban on Tehran’s missile testing.

But UNSCR 2231 also came with a “snapback” mechanism: a way for the original state parties to the Iran deal—the five permanent members of the Security Council plus Germany—to force the return of all prior U.N. sanctions if Tehran violates its commitments. With Iran today spinning enough advanced centrifuges to produce high-enriched uranium for several nuclear bombs, any party could at any time notify the Security Council that Iran is breaking its nuclear deal commitments. This would trigger a 30-day clock before all prior resolutions—and their restrictions—come back into force. Russia or China would then have the opportunity to offer a Security Council resolution to block the snapback, but it would be subject to the veto held by the other permanent members Britain, France, and the United States.

Besides the strong signal it would send to the regime in Tehran, completing snapback would have other key benefits.

The Trump administration attempted to activate snapback in August 2020, but it was disputed by other Security Council members on the grounds that Washington had forfeited the right to initiate snapback when it withdrew from the accord in 2018. The Biden administration rescinded the Trump administration’s move shortly after taking office in 2021 and just last week suggested that only London, Paris, or Berlin could move snapback forward.

Notably, it only takes one country to trigger snapback. For instance, new British Prime Minister Rishi Sunak, who reportedly supports tough Iran measures, including snapback, could start the ball rolling. With Tehran’s nuclear program accelerating, protesters being massacred, Iranian drones and military advisors in Ukraine, and a U.S. envoy all but calling the Iran deal dead, Sunak would be more than justified in taking the lead.

Besides the strong signal it would send to the regime in Tehran, completing snapback would have other key benefits. Snapback means the U.N. arms embargo would return, and the missile embargo would stay. Iran would once again be isolated by the international community, with the potential for the world to expand trade and financial sanctions against the regime. Previous Security Council demands would be revived that Iran halt all enrichment and nuclear-capable ballistic missile activities, both crucial given Tehran’s ongoing non-compliance with the Nuclear Non-Proliferation Treaty, including its efforts to hide nuclear sites and material from international inspectors.

By contrast, reviving the deal and allowing remaining U.N. sanctions to lapse means throwing Iran a financial lifeline when it is most vulnerable. Under the proposed terms of the shorter, weaker nuclear accord the United States offered Iran in recent months, Tehran would receive an estimated $275 billion in revenue during the first year, rising to $1 trillion total by 2030. Iran would retain the ability to expand its nuclear centrifuge program with an eye toward the deal’s full expiration in 2031.

In short, the regime could fortify its economy, quash the popular uprisings, and emerge with an unstoppable nuclear threshold capability simply by saying “yes” to the deal on offer. Western proponents of the nuclear deal claim snapback is irrelevant, a step that would do nothing to stop the flow of drones and missiles from Iran to Russia or weaken the regime in the face of a national uprising. Their argument, however, ignores two basic realities.

First, as long as Western governments hedge their policies to preserve the potential to make a deal with Tehran, they will never fully support the protesters or hold Iran accountable for supporting Russia’s war in Ukraine. Snapback, on the other hand, represents a turning of the page from an era of appeasing and accommodating Iran back to an era of pressure and accountability.

Second, many governments use Security Council resolutions as a basis for national laws and regulations, including sanctions and other enforcement actions against Iran. Restoring prior resolutions on Iran gives those states justification to widen economic and political pressure, or at the very least, think twice about engaging in banned trade with Tehran. International sanctions also support transnational enforcement efforts such as the Proliferation Security Initiative, under which coalitions of states can act to interdict proliferation-related trade to or from Iran.

The Biden administration claims restoring the Iran nuclear deal is no longer a focus. A senior European official said the deal “does not count anymore.” Meanwhile, Iranians are dying at the hands of the regime and Ukrainians are under lethal attacks from weapons made by Tehran and launched with the help of Iranian military advisors. The West should not wait any longer and initiate snapback without delay.

Richard Goldberg is a senior advisor at the Foundation for Defense of Democracies. He served on Capitol Hill, on the U.S. National Security Council, and as the governor of Illinois’s chief of staff. Twitter: @rich_goldberg

Andrea Stricker is the deputy director of the nonproliferation and biodefense program and a research fellow at the Foundation for Defense of Democracies.
Twitter: @StrickerNonpro

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