After the 12-day Iran-Israel war ended with a ceasefire late last month, France’s Foreign Minister Jean-Noel Barrot said France could still "reimpose a global embargo on weapons, nuclear equipment, and banking and insurance sectors in Iran, which were lifted 10 years ago.” Barrot called the snapback mechanism “powerful leverage.” A French diplomatic source told Reuters last week that European powers would look to reactivate UN sanctions if a new nuclear deal with Iran does not guarantee European security interests.
On Monday, Iranian Foreign Ministry spokesperson Esmaeil Baghaei said that "the threat to use the snapback mechanism lacks legal and political basis and will be met with an appropriate and proportionate response from the Islamic Republic of Iran." He accused the European parties — the UK, France and Germany, also known as the E3 — of violating their own obligations under the JCPOA, which President Donald Trump abandoned during his first term in office.
The speculation about the snapback mechanism comes just weeks after Iran announced it was suspending its collaboration with the UN nuclear watchdog, the International Atomic Energy Agency, following the 12-day war in June that saw Israeli and US strikes on Iranian nuclear facilities.
What is the snapback mechanism?
The JCPOA, signed in 2015 between Iran and the P5+1 (the US, UK, France, Russia, China and Germany), laid out a phased process of sanctions relief in exchange for limits on Iran’s nuclear program. Enshrined in UN Security Council Resolution 2231, the agreement also established the snapback mechanism, allowing any country party to the JCPOA to reimpose sanctions if Iran is found to be in noncompliance with the agreement. While the mechanism was designed as a deterrent, it has also become a tool of leverage as Western powers look to renegotiate a nuclear deal with Iran.
The snapback provision, however, expires on Oct. 18, 2025, 10 years after the JCPOA came into effect.
Any current JCPOA member country can submit a noncompliance complaint against Iran to a UN dispute resolution panel. Once such a complaint is submitted, a 30-day window opens during which the 15-member Security Council must vote on a resolution to continue lifting sanctions. This resolution requires affirmative support from at least nine members of the Security Council and no vetoes from the five permanent members of the council — China, France, Russia, the UK and the US.
If the Security Council fails to adopt the resolution, all UN sanctions that were lifted under the JCPOA are automatically reimposed. This is what gives the mechanism its “automatic” quality: Unless the Security Council agrees to continue sanctions relief, the default outcome is a return to the pre-2015 UN sanctions regime.
The structure of the snapback process effectively means that permanent members of the Security Council cannot block the reimposition of sanctions once the process is triggered.
Because the Trump administration withdrew from the deal in 2018, the US can no longer trigger the snapback mechanism. In 2020, the Trump administration attempted to invoke the snapback unilaterally, but all other parties to the agreement and nearly all Security Council members dismissing the US move as illegitimate.
Despite this, Washington could still play a behind-the-scenes role by encouraging European states to initiate the snapback process. The US appears to be pursuing indirect talks with Iran, but the snapback mechanism remains a lifeline for the US in negotiations. Trump also faces domestic pressure to increase sanctions: In February, US Sen. Pete Ricketts (R-Neb.) along with US representatives Claudia Tenney (R-N.Y.) and Josh Gottheimer (D-N.J.) introduced a bipartisan resolution calling on the UK, France and Germany to trigger snapback before the October deadline.
What sanctions are on the table?
If the snapback mechanism is triggered, all UN sanctions previously levied on Iran would be reimposed. These include a general arms embargo on Iran; a ban on Iran’s uranium enrichment; sanctioning the transfer of ballistic missile technologies, including those involving nuclear capabilities, to Iran; a global asset freeze; and targeted travel bans against almost 100 Iranian individuals and entities.
States that breach UN sanctions on Iran would risk diplomatic repercussions and potential penalties enforced by the UN Security Council’s monitoring bodies. Additionally, individual countries like the US could impose secondary sanctions on violators.
But Iran also has friends on the Security Council — most notably Russia and China, who may seek to delegitimize any European move to trigger snapback. But given the nature of the snapback mechanism, their ability to prevent sanctions from being reinstated is very limited.
In the months ahead, the decision to activate snapback will likely hinge on the progress of nuclear negotiations. Currently, these talks are at a standstill. The most recent round of indirect negotiations between the US and Iran, mediated by Oman, ended in June following Israeli airstrikes on Iran.
Trump has said that talks are set to resume soon, and while Araghchi said on Saturday that Iran is “reviewing” the details of a possible resumption of talks, no date or location has been set, according to Iran’s Foreign Ministry.
On Monday, Ali Akbar Velayati, a senior adviser to Iran's supreme leader, said "If negotiations are to be conditioned on stopping enrichment, such negotiations will definitely not take place."
As Al-Monitor's correspondent in Tehran reported in recent days, Iran's rhetoric surrounding its nuclear program has grown increasingly ambiguous since the war with Israel — reflecting a growing rift in the country between hard-liners pushing for nuclear weaponization and moderates who seek to keep diplomatic channels open.
For European capitals and Washington, the threat of reimposing multilateral sanctions serves as leverage both to deter further Iranian nuclear escalation and compel Iran to reengage diplomatically. Keeping the snapback option on the table may be less about imminent activation and more about strengthening their hand ahead of nuclear negotiations.