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Snapback sanctions: “tempest in a cup of tea”

Commentators on the Iran nuclear issue are expressing their views on so-called “snapback” sanctions: 
• Kian Shanfi, RFE/RL, May 29, 2025 - The JCPOA E3, France, Germany and the United Kingdom, are making repeated threats to call for “snapback” sanctions on Iran if it fails to reach an agreement with Washington by the end of June. 
 • Eldar Mamedov, Responsible Statecraft May 30, 2025 - The E3 may trigger snapback sanctions on Iran by August 2025 if Iran and the United States do not reach a “substantial deal” by then (reported by Reuters, May 13). UK, France, and Germany are pushing snap-back sanctions at just the wrong time. 
• David Albright, ISIS, June 6, 2025 - [T]he E3 should trigger the reimposition of UN Iran sanctions via the snapback procedure outlined in the Joint Comprehensive Plan of Action and associated UN Resolution 2231. This action would also cause the return of the UN Security Council demand that Iran end its uranium enrichment program. 

 What are “snapback” sanctions, who can initiate them, and what is the process for doing so? I will answer those questions in this posting. To start, I will paraphrase the Oklahoma song: 
        A lot of tempest in a cup of tea. Snapback sanctions don’t sound very good to me. 

 What are “snapback" sanctions? 
Re-imposing the sanctions provisions of the UN Security Council resolutions on Iran from 2006-2015, which were terminated when UNSC/RES/2231 (2015) endorsed the JCPOA. Those UNSC sanctions applied globally to all States. 
Who can initiate them? 
A party to the JCPOA, that is, China, France, Germany, Russia and the United Kingdom. With President Trump’s withdrawal of the U.S. from JCPOA in 2018, the U.S. is not a party and therefore cannot utilize the JCPOA Dispute Resolution Mechanism. 
What is the process for doing so? 
The process is the Dispute Resolution Mechanism, defined in the JCPOA Main Body in the ultimate paragraphs 36 and 37, usually call the “snapback mechanism.” The text of those paragraphs is below. Here is a summary: 
UNSC/RES/2231 (2025) - Dispute Resolution Mechanism 
    36. Complaint made by E3 to JCPOA Joint Commission (15 or more days) 
     Referred to Ministers of Foreign Affairs (15 or more days) 
     Iran requests consideration by Advisory Board (15 days) 
     Back to Joint Commission for decision (5 days) 
     E3 would notify the UN Security Council. 
    37. Security Council consideration (scheduled according to its calendar) 
    Vote on continuing sanctions lifting (3 days) 
    UNSC decision to continue sanctions lifting or put back in place UNSC sanctions. 
    October 18, 2025. UNSC/RES/2231 terminates. 
When can that mechansm be utilized by a JCPOA party? The Dispute Resolution Mechanism is available to parties as long as the UNSC resolution is in force. As specified in JCPOA Annex V, Implementation Plan, E. UNSCR Termination Day, Paragraph 23, which reads: 
    23. UN Security Council resolution Termination Day will occur in accordance with the terms of the UN     Security Council resolution endorsing the JCPOA, which is 10 years from Adoption Day, 

JCPOA adoption day was October 18, 2015. Therefore, the resolution terminates on October 18, 2025, and the JCPOA Dispute Resolution Mechanism is no longer available after that date. 

Conclusion. Activating the Dispute Resolution Mechanism in JCPOA would start a complex series of steps by the JCPOA Joint Commission taking two months and probably more before it could pass to the UN Security Council. Iran can be expected to use all available legal procedures to delay the consideration. Once it goes to the UN Security Council, further delays can be expected. Russia will have the chair of the Security Council in September 2025 and thus can control its agenda. 
 
While it is possible that the UN Security Council could take the action that would result in snapback of its sanctions on Iran, the chances of that happening are not high. 

And as Richard Nephew said during the BAS webinar on May 14, Iran Update: What happens now?, the effect on Iran of snapback sanctions would not be large since U.S. sanctions have already covered most everything. 

 In sum, in my view, the current discussion of snapback sanctions is a “lot of tempest in a cup of tea.”

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