Newly Restored U.N. Snapback Sanctions on Iran

Extensive international sanctions and restrictions on Iran were suspended under the 2015 nuclear deal, a.k.a. the Joint Comprehensive Plan of Action (JCPOA). However, a provision in U.N. Security Council Resolution 2231 known as “snapback” enabled any of the participants in the JCPOA to initiate United Nations Security Council (UNSC) action to resume application of the suspended sanctions and restrictions in the event of Iranian noncompliance. 

Once initiated, snapback could only be prevented if the UNSC passed a resolution to continue sanctions relief, which could be vetoed by any of the permanent five members of the Council (the United States, Russia, China, the United Kingdom, and France). However, under the JCPOA, if snapback did not take effect by October 18, 2025, all UNSC sanctions on Iran would be terminated and the Iranian nuclear file would be removed from the agenda of the UNSC.

Given this deadline and the Iranian regime’s blatant violations of its JCPOA obligations, the UK, France, and Germany (the “E3”) initiated snapback on August 28, 2025. The E3 offered to support a resolution postponing and extending the deadline for snapback if Iran, in the words of the E3 foreign ministers, “agreed to resume direct and unconditional negotiations with the United States, return to compliance with its legally binding safeguards obligations, and address its high enriched uranium stockpile.” The ministers stated that “Iran did not engage seriously with this offer.” Consequently, snapback took effect on September 27, 2025. 

This resource summarizes the UNSC sanctions and restrictions on Iran which are once again in force. The snapped-back provisions are contained in UNSC Resolutions 1696, 1737, 1747, 1803, 1835, and 1929, which were adopted between 2006 and 2010.

Zero-Enrichment Standard

Resolution 1929 demanded “that Iran shall suspend all enrichment-related and reprocessing activities, including research and development, to be verified by the IAEA [International Atomic Energy Agency, the UN’s nuclear watchdog].” Tehran has never abided by this demand. Zero enrichment was the UN’s requirement for Iran’s nuclear program until the JCPOA permitted enrichment at progressively increasing levels. Since 2019, Iran has enriched uranium at levels and in amounts that go well beyond what the 2015 deal permitted. 

Iran has never needed to enrich uranium in order to benefit from nuclear energy, and despite its claims, it has no right to enrich under the Nuclear Non-Proliferation Treaty (NPT). Tehran’s insistence on enriching—despite international isolation and pressure to stop—its frequent nuclear cheating, and its refusal to cooperate adequately with the International Atomic Energy Agency (IAEA) leads to the conclusion that Iran seeks at least the ability to develop nuclear weapons at a time of its choosing. Consequently, allowing Iran to enrich and stockpile any uranium whatsoever, which Iran could subsequently choose to enrich to a weapons-grade level, is too great a risk. Zero enrichment must remain an international red line.

Zero Heavy-Water Project Work Standard

Resolution 1737 expanded 1929’s requirement for zero enrichment to include no “work on all heavy water-related projects, including the construction of a research reactor moderated by heavy water, also to be verified by the IAEA.” This provision addressed Iran’s secret efforts to build a heavy-water reactor, Arak, that could produce plutonium. 

The JCPOA required Iran to redesign the Arak reactor to make unable to produce large amounts of weapons-grade plutonium. However, the deal would have eventually allowed Iran to reprocess spent fuel—which can be used for nuclear weapons—from heavy-water nuclear reactors; and to build new heavy-water reactors, which would annually produce enough plutonium to fuel several nuclear weapons. 

Further, Iran did not comply with the JCPOA’s requirements regarding the Arak reactor. It did not render the entire reactor incapable of producing weapons-grade plutonium; its stockpile of heavy water repeatedly exceeded the JCPOA’s limits; and it moved part of its heavy-water stockpile to Oman—while keeping that heavy-water under its control—in order to claim that it was technically in compliance. Iran has informed the IAEA that it intends to bring Arak online in 2026.

Again, as a serial nuclear cheater, Iran has forfeited the benefit of the doubt and must not be allowed to build and operate heavy-water reactors that pave the way for Iran to develop plutonium-fueled nuclear weapons.

Ban on Ballistic-Missile Activities

Resolution 1929 “[d]ecides that Iran shall not undertake any activity related to ballistic missiles capable of delivering nuclear weapons, including launches using ballistic missile technology, and that States shall take all necessary measures to prevent the transfer of technology or technical assistance to Iran related to such activities.”

Iran has test-fired more than 30 nuclear-capable ballistic missiles since July 2015, despite a UNSC resolution, approved along with the nuclear accord, which explicitly calls on Iran to refrain from such activity. Iran has shown no signs of slowing the development of its ballistic missile program, which is inextricably intertwined with its nuclear program. In fact, long-range ballistic missiles have historically always been developed in unison with a nuclear weapons program. Iran has invested heavily in its missile and space programs and is making every effort to make them more efficient and operational.

Ballistic missiles are a critical component of all nuclear weapons-having countries’ arsenals. A deliverable nuclear weapon requires three components: enriched fissile material (uranium in Iran’s case), a delivery vehicle (usually some sort of missile—whether fired from land, sea or air), and a warhead that integrates the two. For this reason, ballistic missiles cannot be separated from the nuclear issue because they are the primary launch platform for any nuclear, chemical or biological warhead. Therefore, all countries that have developed or sought nuclear weapons also developed long-range ballistic missiles. It is clear that the only reason for Iran to have advanced ballistic missiles is to deliver a nuclear bomb.

Iran’s nuclear and ballistic missile program has long depended on external assistance from other states, particularly North Korea (formally known as the Democratic People’s Republic of Korea, or DPRK) and China. 

The DPRK has been instrumental in the development of Iran’s ballistic missile program, with Iran-DPRK missile cooperation dating back to the 1980s. Iran and the DPRK signed a “Civilian Scientific and Technological Cooperation Agreement” in September 2012. The accord provides a means for both countries to dodge U.N. and U.S. sanctions on “missile proliferation activities.” Under the agreement, “when one side masters or acquires a key missile-related technology, the other now institutionally benefits.”

China’s support for Iran’s ballistic missile program may reach back to the beginning of Iran’s ballistic missile program in the mid-1980s. In fact, during the Iran-Iraq War (1980-1988), China was one of the few countries that provided Iran with lethal aid and military equipment. Iran began to import solid-propellant production equipment and technology from China in the 1990s. 

More recently, China has continued to provide Iran with materials it needs to develop ballistic missiles indigenously, violating UNSC Resolution 2231, which requires UNSC approval of Iran’s imports of materials that could contribute to the development of ballistic missiles.

In 2017, Chinese tech firms sold U.S.-designated Iranian company Shiraz Electronics Industries millions of dollars-worth of satellite positioning, navigation, and timing equipment. In 2021, Iran was granted further access to Chinese satellite navigation systems for military purposes. In March 2022, the U.S. Department of the Treasury revealed that Iran procured machines to process nitrile butadiene rubber and an inert gas jet milling system used for making solid propellant from Chinese suppliers.

In June 2023, the U.S. Department of the Treasury designated a procurement network of individuals and entities in China, Hong Kong, and Iran, which facilitated transactions on behalf of key players in Iran’s military industrial base, including subsidiaries of the defense ministry. These actors, including Parchin Chemicals Industries (PCI), Aerospace Industries Organization (AIO), Iran Electronics Industries (IEI), and P.B. Sadr, allegedly imported sensitive materials from China, such as centrifuges and associated equipment and services; dual-use, nonferrous metals; and electronics, modules for radars, gyroscopes, and accelerometers.

In April 2025, Treasury sanctioned twelve people or entities in Iran and China for their involvement in “procuring ballistic missile propellant ingredients” for the IRGC. Shortly thereafter, Treasury also sanctioned Chinese targets for their assistance to Iran’s ballistic-missile program.

In June 2025, the Wall Street Journalreported that Iran had “ordered thousands of tons of ballistic-missile ingredients from China,” with “[s]hipments of ammonium perchlorate . . . expected to reach Iran in coming months” that “could fuel hundreds of ballistic missiles.”

Thus, Iran’s ballistic-missile program is intertwined with its pursuit of nuclear weapons, and the program depends on foreign assistance. Consequently, the aforementioned snapped-back ban on Iran’s ballistic-missile activities and on foreign help with those activities is vital to preventing a nuclear-armed Iran.

Travel Restrictions and Asset Freeze Targeting Proliferation - and Delivery System-Related Individuals and Entities and Iran’s Islamic Revolutionary Guard Corps (IRGC)

Resolution 1929 “[d]ecide[d] that all States shall take the necessary measures to prevent the entry into or transit through their territories of individuals” designated under any of the aforementioned resolutions or by the Security Council or Committee” of individuals involved with “Iran’s proliferation sensitive nuclear activities or for the development of nuclear weapon delivery systems, including through the involvement in procurement of the prohibited items, goods, equipment, materials and technology . . .” 

Taken together, Resolutions 1737 and 1929 also outright require all states to “freeze the funds, other financial assets and economic resources” on their territories that are owned or controlled by the aforementioned designated persons, as well as other persons or entities designated for the same reasons.

Resolution 1929 also applies the travel ban and asset freeze to designated IRGC individuals and entities and those “acting on their behalf or at their direction, and to entities owned or controlled by them, including through illicit means.” 1929 also “calls upon all States to exercise vigilance over those transactions involving the IRGC that could contribute to Iran’s proliferation-sensitive nuclear activities or the development of nuclear weapon delivery systems.” 

Resolution 1929 also applies the asset freeze to specified entities, agents, and subsidiaries of the Islamic Republic of Iran Shipping Lines (IRISL).

Entities and persons subject to the asset freeze and travel ban include, but are not limited to: 

  • the Atomic Energy Organization of Iran and select officials thereof;
  • officials of and energy providers for Iran’s uranium and heavy-water reactors;
  • Pars Trash Company and Farayand Technique, involved in Iran’s uranium-enrichment centrifuge program;
  • the Defense Industries Organization, controlled by Iran’s defense ministry;
  • senior individuals and subordinate entities of the Aerospace Industries Organization (AIO), which is central to the ballistic-missile program;
  • Bank Sepah, which supports the AIO;
  • Doostan International Company, a supplier of elements of the ballistic-missile program;
  • Defense Technology and Science Research Center (DTSRC), controlled by Iran’s defense ministry, and the DTSRC subordinate Malek Ashtar University;
  • Modern Industries Technique Company, responsible for designing and building the Arak reactor;
  • Khatam al-Anbiya Construction Headquarters (KAA), an IRGC-owned firm involved in big civilian and military building projects and other engineering work, including the building of the Fordow uranium-enrichment plant, and numerous KAA subsidiaries;
  • Gen. Yahya Rahim Safavi, a senior military adviser to Iran’s supreme leader and a former commander of the IRGC;
  • Ali Akbar Ahmadian, chief of the IRGC Joint Staff;
  • Mohammad Hejazi, commander of the IRGC’s Basij paramilitary organization;
  • Morteza Rezaie, senior IRGC official;
  • Morteza Safari, commander of the IRGC’s Imam Hossein Command and former commander of the IRGC Navy;

Arms Exports Ban

Resolution 1747 prohibited Iranian exports of “arms or related materiel” and required all states to prohibit “the procurement of such items from Iran by their nationals, or using their flag vessels or aircraft, and whether or not originating in the territory of Iran.”

Iran has long exported large quantities of high-quality arms to its proxies and partners across the Middle East, contributing to regional instability. These groups include Asaib Ahl al-Haq (Iraq), Al-Ashtar Brigades (Bahrain), the Badr Organization (Iraq), Hamas (West Bank and Gaza), Hezbollah (Lebanon and beyond), Palestinian Islamic Jihad (Gaza), and the Houthis (Yemen). These arms include missiles, drones, IEDs, rifles, and rocket-propelled grenades. Using these weapons, Iran’s proxies and partners have killed hundreds of American soldiers, Israelis, and citizens of other U.S. allies. Banning arms exports can disrupt Iran’s ability to supply its partners in crime, saving countless lives and enhancing regional security.

Ban on Iranian Export or Foreign Import of Ballistic-Missile Program Items

Targeting Iran’s ability to proliferate ballistic-missile technology, 1737 banned Iran from exporting an extensive array of items related to ballistic-missile program items. The resolution also required all states to “prohibit the procurement of such items from Iran by their nationals, or using their flag vessels or aircraft, and whether or not originating in the territory of Iran.” 

Iran has aided North Korea’s ballistic-missile program in particular. Technology and knowledge flow both ways between Iran and the DPRK. Many North Korean ballistic missile tests have featured precision technology developed by Iran. According to Israeli defense analyst Tal Inbar, “Iran purchased North Korea’s technical know-how on ballistic missile production, upgraded the DPRK missiles’ forward section, and distributed these advancements back to North Korea. The similarities between North Korean missiles launched during recent tests and Iranian technology suggest that Iran is a possible contributor to North Korea’s nuclear buildup, rather than a mere transactional partner.”

Ban on Provision of Military Items

Resolution 1929 “[d]ecides that all States shall prevent the direct or indirect supply, sale or transfer to Iran, from or through their territories or by their nationals or individuals subject to their jurisdiction, or using their flag vessels or aircraft, and whether or not originating in their territories, of any battle tanks, armoured combat vehicles, large calibre artillery systems, combat aircraft, attack helicopters, warships, missiles or missile systems . . . or related materiel, including spare parts . . . [and] decides further that all States shall prevent the provision to Iran by their nationals or from or through their territories of technical training, financial resources or services, advice, other services or assistance related to the supply, sale, transfer, provision, manufacture, maintenance or use of such arms and related materiel, and, in this context, calls upon all States to exercise vigilance and restraint over the supply, sale, transfer, provision, manufacture and use of all other arms and related materiel.”

Any weapons that cannot be provided to Iran consequently cannot be used by Iran against American forces, Israel, or other regional countries. Likewise, Iran cannot reexport those weapons to its proxies and partners throughout the Middle East.

Restrictions on Provision of Enrichment or Heavy-Water Materials, Equipment, Goods, and Technology

To impede Iran’s ability to develop weapons-grade uranium or plutonium, as well as vehicles to deliver nuclear weapons, Resolution 1737 also decided that all states “shall take the necessary measures to prevent the supply, sale or transfer directly or indirectly from their territories, or by their nationals or using their flag vessels or aircraft to, or for the use in or benefit of, Iran, and whether or not originating in their territories, of all items, materials, equipment, goods and technology which could contribute to Iran’s enrichment-related, reprocessing or heavy water-related activities, or to the development of nuclear weapon delivery systems.” 

To further restrict Iran’s abilities in this regard, 1737 decided that all states “shall also take the necessary measures to prevent the provision to Iran of any technical assistance or training, financial assistance, investment, brokering or other services, and the transfer of financial resources or services, related to the supply, sale, transfer, manufacture or use of the prohibited items, materials, equipment, goods and technology.” 

Requirement to Seize and Dispose of Iranian Arms, Missiles and Other Military Items, Nuclear-Related Items, and Ballistic-Missile Technology

Resolution 1929 authorizes and requires all States to “seize and dispose of”:

  • “any arms or related materiel”;
  • “all items, materials, equipment, goods and technology which could contribute to Iran’s enrichment-related, reprocessing or heavy water-related activities, or to the development of nuclear weapon delivery systems”;
  • additional items related to Iran’s proliferation-sensitive nuclear activities;
  • “battle tanks, armoured combat vehicles, large calibre artillery systems, combat aircraft, attack helicopters, warships, missiles or missile systems . . . or related materiel, including spare parts”; and
  • ballistic-missile technology.

This authorization and requirement enable states to disrupt Iran’s ability to advance its nuclear and ballistic-missile programs and attack American soldiers, Israel, and other regional countries.

Ban on Providing Bunkering Services

Resolution 1929 requires all States to prohibit the provision of bunkering services, such as provision of fuel or supplies, to Iranian-owned or Iranian-contracted vessels that they have reasonable grounds to believe are carrying items or technology that the same resolution requires states to seize and dispose of. This provision further impedes Iran’s ability to advance its nuclear and ballistic-missile programs and attack American soldiers, Israel, and other regional countries.

Hortatory Language on Financial Activities with Iranian Banks

Resolution 1803 “calls upon all States to exercise vigilance over the activities of financial institutions in their territories with all banks domiciled in Iran, in particular with Bank Melli and Bank Saderat, and their branches and subsidiaries abroad . . .” 

This provision hampers Iran from using the international financial system to move money in service of its nuclear and ballistic-missile programs and sponsorship of terrorism. As the U.S. Treasury Department has noted, Bank Melli “provides banking services to entities involved in Iran's nuclear and ballistic missile programs,” as well as to the IRGC and the latter’s Qods Force, both designated as Foreign Terrorist Organizations (FTOs) by the U.S. Likewise, the Iranian regime has used Bank Saderat to move money to Iran’s FTO proxies, including Hamas, Hezbollah, and Palestinian Islamic Jihad.

Hortatory Language on Restricting Banking by and with Iran

Resolution 1929 “[c]alls upon States to take appropriate measures that prohibit in their territories the opening of new branches, subsidiaries, or representative offices of Iranian banks, and also that prohibit Iranian banks from establishing new joint ventures, taking an ownership interest in or establishing or maintaining correspondent relationships with banks in their jurisdiction to prevent the provision of financial services if they have information that provides reasonable grounds to believe that these activities could contribute to Iran’s proliferation-sensitive nuclear activities or the development of nuclear weapon delivery systems.”

1929 also “[c]alls upon States to take appropriate measures that prohibit financial institutions within their territories or under their jurisdiction from opening representative offices or subsidiaries or banking accounts in Iran if they have information that provides reasonable grounds to believe that such financial services could contribute to Iran’s proliferation-sensitive nuclear activities or the development of nuclear weapon delivery systems.”

These provisions likewise make it harder from Iranian banks to do business with foreign financial institutions, impeding Tehran’s ability to carry out transactions in support of its nuclear and ballistic-missile programs.

Hortatory Language on Provision of Financial Services or Transfer of Financial Assets

Resolution 1929 calls upon all States “to prevent the provision of financial services, including insurance or re-insurance, or the transfer . . . of any financial or other assets or resources if they have information that provides reasonable grounds to believe that such services, assets or resources could contribute to Iran’s proliferation-sensitive nuclear activities, or the development of nuclear weapon delivery systems, including by freezing any financial or other assets or resources on their territories or that hereafter come within their territories, or that are subject to their jurisdiction or that hereafter become subject to their jurisdiction, that are related to such programmes or activities and applying enhanced monitoring to prevent all such transactions in accordance with their national authorities and legislation.”

Insurance and reinsurance in particular are services key to Iran’s shipping industry, which transports oil—Iran’s economic lifeline. Depriving Iran of insurance and reinsurance therefore further squeezes the regime’s finances and deprives it of revenue to fund its destabilizing activities.

Hortatory Language on Financial Assistance to and Financial Support for Trade with Iran

Resolution 1747 “[c]alls upon all States and international financial institutions not to enter into new commitments for grants, financial assistance, and concessional loans, to the Government of the Islamic Republic of Iran, except for humanitarian and developmental purposes.”

Resolution 1803 “[c]alls upon all States to exercise vigilance in entering into new commitments for public provided financial support for trade with Iran, including the granting of export credits, guarantees or insurance, to their nationals or entities involved in such trade, in order to avoid such financial support contributing to the proliferation sensitive nuclear activities, or to the development of nuclear weapon delivery systems . . .”

Since money is fungible, every dollar that Iran receives from abroad is another dollar that can bankroll Iran’s destabilizing activities. These provisions therefore can restrict the supply of outside funds to Iran and put added pressure on the regime at a time when Tehran’s economy is in shambles. 

Hortatory Language on Cargo Inspections

Resolution 1803 “[c]alls upon all States . . . to inspect the cargoes to and from Iran, of aircraft and vessels, at their airports and seaports, owned or operated by Iran Air Cargo and Islamic Republic of Iran Shipping Line [IRISL], provided there are reasonable grounds to believe that the aircraft or vessel is transporting [prohibited goods] . . .”

As the U.S. State Department has expressed “concern that IRISL is using its global transportation system to ship items of proliferation concern to Iran . . .” Iran Watch notes that IRISL “has transported prohibited military-related cargo and facilitated shipments on behalf of and destined for” Iran’s defense ministry and ministry subordinates, and “[h]as transported items controlled by the Nuclear Suppliers Group (NSG); has allegedly transported hydraulic press machinery and copper discs, which are used in explosively formed penetrators (EEPs); has allegedly shipped military-related items to Hezbollah; has allegedly shipped military-related items on behalf of the Islamic Revolutionary Guard Corps (IRGC) and the IRGC Quds Force.” IRISL has also transported chemical weapons precursors from China and shipped a precursor chemical to be used in Iran’s ballistic-missile program.

Iran Air Cargo is the cargo branch of Iran Air, the nation’s flag carrier. As the U.S. Treasury Department has stated, “Iran Air has a history of transporting goods on behalf of” the IRGC and Iran’s defense ministry, and “has also provided freight shipping services to Russia, including shipments of electronics and aircraft parts.” 

Thus, by urging states to carry out cargo inspections of IRISL vessels and Iran Air Cargo planes, the UNSC could make it harder for Iran to transport weapons and weapons-related materials for use by its WMD programs, by its terrorist proxies and partners, and by Russia for its war of aggression against Ukraine.