Without prompt action, the United States and Europe may soon lose the ability to sanction Iran’s nuclear program effectively.
Israel and the United States did Europe and the civilized world a massive favor by striking Iran’s nuclear program and much of the regime’s ballistic missile production facilities. Iran’s missiles and drones have already helped slaughter European civilians and cities in Ukraine—a successful nuclear weapon program would imperil European capitals as well. The United States never expected Europe to participate in the strikes, but now Europe must do its part in implementing sanctions—and fast.
The first Trump administration returned economic sanctions on Iran unilaterally. But Europe is in the driver’s seat to restore and retain the vital international arms and nuclear sanctions at the United Nations. These restrictions from the old Iran deal are expiring fast. The most pivotal sunset arrives on October 18, 2025, the deal’s self-described “Termination Day.” If that day comes and goes without action from the West, the possibility of re-initiating UN sanctions against Iran, including arms, missile, and nuclear embargoes, will expire permanently, and the UN Security Council will officially close the nuclear file on Iran. This outcome cannot be allowed.
While Iran’s nuclear program has suffered a significant setback, the country is still widely out of compliance with its original nuclear obligations, as was thoroughly documented by the IAEA just prior to Israeli and US strikes. Tehran’s recent decision to halt cooperation with the IAEA only heightens the need for strict international sanctions to continue.
Fortunately, the Iran deal had a mechanism known as the “snapback,” which allows participants of the original deal to unilaterally and permanently restore all sanctions against Iran to their original and stronger status as they had existed prior to the 2015 pact. Since the United States withdrew from the deal in 2018, the Trump administration has deferred responsibility for conducting snapback to the other Western participants of the JCPOA: the United Kingdom, France, and Germany (collectively referred to as the E3). The E3 has chosen not to exercise this option despite Iran repeatedly violating its nuclear commitments over the past six years.
Snapback expires along with all other UN sanctions on October 18, but the West doesn’t even have that long. Once the snapback process is invoked, sanctions officially take 30 days to return—a timeline that bureaucratic processing and debates in the UN Security Council could extend. This places the functional deadline closer to September 10.
Snapback faces even further peril at the council from the rotating bureaucratic leadership. Each month, a new member of the council takes the helm and controls various bureaucratic processes, including those vital for the successful implementation of snapback. Russia is set to rotate into the presidency of the Security Council in October and would be keen to block or undermine the snapback process should it be initiated in September. Meanwhile, Pakistan leads the Council in July and could also be convinced to do Tehran or Moscow’s bidding.
Should Europe successfully navigate the icebergs of the Security Council’s calendar, the difficult part of enforcing the renewed sanctions would remain after the snapback is imposed and UN sanctions are restored. The old pre-2015 UN sanctions regime relied on an eight-member Panel of Experts to develop, monitor, and advance sanctions enforcement against Iran. However, the panel’s funding and mandate required annual renewal under the UN framework.
Russia made waves last year when it vetoed the extension of the similarly designed Panel of Experts for sanctions against North Korea. Moscow is almost certain to use its veto again to block the practical revival of the sanctions, and there would be little the West could do to prevent this outcome. The United States and Europe should start preparing for that eventuality now.
In lieu of the United Nations running sanctions enforcement, the West should immediately begin creating a multinational coalition of like-minded countries interested in enforcing what the United Nations will not. This coalition should share information on Tehran’s sanctions-busting efforts with willing UN member states and use their collective voice to impose pressure on all countries to abide by the renewed sanctions.
Enforcing sanctions requires funding large teams of technical experts. It would be wise for the United States to ease the budgetary burden of such hires. Congress and the Executive Branch should develop and fund a sanctions technical support program to support partner nations in identifying and disrupting all instances of Iranian sanctions evasion. As the United States bolsters its partners’ military forces, Washington should lead efforts to train foreign sanctions and compliance officers, develop intelligence-sharing processes, and support any UN efforts to expand enforcement of renewed Iran sanctions.
The UN sanctions should never have been lifted in the first place, and Tehran rewarded the international community with a decade of terror and nuclear extortion. European leaders accommodated this behavior for too long, and now they have precious little time to make it right. Yet, they have a significant opportunity to work with the Trump administration and demonstrate that they can be powerful partners against shared threats. If snapback and the ensuing enforcement efforts are executed in the right way, this could be a catalyst for a much more productive transatlantic relationship in addressing threats in the Middle East.
About the Author: Gabriel Noronha
Gabriel Noronha is a fellow with the Jewish Institute for National Security of America (JINSA) and the President of POLARIS National Security. He served as the Special Advisor for Iran at the State Department in the first Trump administration and as the Special Assistant for the Senate Armed Services Committee under Chairmen John McCain and Jim Inhofe. Follow him on X: @GlNoronha.
Image: Lev Radin / Shutterstock.com.
