Summary
On 18 October 2023, eight years after UNSCR 2231 (which incorporated and endorsed the JCPOA) was adopted, “transition day” triggered the termination of the UN asset freezes on individuals and entities listed in Annex B of the resolution and restrictions related to development of nuclear weapons delivery systems (including ballistic missiles). The restrictions on nuclear materials (proliferation sensitive goods and technology imports and exports ban) and investment ban restrictions remained in place for another two years, as stipulated in the JCPOA agreement.
Concerned that Iran had violated the terms of the agreement with its enrichment activities and lack of full cooperation with IAEA inspections, the EU and UK both announced the adoption of autonomous sanctions measures on Iran’s nuclear weapons delivery systems (including ballistic missiles) and on the individuals and entities previously subject to asset freeze restrictions under the UN regime. In parallel, the US imposed additional sanctions on 26 individuals and entities associated with Iran’s ballistic missile and drone programs. Iran condemned the actions as “unilateral, illegal and politically unjustifiable.”
The IAEA’s quarterly report of 15 November 2023 documented the continued growth of Iran’s enriched uranium stockpiles and criticized the continued impasse over safeguards concerns and lack of transparency. It reported that Iran had accumulated an enriched uranium stockpile of nearly 4.5 tons, including 6.7kg enriched to 60%. At its board meeting on 22 November 2023, the IAEA reiterated criticism of Iran’s September 2023 decision to bar top inspectors and reported no progress in investigations into past activities at undeclared sites. This took place in the midst of heighted military tensions and threats to international shipping in the region triggered by Israel’s invasion of Gaza.
During December 2023, the US, EU and UK designated additional individuals and entities in Iran for their support of Iranian-backed groups in the region supporting Hamas and its efforts against Israel (the Houthis in Yemen and Hezbollah in Lebanon in particular). The IAEA informed its member states that Iran had increased its production of 60% enriched uranium (closest to weapons grade) by three-fold above November 2023 levels, a development that was specifically condemned by the US and the EU+3.
In the first months of 2024, the IAEA continued to express concerns about Iran’s enrichment or uranium, but noted at its March 2024 board meeting that the level enriched to 60% had declined slightly. Separately, the U.S. intelligence community came to the conclusion that “Iran is not currently undertaking the key nuclear weapons-development activities necessary to produce a testable nuclear device.” Additional autonomous US sanctions were added to Iranian individuals and entities for Iran’s continued export of drones and drone technology to Russia on 2 February 2024.
Iran’s long-standing proxy war with Israel flared up into direct hostilities in April 2024, after Iran launched hundreds of missiles and drones against Israeli targets in retaliation for Israel’s strike on Iran’s consulate in Damascus on 1 April 2024 that killed two high ranking IRGC commanders.
In his June 2024 report, the Secretary-General stated that “as at 11 May 2024, the total stockpile of (Iran’s) enriched uranium was 6,201.3 kg (which exceeds the 202.8 kg limit), including 781.3 kg enriched to 20 per cent uranium 235 and 144.1 kg enriched to 60 per cent uranium 235.” On 5 June 2024, the IAEA Board voted 20 to 2 in favor of a resolution censuring Iran, declaring it non-compliant with its NPT/JCPOA obligations – the first since November 2022 – for its denial of access to Iranian facilities and lack of progress in resolving safeguards concerns.
On 28 June 2024, Iran held elections, following the 19 May 2024 helicopter crash in a remote area of Iran that killed President Raisi and Foreign Minister Amir-Abdollahian. Despite low turnout rates in the run-off election on 5 July 2024, Masoud Pezeshkian, who was backed by reformists, regional constituencies, and moderates, was elected President. The threat of a broader regional conflict flared again at the end of July 2024, following Israel’s assassination of Hamas political leader Ismail Haniyeh in Tehran, shortly after he attended the inauguration of newly elected President Pezeshkian.
Purposes
Coerce
Constrain
Constrain Iran from accessing to sensitive technologies in support of its nuclear and missile programs and from supporting armed groups in the region.
Signal
Signal continued support for non-proliferation norms and a partial normalization in relations with Iran on the nuclear issue.
Sanctions type
Ongoing sanctions:
- Restrictions on proliferation sensitive goods and technology imports and exports ban (specific items and the related transfer, training, assistance, investment, brokering, and other services, including nuclear weapon delivery systems restrictions) and investment and acquisition of interest in foreign commercial activity involving uranium mining or nuclear material and technology made subject to prior case-by-case Security Council approval (exemptions and the related procedures specified).
Termination of existing sanctions:
- Asset freeze and restrictions related to development of nuclear weapons delivery systems were terminated at the start of the episode.
For more information, see https://main.un.org/securitycouncil/en/content/2231/background
Designation criteria
No individual sanctions in place.
Potential scope
Potential scope of impact
UN sanctions can have some non-discriminating impact on the general population, since they include arms embargoes, diplomatic sanctions, and/or restrictions on the conduct of particular activities or the export of specific commodities.
Implementation
Sanctions were imposed for a limited time period and their dates of termination were specified. Proliferation sensitive goods and technology and investment ban restrictions were imposed for 10 years from JCPOA Adoption Day (until 18.10.2025), restrictions related to development of nuclear weapon delivery systems and asset freeze were imposed for 8 years (until 18.10.2023).
All UNSCR 2231 restrictions will be terminated earlier, if IAEA report confirms the Broader Conclusion of JCPOA or terminated and replaced with provisions of UNSCR 1696, 1737, 1747, 1803, 1835, and 1929 as a result of significant non-performance of commitments by Iran under the JCPOA and UNSCR 2231 “snapback” mechanism.
No Sanctions Committee and Panel of Experts in place (their functions were taken over by other actors – Security Council, UN Secretariat, and the Secretary General).
No individual sanctions in place. Enforcement authorities specified.
Restrictions specifications:
Security Council Facilitator reports:
https://www.un.org/securitycouncil/content/2231/reports-and-briefings-facilitator
Effectiveness
Constraint
Policy outcome
While Iran’s nuclear program has been somewhat constrained by the IAEA inspection requirements of the JCPOA, its ballistic missile program and arms exports to armed groups throughout the region have continued. Iran’s stockpile of highly enriched uranium (up to 60%) has increased, and its total stockpile of enriched uranium reached a level 30 times higher than its allowed limit, continuing its policy of non-compliance with the agreement in response to the additional autonomous sanctions added by the US, EU and UK after some of the UN sanctions lapsed.
Sanctions contribution
While UN targeted sanctions remain in place, constraints to the development of Iran’s nuclear program came chiefly from the enhanced monitoring and verification mechanisms established in the JCPOA and monitored by the IAEA. The re-imposition of unilateral sanctions on nuclear weapons delivery systems and individual asset freezes (the UN sanctions lifted at the start of the episode) by the US, EU and the UK, undermined the agreement and contributed to the reconstitution of some of Iran's nuclear capabilities.
Signaling
Policy outcome
Support for nuclear non-proliferation norms were articulated by the Secretary-General and IAEA assessments, but the inability to agree on how to get the US back into the JCPOA, Russia’s continued purchase of drones from Iran, as well as the reimposition of terminated UN sanctions by the US, EU and UK, undermined a unified Security Council message on Iran, despite verbal commitment to the agreement.
Sanctions contribution
The continuation of a gradual reduction of UN sanctions through the JCPOA sent a critical message through which the normalization of diplomatic relations with Iran has taken place, but unilateral sanctions and broader diplomatic and commercial activities are more important. The IAEA’s censure (vote to declare Iran non-compliant with its NPT/JCPOA obligations) appears more significant than the remaining UN sanctions.
Overall
Unintended consequences
Humanitarian consequences (but due to unilateral sanctions, not UN restrictive measures).
UN sanctions resolutions guide
Substantive
- Provisions of UNSCR 2231 entered into force on 16.01.2016 [JCPOA Implementation Day]
- Permits, upon prior case-by-case approval by the Security Council, imports to Iran of all items, materials, equipment, goods and technology which could contribute to Iran’s enrichment-related, reprocessing or heavy water-related activities, or development of nuclear weapon delivery systems (10 years after JCPOA Adoption Day – 18.10.2025, earlier if IAEA report confirms the Broader Conclusion)
- Specifies such items, materials, equipment, goods and technology (INFCIRC/254/Rev.12/Part 1, INFCIRC/254/Rev.9/Part 2, or their most recent versions, and any items states determine could contribute to reprocessing or enrichment-related or heavy water-related activities inconsistent with the JCPOA)
- Permits, upon prior case-by-case approval by the Security Council, technical training, technical or financial assistance, investment, brokering or other services, and transfer of financial resources or services, related to supply, sale, transfer, manufacture or use of prohibited items, materials, equipment, goods and technology (10 years after JCPOA Adoption Day – 18.10.2025, earlier if IAEA report confirms the Broader Conclusion)
- Permits, upon prior case-by-case approval by the Security Council, investment and acquisition of an interest in foreign commercial activity involving uranium mining or production or use of nuclear material and technology listed in INFCIRC/254/Rev.12/Part 1 by Iran, its nationals, entities under its jurisdiction, or individuals and entities owned or controlled by them, acting on their behalf, or at their direction (10 years after JCPOA Adoption Day – 18.10.2025, earlier if IAEA report confirms the Broader Conclusion)
- Specifies exemptions from prior Security Council approval and the related exemption procedures for (1) items, materials, equipment, goods and technology set out in INFCIRC/254/Rev.9/Part 2; (2) equipment covered by B.1 of INFCIRC/254/Rev.12/Part 1 when such equipment is for light water reactors, low-enriched uranium covered by A.1.2 of INFCIRC/254/Rev.12/Part 1 when it is incorporated in assembled nuclear fuel elements for such reactors; and (3) items, materials, equipment, goods, technology, and related technical training, technical and financial assistance, investment, brokering or other services directly related to (a) necessary modification of two cascades at the Fordow facility for stable isotope production, (b) export of Iran’s enriched uranium in excess of 300kg in return for natural uranium, and (c) modernization of the Arak reactor based on agreed design
- Specifies that in case of IAEA report confirming the Broader Conclusion before 18.10.2025, prior Security Council approval requirements will be suspended immediately and the related exemptions will continue to apply, permitting such activities upon prior case-by-case Security Council and Joint Commission notification
- Decides that states shall prevent and prohibit any activities inconsistent with the specified nuclear and arms imports restrictions until the Termination Day (10 years after JCPOA Adoption day – 18.10.2025, provided sanctions have not been reinstated under the “snapback” mechanism) or earlier if IAEA report confirms the Broader Conclusion
- Calls for inspection of cargo to and from Iran if reasonable grounds for UNSCR 2231 or JCPOA violation
Procedural
- Specifies a “snapback” mechanism for reintroduction of provisions of UNSCR 1696, 1737, 1747, 1803, 1835, and 1929 and termination of provisions in paragraphs 7, 8, 16, and 20 of UNSCR 2231 if the UNSC fails to adopt a resolution to continue the termination of previous resolutions within 30 days of notification of an issue constituting significant non-performance of commitments under JCPOA by a JCPOA participant State [paragraphs 11 and 12 of UNSCR 2231 and 36 and 37 of JCPOA], unless the notifying state informs the UNSC that the issue has been resolved before the end of the 30-day period [paragraph 13 of UNSCR 2231]
- Specifies that the Security Council will directly undertake the tasks related to UNSCR 2231, including monitoring and improvement of implementation, answering of inquiries, provision of support and guidance, review of proposals for nuclear, ballistic missile, and arms-related transfers to and activities with Iran, examination of alleged inconsistencies with the resolution, and granting of exemptions to the restrictions
- Asks for Secretary-General reports on restrictions implementation (every 6 months)
