Germany, France, and Britain have long anticipated last-minute interference from Moscow in their talks with Iran. Now, that scenario appears to be unfolding: according to reports, Russia has submitted a draft resolution to the UN Security Council seeking an extension of Resolution 2231 – the measure that enshrined the 2015 nuclear deal between the UN veto powers and Iran, and which is set to expire on October 18.
For the three European states, Resolution 2231 is more than just a relic of the 2015 accord. It contains the so-called snapback mechanism, a clause that would allow the reinstatement of UN sanctions on Iran originally imposed between 2006 and 2010. That tool remains available to the Europeans until October, giving them leverage over Tehran. Their conditions: Iran must once again permit full IAEA inspections, disclose the whereabouts of its stockpile of highly enriched uranium, and re-engage in talks with Washington.
To that end, the Europeans have issued Tehran an ultimatum. Several negotiation rounds – most recently in Geneva with Iran’s deputy foreign minister Majid Takht-Ravanchi – ended “without a final result,” diplomats said. Officially, Europe insists it remains open to dialogue. In Tehran, however, the strategy is widely seen as an attempt to delegitimize Iran by leaning on Russia and China. At the same time, Iran has signaled interest in delaying the snapback – but only if the UN Security Council grants such an extension without preconditions.
From Tehran’s perspective, the European demands are difficult to meet. Disclosing uranium stockpiles could provide a pretext for new military strikes by the U.S. or Israel, critics argue. Allowing IAEA inspections is viewed as a bargaining chip for potential future talks with Washington. And as for reopening negotiations with the U.S., Iranian leaders point to Washington’s own lack of interest. Domestically, reformists warn of a dangerous escalation spiral, but Supreme Leader Ali Khamenei recently ruled out direct talks with the U.S., insisting that Washington’s goal is Iran’s total capitulation.
Should the UN sanctions be reactivated, their impact would depend largely on China’s reaction. Beijing currently buys roughly 90 percent of Iran’s oil exports, much of it through opaque channels designed to bypass U.S. secondary sanctions. If those sales were also covered by new UN sanctions, China could face greater pressure – but economic realities complicate matters. Iran accounts for more than 10 percent of China’s oil imports, often sold at steep discounts. Those supplies would be difficult to replace.
Among the sanctions under discussion is a ban on arms exports to Iran. Russia, Tehran’s main supplier, is unlikely to heed such restrictions. Yet doubts about Moscow’s reliability are growing in Iran. A member of the country’s Expediency Council recently claimed Russia had passed information about Iranian air-defense systems to Israel. Against this backdrop, Tehran has been deepening its military cooperation with China – though it remains unclear whether Beijing would alter its stance under renewed UN sanctions.
Another possible consequence of snapback would be a complete ban on uranium enrichment – strengthening Washington’s hand, since the U.S. rejects enrichment outright. Tehran insists on its right to enrich uranium for civilian purposes. Even if American strikes on Iranian nuclear facilities have diminished capacity, the lack of inspections increases the risk of illicit activity.
On the European level, snapback would trigger additional measures: account freezes, travel bans, targeted restrictions on trade. In practice, however, many of these effects are already being felt, as U.S. sanctions have largely cut European businesses and banks out of Iran. German exports to Iran fell to just €1.5 billion last year, placing the country 79th among Germany’s trading partners. In one case, an Iranian student in Italy had her bank account frozen simply because the word “Iran” appeared in a transfer reference.
Analysts warn that the most immediate effect of snapback would be psychological. Markets could see sharp currency swings, purchasing power erosion, layoffs, and rising public discontent, according to an Iranian intelligence ministry analysis cited by the exile broadcaster Iran International. Pro-government voices are already threatening retaliation in the Strait of Hormuz, such as boarding European-bound vessels to unsettle global energy markets.
Economically, the lower and middle classes would bear the brunt of renewed sanctions, says Hossein Raghfar, an economist at Alzahra University. Wealthy elites and regime-affiliated business groups – particularly those linked to the Revolutionary Guard or religious foundations – would likely profit instead, using their control of smuggling networks and monopoly positions to strengthen their grip.
Whether Europe can use snapback to exert meaningful pressure on Tehran remains uncertain. The mechanism exists, but its effectiveness will depend on geopolitical alignments, economic dependencies, and internal dynamics within Iran. What is certain is that in the standoff over Iran’s nuclear program, political signaling and economic coercion have become inseparable – and the next escalation step is closer than many Europeans would like to admit.
