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September 30, 2025

This month’s newsletter features a new episode of Iran Watch Listen that
discusses emerging realities after the bombing of Iran’s nuclear program
and the return of United Nations sanctions against Iran, as well as news
and other resources related to the “snapback” of U.N. sanctions.

The newsletter also includes news about renewed Iranian missile activity,
as well as profiles of several entities now subject to renewed U.N.
Security Council sanctions. Additions to the Iran Watch library include
official documents related to snapback, reports and statements from the
International Atomic Energy Agency (IAEA)’s Board of Governors meeting, and
recent sanctions and enforcement actions by the United States.

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PUBLICATIONS

[4]

The U.N. Security Council meets to discuss threats to international peace
and security. (Photo Credit: United Nations/Manuel Elias)

Podcast | [5]Iran Watch Listen: Taking Stock of Strikes and Sanctions

Israeli and U.S. airstrikes in June set back Iran’s nuclear program, and
then France, Germany, and the United Kingdom (the “E3”) triggered the
JCPOA’s snapback mechanism to restore a decade’s worth of United Nations
sanctions. These actions changed the game when it comes to Tehran’s pursuit
of a nuclear weapon, but they also created new uncertainties. Valerie Lincy
and John Caves sat down with John Lauder, a Wisconsin Project Senior Fellow
with more than three decades of experience in the U.S. intelligence
community, to think through the new realities.

[6]LISTEN TO THE PODCAST

Policy Brief | [7]Trigger Warning: The Consequences of Snapping Back
Sanctions on Iran

In 2023, Iran Watch published a policy brief arguing for the triggering of
snapback that explained the U.N. measures which are now restored and
analyzed their likely effects. Snapback provides the E3, the United States,
and like-minded countries with a set of tools that can be immediately put
to use in countering the proliferation problem posed by Iran. These include
expanded legal authority to inspect cargos, restrictions on Iranian
shipping, and the potential for sanctions coordination between the United
States, the European Union, and other countries.

[8]READ THE POLICY BRIEF

Policy Brief | [9]Stuck in the Past: The U.N.’s 2231 List

Even before it expired in 2023, the United Nations’ 2231 List of targeted
sanctions on Iranian entities was woefully out of date, containing deceased
individuals and defunct or renamed companies. The revived [10]1737
Sanctions List has similar shortcomings. This policy brief from 2022
explains the issues and offers ideas for how the list can be brought up to
date by the countries implementing it, even if Russia and China obstruct an
overhaul at the Security Council.

[11]READ THE POLICY BRIEF

ENTITIES OF CONCERN

With the return of U.N. sanctions on Iran’s nuclear and missile programs,
dozens of Iranian entities are once again subject to financial and trade
restrictions. Detailed information about nearly all of these entities
[12]can be found on Iran Watch.

[13]Qods Aviation Industries (QAI)

A subsidiary of the [14]Iran Aviation Industries Organization (IAIO) that
designs and manufactures unmanned aerial vehicles (UAVs); according to the
U.N. Security Council, has produced UAVs and other products used by the
[15]Islamic Revolutionary Guard Corps (IRGC).

[16]LEARN MORE

[17]Malek Ashtar University

An Iranian university that supports the education and research and
development needs of the [18]Ministry of Defense and Armed Forces Logistics
(MODAFL); faculty members have conducted research relevant to missiles and
nuclear power.

[19]LEARN MORE

[20]Pars Aviation Services Company (PASC)

An aircraft supply and repair company that the U.N. Security Council has
identified as an entity affiliated with the IRGC; reportedly owned by
[21]Bonyad Taavon Sepah on behalf of the [22]IRGC Aerospace Force.

[23]LEARN MORE

IN THE NEWS

[24]

Iran tests a Khorramshahr-4 ballistic missile in 2023. (Photo Credit:
Tasnim News Agency)

[25]U.N. Arms Embargo, Other Sanctions Reimposed on Iran Over Nuclear
Program | Reuters

September 28, 2025: The United Nations reinstated sanctions on Iran at
midnight GMT on September 28. France, Germany, and the United Kingdom had
initiated the return of sanctions in August and failed to reach an
agreement with Iran in the meantime to delay it. The restored sanctions
include an arms embargo, a ban on uranium enrichment and reprocessing, a
ban on activity related to ballistic missiles capable of delivering nuclear
weapons, asset freezes and travel bans on Iranian individuals and
companies, and trade restrictions on items with nuclear or missile
applications. U.N. member states are also authorized to seize and dispose
of goods prohibited from being shipped to Iran. Iran threatened a response
to the reimposition of sanctions, and Russia claimed that the renewed
sanctions were illegitimate.

[26]Iran Has Likely Carried Out an Undeclared Missile Test, Satellite
Photos Analyzed By the AP Show | Associated Press

September 25, 2025: Iran likely carried out an undeclared missile test at
its Imam Khomeini Spaceport in Semnan Province on September 18, according
to satellite imagery and Iranian social media videos analyzed by the
Associated Press. An Iranian member of parliament claimed that the country
had tested an "intercontinental-range" missile. Iran has previously used
the same location to launch space-launch vehicles (SLVs) which share
certain characteristics with intercontinental ballistic missiles (ICBMs).

[27]Fearing Another War with Israel, Iran Begins Rebuilding Missile Sites,
but Key Component Is Missing | Associated Press

September 24, 2025: Iran is rebuilding missile production sites damaged by
Israel in June, according to satellite imagery analyzed by the Associated
Press. The imagery indicates construction at bases for manufacturing
solid-fueled missiles located near Parchin and Shahroud. Iran does not
appear to have acquired replacements for planetary mixers that were
destroyed by Israel in an earlier strike in October 2024. The mixers are
large pieces of equipment needed to produce solid missile fuel. They can be
purchased from Chinese firms, but the Chinese government did not indicate
whether or not it would supply replacement mixers or missile fuel
ingredients to Iran.

FROM THE LIBRARY

United Nations sanctions contained in Security Council resolutions [28]1696
(2006), [29]1737 (2006), [30]1803 (2008), and [31]1929 (2010) went back
into effect over the weekend.
* The U.N. Security Council reissued its [32]1737 Sanctions List of
individuals and companies subject to a United Nations asset freeze –
September 28
* The European Union [33]swiftly issued the necessary regulations for its
member states to implement the renewed sanctions – September 28
* France, Germany, and the United Kingdom (the E3) [34]said that Iran’s
failure to take meaningful action to restore monitoring of its nuclear
program led to snapback going into effect, but did not rule out further
diplomacy – September 28
* Iran [35]rejected snapback and threatened a response against countries
that implement the reimposed sanctions – September 28
* Russia [36]disputed the legitimacy of snapback and [37]described it as
a “trap” set for Iran – September 27 and 28
* The United States [38]welcomed snapback taking effect and said
diplomacy remained an option – September 27

The IAEA held its quarterly Board of Governors meeting in early September.
* The Agency’s [39]verification and monitoring report contained estimates
of Iran’s stockpile of enriched uranium on the eve of the Israeli strikes
– September 3
* The [40]NPT safeguards report chronicles the IAEA’s efforts to obtain
the Iranian government’s consent to resume monitoring activities in the
country – September 3
* The IAEA Director General gave a [41]statement describing an initial
understanding reached between the Agency and Iran during negotiations in
Cairo – September 10

The United States continued its maximum pressure campaign of sanctions and
enforcement actions against Iran.
* The Treasury Department [42]sanctioned a shipping network for smuggling
Iranian oil disguised as Iraqi oil – September 2
* The Department of Justice filed a [43]civil forfeiture action to
recover over $500,000 in cryptocurrency held by indicted IRGC drone program
supplier Mohammad Abedini – September 11
* The United States sanctioned entities receiving Iranian support in
[44]Yemen and [45]Sudan – September 11 and 12
* The Treasury [46]targeted a “shadow banking” network in Hong Kong and
the United Arab Emirates for facilitating financial transactions for
Iran’s military – September 16
* The State Department [47]designated four Iraqi militia groups aligned
with Iran as Foreign Terrorist Organizations (FTOs) – September 17

Iran Watch is a website published by the Wisconsin Project on Nuclear Arms
Control. The Wisconsin Project is a non-profit, non-partisan organization
that conducts research, advocacy, and public education aimed at inhibiting
strategic trade from contributing to the proliferation of weapons of mass
destruction.

Copyright © 2025 - Wisconsin Project on Nuclear Arms Control

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