 | 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. Was this email forwarded to you? Sign up to receive the newsletter in your inbox, or view the newsletter in your browser. |
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| The U.N. Security Council meets to discuss threats to international peace and security. (Photo Credit: United Nations/Manuel Elias) |
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| 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. |
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| 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. |
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| Even before it expired in 2023, the United Nations’ 2231 List of targeted sanctions on Iranian entities was woefully out of date, containing deceased individuals and defunct or renamed companies.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 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. |
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| 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 can be found on Iran Watch. |
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| Iran tests a Khorramshahr-4 ballistic missile in 2023. (Photo Credit: Tasnim News Agency) |
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| 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. |
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| 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). |
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| 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. |
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| United Nations sanctions contained in Security Council resolutions 1696 (2006), 1737 (2006), 1803 (2008), and 1929 (2010) went back into effect over the weekend. - The U.N. Security Council reissued its 1737 Sanctions List of individuals and companies subject to a United Nations asset freeze – September 28
- The European Union swiftly issued the necessary regulations for its member states to implement the renewed sanctions – September 28
- France, Germany, and the United Kingdom (the E3) 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 rejected snapback and threatened a response against countries that implement the reimposed sanctions – September 28
- Russia disputed the legitimacy of snapback and described it as a “trap” set for Iran – September 27 and 28
- The United States 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 verification and monitoring report contained estimates of Iran’s stockpile of enriched uranium on the eve of the Israeli strikes – September 3
- The 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 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 sanctioned a shipping network for smuggling Iranian oil disguised as Iraqi oil – September 2
- The Department of Justice filed a 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 Yemen and Sudan – September 11 and 12
- The Treasury 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 designated four Iraqi militia groups aligned with Iran as Foreign Terrorist Organizations (FTOs) – September 17
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| 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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