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

With negotiations to restore the Joint Comprehensive Plan of Action (JCPOA) stalled and more of its restrictions set to expire, Western parties to the deal will likely face calls in 2023 to trigger the “snapback” mechanism of U.N. Security Council resolution 2231, which underpins the accord. This policy brief examines the direct and indirect consequences of taking such action.

Though it would not halt Iran’s nuclear advances, triggering snapback would allow Europe and the United States to make use of the expanded restrictions provided for in previous Security Council resolutions to combat the other pressing proliferation challenges posed by Iran, such as its transfers of drones and other arms to Russia and across the Middle East. Snapback would also align Europe’s Iran sanctions policy with that of the United States and provide a sanctions benchmark for other countries. At minimum, Britain, France, and Germany should not allow additional European nonproliferation sanctions on Iran to sunset on schedule in October and should instead reimpose other sanctions that the JCPOA had suspended.

ENTITIES OF CONCERN

In December 2021, the U.S. Commerce Department added to its Entity List a far-flung network of companies that have supplied Iran with U.S.-origin items in support of its military industries.

Shenzhen Rion Technology

A computer, communications, and electronics manufacturer based in China; sells navigation systems and related products, including inertial navigation systems and GPS navigation systems; part of RION Group, which has overseas offices in Germany, South Korea, and the United Kingdom._

Thundsea Electric Limited

An electronic instrument manufacturer based in Hong Kong; serves the oil and gas and mining industries; is developing a surveying machine based on fiber optic gyroscopes and systems for thermal imaging and video surveillance.

ROV Solutions

A subsea engineering consultancy based in the Republic of Georgia and Hong Kong; provides upgrades to remotely operated underwater vehicles; shares an address with Thundsea Electric Limited.

IN THE NEWS

Israel Launched Drone Attack on Iranian Facility, Officials Say | New York Times

January 29, 2023: Israel carried out a strike against an Iranian military facility in Isfahan using several small quadcopter drones, according to U.S. officials. The facility's exact purpose was not clear, although Iran said that it was an ammunition manufacturing plant. Iran also claimed that the attack caused little damage.

Iran’s Amassed Enough Material for ‘Several Nuclear Weapons,’ Says IAEA Chief | CNN

January 25, 2023: Rafael Grossi, head of the International Atomic Energy Agency, said that Iran has amassed 70 kilograms of uranium enriched to 60 percent fissile purity and 1,000 kilograms enriched to 20 percent, enough for “several nuclear weapons.” Grossi plans to travel to Iran in February.

EU Parliament Calls for More Sanctions Against Iranian Regime | Reuters

January 19, 2023: The European Parliament adopted a nonbinding resolution calling for EU sanctions against all Iranian entities linked to human rights violations, including Supreme Leader Ali Khamenei and President Ebrahim Raisi. Earlier, the parliament passed a similar resolution calling for the designation of the IRGC as a terrorist organization.

Iranian Oil Exports End 2022 at a High, Despite No Nuclear Deal | Reuters

January 15, 2023: Iran's oil exports in averaged 1.137 million barrels per day in December, the highest figure for 2022, according to SVB International, a company that tracks Iran's oil trade. By some estimates, Iranian crude exports have reached their highest level since April 2019. China remains Iran's biggest customer.

FROM THE LIBRARY

In December and January, Western governments announced more sanctions against Iranian entities for violently suppressing protests.

• The United States sanctioned Iran’s prosecutor general and a company that manufactures equipment for Iran’s Law Enforcement Forces - December 21.
• Canada announced sanctions on Iran Newspaper and the Press Supervisory Board, both linked to Iran’s state media - January 6.
• On January 23, the European Union, the United States, and the United Kingdom introduced sanctions against individuals and institutions connected to the IRGC and the Basij - January 23.

The U.S. Treasury Department adopted more sanctions targeting Iran’s drone industry.

• The designations included six executives and board members of Qods Aviation Industries, a defense manufacturer responsible for the design and production of the Mohajer-6 drone - January 6.
• They also included Nader Khoon Siavash, the director of Iran’s Aerospace Industries Organization - January 6.

The U.S. government took action to enforce U.S. and international law.

• Behrouz Mokhtari, a naturalized U.S. citizen, pleaded guilty to two conspiracies to violate sanctions imposed by the United States on Iran, including by attempting to facilitate Iranian petrochemical sales - January 9.
• The U.S. Navy intercepted a dhow in the Gulf of Oman that it says came from Iran and that was carrying more than 2,000 AK-47 assault rifles - January 10.

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. 

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