JCPOA Crisis: Balance of Power Returns

On September 26, 2025, the UN Security Council rejected a proposed resolution on extending the Joint Comprehensive Plan of Action (JCPOA) on the Iranian nuclear programme. Among the permanent members of the UN Security Council, the United States, Great Britain, and France voted against. China and Russia voted in favour. The vote a week earlier had the same result.  The JCPOA, enshrined in UN Security Council Resolution 2231 in 2015 proposed the lifting of international and unilateral sanctions against Iran in exchange for the cessation of its military nuclear programme. A vote against the draft resolution extending the JCPOA effectively triggers the UN Security Council's snapback mechanism. Such a development is unlikely to strengthen international security. Iran has additional incentives to emulate North Korea and become a de facto nuclear power.

This raises the question: if the United States can unilaterally exert economic pressure on Iran and, together with its allies, carry out air strikes against the country, why resort to Snapback and reinstate international sanctions through the UN Security Council? The answer is to further legitimise unilateral sanctions, augmenting them with international sanctions. The United States pursued a similar policy in the 2000s and early 2010s, achieving the internationalisation of its restrictive measures. Back then, this move helped the Americans bolster their threats of secondary sanctions against buyers of Iranian oil. Although the UN Security Council never imposed such restrictions, the very existence of international sanctions gave the United States greater confidence in implementing its unilateral restrictive measures.

Will reinstating international sanctions against Iran be effective in resolving the nuclear issue? The answer is no. Quite the contrary. Iran may be pursuing more vigorous efforts in developing nuclear weaponry and missiles. It's quite possible that the US and Israeli strikes on Iran have seriously damaged the material base that could be used in its nuclear programme. Precise information here is also lacking. However, Iran is a large country, and with the political will, its intellectual, scientific, and industrial resources could be sufficient to acquire nuclear weapons in the future.

In pursuing this course, Tehran may well look to the experience of the DPRK. Pyongyang found itself under the harshest UN Security Council sanctions, compounded by unilateral measures introduced by the US and other Western countries. However, even with extremely limited material resources, Pyongyang managed to achieve its goals. Both the failure of international efforts to resolve the DPRK nuclear issue and the JCPOA crisis are signs that the successes of multilateral diplomacy have been temporary. The balance of power has once again become entrenched in international politics as a key instrument for ensuring national security. Nuclear weapons will inevitably be seen as a crucial element of this balance.

On September 26, 2025, the UN Security Council rejected a proposed resolution on extending the Joint Comprehensive Plan of Action (JCPOA) on the Iranian nuclear programme. Among the permanent members of the UN Security Council, the United States, Great Britain, and France voted against. China and Russia voted in favour. The vote a week earlier had the same result.  The JCPOA, enshrined in UN Security Council Resolution 2231 in 2015 proposed the lifting of international and unilateral sanctions against Iran in exchange for the cessation of its military nuclear programme. A vote against the draft resolution extending the JCPOA effectively triggers the UN Security Council's snapback mechanism. Such a development is unlikely to strengthen international security. Iran has additional incentives to emulate North Korea and become a de facto nuclear power.

The JCPOA agreement in 2015, enshrined in UN Security Council Resolution 2231, was a major achievement of multilateral diplomacy. The Iran nuclear deal demonstrated that a major international security issue could be resolved through negotiations, and that the UN retains its influence and authority, as does the International Atomic Energy Agency (IAEA), which operates within the UN system. Iran managed to find compromises with the P5+1 negotiators, which included Russia, the United States, China, the United Kingdom, and France. Moreover, an agreement was reached even amid growing tensions in relations between Russia and Western countries. Moscow did not abuse its influence in the UN Security Council by trading support for the JCPOA for Western concessions on other security issues. The lifting of UN Security Council sanctions, as well as a significant portion of unilateral US and EU restrictions, opened the door to normal economic development for Iran. Previously, the Islamic Republic had been under increasing pressure from UN Security Council sanctions, while US sanctions had been applied against Tehran since 1979. The JCPOA was a true breakthrough for its time.

However, the nuclear deal encountered a crisis just three years later, in 2018. After winning the US election, President Donald Trump expressed scepticism about the deal. Under US law, he had every means to terminate its terms and, at the very least, reinstate unilateral US sanctions. His predecessor, Barack Obama, used so-called "executive commitments" to participate in the deal. He used his authority to suspend US federal laws sanctioning Iran. However, his constitutional authority was insufficient to repeal them. Furthermore, US participation in the deal was not approved by the US Senate, meaning it did not have the force of an international treaty.

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This legal configuration within the United States allowed Donald Trump to invoke the Iran Nuclear Agreement Review Act (INARA) and abandon the JCPOA in 2018. The reimposition of US sanctions and their further escalation was preceded by an ultimatum, known as the “12 Points”, voiced by US Secretary of State Mike Pompeo. US concerns included Iran's missile programme, support for political movements hostile to US allies in the Middle East, and other issues. There is no doubt that Iran actively promoted its interests outside the JCPOA while remaining an adversary of the United States. Tehran's foreign policy, like the security policy of any other country, cannot be idealised. However, resolving these differences could have been the subject of separate negotiations, both bilaterally and multilaterally. The achievements of the JCPOA could have been preserved while other disagreements were consistently resolved, to the greatest possible extent. However, the United States lumped these issues together with the nuclear issue, refusing to implement the JCPOA unless Tehran made further concessions not stipulated by the deal. Predictably, Iran rejected Washington's terms. Moreover, Trump's initial actions drew criticism even from US allies among the permanent members of the UN Security Council.

Washington’s unilateral actions significantly undermined the JCPOA. The problem was that American sanctions, given US leadership in the global financial system, could not be ignored by businesses in other countries. The Americans interpreted their jurisdiction broadly and, for example, viewed US dollar transactions with Iran as grounds for the administrative and even criminal prosecution of foreign financial institutions and companies. A number of banks in EU countries had paid substantial fines for transactions with Iran even before the JCPOA was signed, so new US sanctions negatively impacted Iran's economic relations with third countries. The EU's attempts to modernise its tools to protect its businesses from secondary sanctions and coercive US measures did not fundamentally change the situation. The EU-initiated Financial Instrument in Support of Trade Exchanges (INSTEX), an independent financial messaging mechanism for humanitarian transactions with Iran, failed.

The return of a Democratic president to the White House in 2021 did not fundamentally change the situation. Timid attempts to return to negotiations proved fruitless. The Biden administration avoided a new escalation of sanctions, but did not lift Donald Trump's restrictions or relaunch US participation in the JCPOA. The nuclear deal, therefore, largely lost its purpose, as unilateral US sanctions were sufficient to once again hit Iran's economy, distorting the country's normal market relations with the outside world.

Little is known about the actual state of Iran's nuclear programme. It's possible that, amid the erosion of the JCPOA, periodic threats of air strikes from the US and its allies, and assassinations of Iranian officials and security forces, Tehran was moving toward restarting nuclear development for military purposes. Or perhaps it was already pursuing such development, believing that the country would have no other security guarantees. At the very least, suspicions of such developments were exploited by Israel and the United States for large-scale military strikes against Iran in June 2025. The use of force was evidence that the results of the multilateral diplomacy of 2015 had been completely buried.

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This raises the question: if the United States can unilaterally exert economic pressure on Iran and, together with its allies, carry out air strikes against the country, why resort to Snapback and reinstate international sanctions through the UN Security Council? The answer is to further legitimise unilateral sanctions, augmenting them with international sanctions. The United States pursued a similar policy in the 2000s and early 2010s, achieving the internationalisation of its restrictive measures. Back then, this move helped the Americans bolster their threats of secondary sanctions against buyers of Iranian oil. Although the UN Security Council never imposed such restrictions, the very existence of international sanctions gave the United States greater confidence in implementing its unilateral restrictive measures.

Will reinstating international sanctions against Iran be effective in resolving the nuclear issue? The answer is no. Quite the contrary. Iran may be pursuing more vigorous efforts in developing nuclear weaponry and missiles. It's quite possible that the US and Israeli strikes on Iran have seriously damaged the material base that could be used in its nuclear programme. Precise information here is also lacking. However, Iran is a large country, and with the political will, its intellectual, scientific, and industrial resources could be sufficient to acquire nuclear weapons in the future.

In pursuing this course, Tehran may well look to the experience of the DPRK. Pyongyang found itself under the harshest UN Security Council sanctions, compounded by unilateral measures introduced by the US and other Western countries. However, even with extremely limited material resources, Pyongyang managed to achieve its goals. Both the failure of international efforts to resolve the DPRK nuclear issue and the JCPOA crisis are signs that the successes of multilateral diplomacy have been temporary. The balance of power has once again become entrenched in international politics as a key instrument for ensuring national security. Nuclear weapons will inevitably be seen as a crucial element of this balance.

First published in the Valdai Discussion Club.