JCPoA: From consensus to breakdown

The JCPoA, endorsed in 2015, set strict limits on Iran’s nuclear activities in exchange for sanctions relief. Key commitments included sharply reducing enriched uranium stockpiles, capping enrichment levels and enabling robust IAEA inspections. The agreement began to unravel after the United States’ withdrawal in May 2018, leading Iran to systematically breach its obligations from 2019 onwards.

Iran’s non-compliance

The E3 have determined that Iran now holds uranium stockpiles beyond permitted levels, deploys advanced centrifuges and blocks IAEA inspectors from key sites. Further, the abandonment of the Additional Protocol by Iran has eroded transparency, raising proliferation concerns regarding Iran’s nuclear intentions.

E3’s diplomatic efforts and legal framework

The E3 have spent over five years on diplomatic efforts including formal dispute resolution, sustained negotiations and multiple proposals—all ultimately rejected by Iran. With the snapback mechanism, any JCPoA participant can notify the Security Council of significant non-performance, triggering a 30-day countdown. If no new resolution is adopted, previously lifted UN sanctions and restrictions automatically reapply.

Implications of snapback

This process places immediate pressure on Iran to return to compliance or face renewed comprehensive sanctions, arms embargoes, and other restrictive measures.

The path ahead

The E3 signal remains open to diplomatic solutions, but the 30-day window could represent the final chance for constructive engagement. Iran’s response will determine whether international engagement continues under the JCPoA framework or transitions to comprehensive sanctions enforcement.

Under the JCPoA, Iran remains subject to a lighter touch sanctions regime under the UK and EU sanctions programmes as relevant to its nuclear programme. A comprehensive and distinct regime is in place related to human rights abuses. Following snapback, significant and wide-ranging sanctions will be reinstated on Iran related to its nuclear programme in both the UK (and UK associated jurisdictions) and the EU. These will be directly relevant to all jurisdictions at Harneys.

Entities with exposure to Iran should immediately seek appropriate legal advice as regards next steps regarding sanctions compliance post-snapback.

UK’s press release can be found here, France’s news release here and Germany’s here