The expiration of sanctions on Iran’s nuclear and ballistic missile programs poses a heightened threat to regional stability. Iran can now import and export missiles and missile technology and advance its nuclear ambitions, regional power projection, and export terrorism and subversion.
Furthermore, deepening strategic ties between Russia and Iran, especially in missile exchanges, could escalate tensions in the Middle East and conflict zones like Ukraine.
This, combined with Iran’s relentless harassment of American forces in the Persian Gulf and the aggressive actions of its Shiite proxies against U.S. troops in Iraq and Syria, often goes unnoticed. Such perceived oversight could embolden Tehran, and when the time seems right, it might unexpectedly target U.S. aircraft and bases or allies in the region.
Just as Hamas surprised Israel on October 7th
Iran’s Foreign Ministry has issued a “Statement on the Termination of Certain Provisions of the UNSCR 2231 18 October 2023,” saying the sanctions on its nuclear, ballistic, and arms programs set to expire on 18 October as per the 2015 JCPOA have now “terminated unconditionally” and “do not require any action” from the UN to take effect. Part of the statement reads :
As of today, 18 October 2023, the last part of unjustly imposed restrictions by the United Nations Security Council on missile-related activities and associated services and technology to/from the Islamic Republic of Iran, including an asset freeze and financial restrictions on specific Iranian individuals and entities, terminated unconditionally. According to the provisions of 2231 UNSCR, termination of these restrictions does not require any resolution, statement or any other action in the context of the UNSC and occurred automatically.
According to UNSCR 2231, effective 18 October 2023:
Iran is no longer restricted from activities related to ballistic missiles designed to deliver nuclear weapons. This confirms Iran’s stance that its ballistic missile program was always consistent with this provision.
The restrictions on transferring missile-related items, services, and technology to/from Iran have been lifted.
Any restrictions on activities and financial services related to specific Iranian individuals and entities on the 2231 list have ended. This includes bans on providing funds, financial assets, and economic resources by UN Member States to those listed.
Previously, by 18 October 2020, all limitations on arms-related transfers to/from Iran had ended. Also, restrictions regarding the entry or transit of specific Iranian nationals through UN Member States’ territories had ceased.
Iran emphasizes that all Member States should uphold the termination of these restrictions at their national levels. Any sanctions or limitations on Iran’s defense engagements contradict the termination of UNSCR 2231 restrictions and violate the resolution.
Iran reiterated that its defense doctrine is based on domestic capabilities, not unconventional arms or weapons of mass destruction. Iran’s military capabilities, including ballistic missiles, are strictly for self-defense. Any sanctions against Iran, primarily.” related to its nuclear program, are “viewed as baseless, unjust, and illegal by the Iranian government”.
EUE + UK reaction
EU nations and the UK have declared their intention to uphold sanctions against Iran beyond the transition day. A spokesperson for the E3 said:
“In direct response to Iran’s consistent and severe non-compliance with its JCPoA commitments since 2019, the governments of France, Germany, and the United Kingdom intend to maintain nuclear proliferation-related measures on Iran, as well as arms and missile embargoes, after JCPoA Transition Day on 18 October 2023. We have jointly notified the JCPoA Coordinator in that regard.
This decision is fully compliant with the JCPoA. It follows our attempts to resolve Iran’s non-compliance through the JCPoA’s Dispute Resolution Mechanism, which we triggered in January 2020. Iran has refused opportunities to return to the JCPoA twice and has continued to expand its program beyond JCPoA limitations and without any credible civilian justification. Its enriched uranium stockpile is more than 18 times the amount permitted under the JCPoA.
Our commitment to finding a diplomatic solution remains. This decision does not amount to imposing additional sanctions nor to triggering the snapback mechanism. We stand ready to reverse our decision should Iran fully implement its JCPoA commitments.”
The European Council has published a statement that it has chosen to maintain restrictive measures against Iran under the EU’s non-proliferation regime. Despite the initial plan to lift these restrictions on Transition Day (18 October 2023) as part of the Joint Comprehensive Plan of Action (JCPoA), the Council decided otherwise due to Iran’s reported non-compliance with the JCPoA commitments, as noted by the International Atomic Energy Agency since 2019. The measures in place include designations initially imposed by the UN on individuals and entities linked to nuclear or ballistic missile activities or the Islamic Revolutionary Guard Corps (IRGC).
Additionally, sectoral and individual measures will remain under the EU’s sanctions regime, specifically related to Iran’s nuclear proliferation, arms, and missile embargoes. This decision doesn’t introduce any new EU sanctions on Iran, and any EU sanctions previously lifted under the JCPoA will continue to be lifted. This action is consistent with the EU’s dedication to fully implementing the JCPoA. It follows a letter received in September 2023 from the Foreign Ministers of France, Germany, and the UK, signaling their willingness to reverse this decision if Iran meets its JCPoA obligations.
Iran’s reaction to EU3 statement
Iran’s Foreign Ministry spokesman has criticized the EU for deciding to maintain restrictive measures against Tehran under the non-proliferation sanctions regime after a nuclear agreement transition day. Nasser Kanani described the act as “one-sided, unlawful, and politically indefensible.”
In criticizing the decision, the spokesperson labeled it “a blatant breach of the commitments” by the EU and the three European state signatories of the 2015 nuclear agreement and UN Security Council Resolution 2231, terming it as “malevolent behavior.” State-run media and conservative commentators have also chastised the E3 (“America’s pawns)” and cast doubt on the validity of their decision.
Russian reaction to expiration of arms sanctions
The Russian Foreign Ministry asserts that Moscow no longer needs UN approval for missile technology exchanges between Russia and Iran, as the constraints set by UN Security Council resolution 2231 will end on 18 October.
In a declaration on their website on 17 October, the ministry emphasized that Russia will “adhere closely to the directives” of the Russian presidential decree No 109 from 11 March 2016, titled “On implementing the UN Security Council resolution 2231 from 20 July 2015.”
The Russian ministry highlighted, “Transfers of products between Iran and Russia, which fall under the Missile Technology Control Regime, don’t require prior consensus in the UN Security Council anymore.”
It added that the list of ‘named’ individuals in the resolution’s annex is outdated. “European nations should acknowledge this reality and halt their unilateral constraints towards Tehran immediately,” the ministry urged.
The statement warned that failing to recognize this could risk the continuity of the Iran nuclear agreement, formally referred to as the Joint Comprehensive Plan of Action (JCPOA).
The ministry cautioned, “Choosing alternative paths could raise doubts about the JCPOA’s future and intensify the tension around Iran’s nuclear endeavors, potentially leading to severe repercussions in the already volatile Middle East.”
The Russian Foreign Ministry stressed that the US and the EU bear “the responsibility to initiate several concrete actions to terminate the inherently illicit unilateral sanctions against Iran permanently.”
The USA committed to counter Iran Despite the expiration.
On October 18, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 11 individuals, eight entities, and one vessel based in Iran, Hong Kong, the People’s Republic of China (PRC), and Venezuela that are enabling Iran’s destabilizing ballistic missile and unmanned aerial vehicle (UAV) programs. The persons designated today have materially supported Iran’s Islamic Revolutionary Guard Corps (IRGC), Ministry of Defense and Armed Forces Logistics (MODAFL), or their subordinates in the production and proliferation of missiles and UAVs.
Under Secretary of the Treasury for Terrorism and Financial Intelligence, Brian E. Nelson said the US will counter “Iran’s reckless choice to continue its proliferation of destructive UAVs and other weapons prolongs numerous conflicts in regions around the world…The United States will continue to take action to disrupt Iran’s proliferation of UAVs and other weapons to oppressive regimes and destabilizing actors, and we encourage the international community to do the same.”
Nelson reiterated that the action is taken as the UN’s restrictions on Iran’s missile-related activities under UN Security Council Resolution 2231 (UNSCR 2231) expire. The European Union acts to retain the nuclear, conventional arms, and missile-related restrictions on Iran set to expire today under its nonproliferation sanctions regime. Despite the expiration of UNSCR 2231, the United States remains steadfast in its commitment to counter the threat posed by Iran’s procurement, development, and proliferation of missiles, UAVs, and other military weapons.
The lifting of sanctions related to Iran’s ballistic missiles will allow Iran to enhance its missile capabilities, improving the range, precision, and types of warheads, which may include nuclear ones. This advancement threatens U.S. installations and assets in Israel and the Gulf States.
The termination of the arms embargo might enable Iran to acquire sophisticated weaponry and amplify its weapons supply to groups and nations within its sphere of influence, such as the so-called “Axis of Resistance” Syria, Hezbollah, Hamas, the PIJ, Shiite militias in Iraq and Syria and the Houthi rebels in Yemen. This could intensify unrest and terrorist activities across the Middle East.
Furthermore, Iran could provide Russia with short-to-medium-range ballistic missiles for use in the Ukrainian conflict. This could further cement the strategic partnership between Russia and Iran, demonstrated in the Iranian attack on drones and Russia’s use in its war in Ukraine.
The West’s perceived leniency towards Iran, despite its alleged involvement in supporting terrorism and arming groups like Hamas, Hezbollah, and the Houthis, contributes to regional tensions. Bolstered by such perceived international leniency, Iran will continue its regional power projection, thus prolonging escalation in the region.
While the West continues to show tolerance towards Iran, including its responsibility for exporting terrorism and arming Hamas, Hezbollah, and the Houthis over the years, Iran continues building up its asymmetric capabilities (drones, missile speedboats) and projecting power in the region.
Iran’s relentless harassment of American forces in the Persian Gulf, along with the attacks of its Shiite proxies against U.S. troops in Iraq and Syria, often goes unnoticed. This perceived leniency emboldened Iran, and when it believed the time was ripe, it could suddenly target U.S. aircraft and bases in the region, as well as Gulf states, including Saudi Arabia and Israel.
Just as Hamas surprised Israel on October 7th
Iran Dossier The expiration of sanctions on Iran’s nuclear and ballistic missile programs poses a heightened threat to regional stability. Iran can…