The United States and European countries, including Britain, are at loggerheads over efforts by the Trump administration to reimpose all sanctions on Iran lifted after the 2015 nuclear deal. The so-called “snapback” clause in the Joint Comprehensive Plan of Action was triggered when the UN Security Council voted last month not to extend the arms embargo on Iran which is set to expire in October.
The US argues that all sanctions underpinned by UN Security Council resolutions that were in place before the JCPOA, as well as arms bans, restrictions on Iran’s ballistic missile activity and its nuclear enrichment, should now be reimposed. It also says that all UN member states are obliged to implement sanctions and warns it is “prepared to use [its] domestic authorities to impose consequences for those failures and ensure that Iran does not reap the benefits of UN-prohibited activity”.

However, the UK, France and Germany – the “E3” – said that the US forfeited its right to snapback UN sanctions when it withdrew from the nuclear accord in 2018. Together with China and Russia, the E3 have attempted to salvage the JCPOA, despite Iran’s repeated breaches of the agreement. Since 2018, the US’ “maximum pressure” campaign has seen the Trump administration impose its own sweeping sanctions on Tehran. But without action by the E3, the embargo on conventional arms sales to Iran – which remained in place even after the JCPOA came into effect – will automatically expire on 18 October.
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