NEW YORK CITY: When the US and Iran signed a memorandum of understanding on June 14, ending more than three months of war and opening a 60-day negotiating window, the announcement was greeted with international relief.
But many questions remain unanswered, central among them whether the economic relief Tehran is demanding can actually be delivered, and if so, through which legal channels.
The answer, experts say, is complicated and its path runs directly through a deeply divided UN Security Council.
The US and Iran have agreed to an “immediate and permanent” end to military operations on all fronts, including Lebanon, and an official signing ceremony for the deal has been scheduled for June 19 in Switzerland.
Among the provisions of the deal, Iran commits to a moratorium on the enrichment of nuclear material and the US agrees to lift sanctions and release billions of dollars of frozen Iranian funds; though many of the terms remain contingent on a final agreement being reached.
Iranian state media has published what it described as a “14-point draft.” According to this account of the deal, the draft provides for the release of $24 billion in frozen Iranian assets during the 60-day negotiating period — though neither Iranian nor US officials have publicly confirmed its contents.
What both sides appear to agree on is that the negotiations on a final accord must conclude within 60 days, a time frame that can be extended by mutual consent.
Iran’s deputy foreign minister said that Tehran’s top priority during those talks will be the termination of all UN and International Atomic Energy Agency resolutions against it. This demand runs headlong into one of the most hotly contested legal disputes within the Security Council in recent years: snapback sanctions.
The snapback mechanism was written into UN Security Council Resolution 2231, which endorsed the 2015 Iran nuclear deal, more formally known as the Joint Comprehensive Plan of Action.
The JCPOA provided Iran with sanctions relief, while Resolution 2231 allowed any participant to trigger the reimposition of six previous sanctions resolutions simply by notifying the council of significant noncompliance with the terms of the deal — a process that once started could not be stopped by a veto.
France, Germany and the UK, known collectively as the “E3,” triggered the snapback mechanism on Aug. 28, 2025. The council failed to adopt any resolutions that would have preserved the sanctions relief, and UN sanctions on Iran were automatically reimposed on Sept. 27. Those sanctions cover Iran’s nuclear and missile programs, asset freezes, travel bans, and restrictions on the access of Iranian banks to the global financial system. The US-Iran peace agreement does not affect any of that.
“Only the Security Council can agree to undo the sanctions that were reimposed by the snapback mechanism last August,” Daniel Forti, a senior analyst who covers the Iran nuclear file for nongovernmental organization the International Crisis Group, told Arab News.
“While the (US-Iran) MoU suggests a potential pathway where there may be more political interest from the US to eventually consider removing those sanctions, it will take the entirety of the Security Council to ultimately sign off on those sanctions-relief efforts.”
Such unanimity among council members is nowhere close to guaranteed. China and Russia contested the legal and procedural right of the E3 to trigger the snapback, arguing that all previous sanctions were permanently lifted on Oct. 18, 2025, when the JCPOA and Resolution 2231 were originally set to expire.
In a letter to the Security Council in October 2025, Iran, China and Russia argued that the E3 lacked the standing to invoke the snapback mechanism because the three governments had “ceased to perform” their own JCPOA commitments. However, the US, France and the UK insisted the mechanism was properly triggered and the sanctions had therefore been reinstated.
The result is a deep fracture within the council that has left the practical enforcement of the sanctions uneven.
Forti explained the situation plainly: “The snapback sanctions cover four distinct sanctions regimes set out in four different resolutions, targeting everything from Iran’s nuclear and missile production to asset freezes, travel bans, and financial connections of Iranian banks to the global system.
“Although Russia, China and some other states may continue to trade with Iran while not observing these sanctions, a number of other states do — so it imposes a major economic cost on Iran regardless.”
This uneven enforcement has real consequences. European states in particular have hardened their positions on Iran following the nuclear standoff and the provision of arms to Russia by Tehran. The prospect of Beijing and Moscow simply ignoring the reimposed sanctions while Western states enforce them creates a fractured global trade reality: neither full sanctions nor full relief.
The Crisis Group, in its assessment of this weekend’s US-Iran agreement, noted that “what degree of economic relief Iran will receive in return” for nuclear concessions remains one of the central unresolved questions of the 60-day talks.
Past statements by US President Donald Trump, the group noted, have included the possibility of loosening the primary US embargo and establishing a significant recovery fund for Iran, which “could give Iran an incentive to agree to substantial nuclear concessions.”
But there is a critical distinction to be made here: bilateral US sanctions, those imposed directly by Washington, can be eased or lifted through American executive action alone. Multilateral UN sanctions cannot.
Forti made this distinction clear: “The US does have policy influence to make changes in its national capacity, whereas making changes to the four sanctions regimes under the UN requires going through a much more arduous multilateral route.”
The Iranian Foreign Ministry has announced it will demand a new Security Council resolution to ratify any final agreement, citing lessons learned from the collapse of the 2015 deal. Forti described this as sound strategy for everyone involved.
“It’s in every state’s interest to have a final deal ratified by the Security Council,” he said. “It creates international legitimacy for the political underpinnings of the agreement, gives legal backing to specific provisions, and creates an opening for an impartial organization like the UN to assist with technical implementation.”
A ratifying Security Council resolution could also explicitly lift the reimposed snapback sanctions, but only if all five permanent members agree, or at a minimum decline to use their power of veto.
Given the current alignment within the council, that remains the hardest diplomatic lift of all. As Forti put it, any path to meaningful economic relief for Iran runs not through Washington alone but through the UN headquarters in New York.
