This Advisory Note is produced by the Australian Sanctions Office (ASO) to inform the regulated community of a developing issue presenting significant sanctions risk. It provides a summary of relevant sanctions laws but does not cover all possible sanctions risks. Users should consider all applicable sanctions measures and seek independent legal advice. This document should not be used as a substitute for legal advice. Users are responsible for ensuring compliance with Australian sanctions laws.

The snapback mechanism

In 2015, the United Nations Security Council (UNSC) adopted UNSC Resolution 2231 endorsing the Joint Comprehensive Plan of Action (JCPOA). This allowed the UNSC to have oversight of Iran's nuclear activities in return for sanctions relief as long as certain conditions (such as access for the International Atomic Energy Agency) were met. The resolution also contained a mechanism through which the suspended sanctions against Iran could be 'snapped back' into effect if Iran failed to comply with its obligations under JCPOA.

On 28 August 2025, France, Germany and the UK triggered the 'snapback' of international sanctions on the basis that Iran had not complied with the JCPOA by exceeding the maximum allowed uranium stockpile; undertaking prohibited enrichment activities; and obstructing international verification and monitoring.

On 28 September 2025, the UNSC sanctions that were eased under the JCPOA were automatically reimposed by the UNSC. The measures include a full arms embargo on Iran; export bans on nuclear and ballistic missile related goods; a prohibition on providing services related to the export of nuclear and ballistic missile related goods; and asset freezes on individuals and entities.

Australia implements UNSC sanctions through Australian domestic laws, including the Charter of the United Nations Act 1945 and its regulations. These prohibitions were reimposed under Australian domestic law from 12 December 2025.

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