by Vasily Nebenzya 

 I have to refer to the note verbale from the Secretariat of the United Nations DPPA/SCAD/SCA/4/25(1) [1], as well as the notification from the Department of Political and Peacebuilding Affairs to the Security Council, both dated 28 September 2025, regarding the so-called “re-application of resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008) and 1929 (2010)” of the Security Council concerning the Islamic Republic of Iran.

I would also like to draw your attention to the vote on the Security Council draft resolution submitted by the Republic of Korea on extending the regime of termination of the United Nations sanctions against Iran that took place on 19 September 2025, as well as to the vote on 26 September 2025 on the draft presented by China and Russia aimed at the extension of the Security Council resolution 2231 (2015).

During the above-mentioned meetings of the Security Council, the United States, the United Kingdom and France, supported by a number of non-permanent members of the Council, voted against both drafts, thus expressing themselves against giving additional room for negotiations in the context of the Iranian nuclear issue. Regrettably, despite all the energetic diplomatic efforts of the last two weeks and Iran’s readiness to engage in finding a solution, the above-mentioned States rejected all the compromises and chose an escalatory path.

In parallel, the United Kingdom, France and Germany have continued to insist on the validity of their so-called “snapback” notification that was circulated in the Security Council on 28 August. The claims by E3 that the “snapback” mechanism was triggered do not withstand any scrutiny, as these States did not follow the procedures for dispute resolution established by the Joint Comprehensive Plan of Action (JCPOA), being an integral part of resolution 2231 (2015). Moreover, numerous violations of these documents committed by the United Kingdom, France and Germany deprived them of the right to use the instrument prescribed therein. Hence, their “notification” allegedly having triggered the “snapback” is legally null and void and it cannot be regarded as a notification submitted pursuant to operative paragraph 11 of Security Council resolution 2231 (2015), as indicated, inter alia, in the letter addressed to you by the Ministers for Foreign Affairs of Russia, China and Iran dated 28 August. Therefore, the draft resolution put to a vote on 19 September by the President of the Council undoubtedly did not meet the requirements of resolution 2231 (2015), and the outcome of its consideration cannot entail the restoration of the United Nations sanctions against Iran. For that reason, the claimed “snapback” procedure cannot be considered to be triggered.

The efforts of the Western States to maintain the opposite only demonstrate that they are desperately trying to legitimize their blatant violations of resolution 2231 (2015) committed previously, as well as to compel the rest of the world to side with their confrontational and fundamentally erroneous policy.

Since the Security Council did not adopt a resolution on the technical extension of Security Council resolution 2231 (2015), it will then cease to be in effect in accordance with the established timeline – which is the termination day of JCPOA, namely 18 October 2025. After that, any restrictions and rules provided for therein, including those relating to Iran’s nuclear programme, will cease to be relevant.

Therefore, the Secretariat has no grounds whatsoever for undertaking any steps aimed at “re-application” of a number of Council resolutions that were terminated in accordance with resolution 2231 (2015), nor for renewing the relevant mandates. Our country has already warned the Secretary-General accordingly, inter alia, in the letter by the Minister of Foreign Affairs of the Russian Federation circulated in the Council on 27 September 2025 (see S/2025/601).

I regret to underline that the actions undertaken by the Secretariat, as indicated in its above-mentioned note verbale, lack any legal or procedural grounds and contradict the Charter of the United Nations, namely its Article 100, as well as consensual decisions of the Security Council, including its resolution 2231 (2015). The references to the process set forth in paragraphs 11 and 12 of this resolution are irrelevant and cannot serve as a basis for any steps by the Secretariat, as the procedures stipulated therein have never been invoked.

However, the Secretariat circulated on 28 September 2025 a notification on re establishment of the sanctions list maintained by the Security Council Committee established pursuant to resolution 1737 (2006) as well as reinstallation of the relevant website. This is a counterproductive and wrongful act that can seriously damage the authority of the Security Council.

We urge the Secretariat to withdraw its notification DPPA/SCAD/SCA/4/25(1), to cancel the re-establishment of the sanctions list maintained by the Security Council Committee established pursuant to resolution 1737 (2006), to terminate the relevant website for the Committee established pursuant to resolution 1737 (2006) with information concerning the sanctions regime, including the nature and scope of the sanctions measures, relevant resolutions and documents of the Council, and lists of designated individuals, groups and entities, and refrain from any further steps serving the position of a small group of States rather than following decisions of the Security Council.

There is no basis either for the re-establishment of the Committee established pursuant to resolution 1737 (2006) itself, so no step should be taken in this regard (no call for nomination of experts to the Panel nor appointment of the Chair).

I would be grateful if this communication could be circulated as a document of the Security Council.

Vasily Nebenzya

     

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[1] “General Secretariat reinstates sanctions against Iran”, UN (General Secretariat) , Voltaire Network, 27 September 2025.