August 14, 2017 | Memo

Iran’s Compliance with UNSCR 2231: Alleged Violations Must Be Addressed

FDD Research Memo

Co-written by Valerie Lincy. [1]

Download the full memo here.

Executive Summary

UN Security Council Resolution (UNSCR) 2231 implements the 2015 nuclear agreement with Iran and imposes missile- and arms-related restrictions. Little-noticed biannual reporting by the UN Secretary General alleges that Iran is repeatedly violating these non-nuclear provisions. Thus far, the United States has responded to such violations with sanctions and designations of Iranian and foreign entities supporting Tehran’s ballistic missile development. However, the UN and its member states have not responded. More must be done to investigate allegations of noncompliance and to punish violations of the resolution.

The Challenge of Responding to Alleged Violations of UNSCR 2231

On July 27, Iran tested its Simorgh satellite launch vehicle from a newly inaugurated space center.[2] In response, the United States, France, Germany, and the United Kingdom addressed a letter to the UN Security Council calling the test “a threatening and provocative step” and “inconsistent” with UNSCR 2231, which codifies the Joint Comprehensive Plan of Action (JCPOA) nuclear deal.[3] The countries expressed alarm over Iran’s satellite launch vehicle test because it could help extend the range of Tehran’s nuclear-capable ballistic missiles.

The Simorgh test is only the latest example of Tehran’s defiance of ballistic missile restrictions set forth in Annex B of UNSCR 2231. According to a June 20 report by the UN Secretary General,[4] Iran may have violated the prescribed limitations on arms imports and exports and ballistic missile testing, as well as entity-specific prohibitions on multiple occasions.

The United States has responded to the recent test and to ballistic missile launches with targeted sanctions, most recently on July 28,[5] as well as with a sweeping new sanctions bill that the president signed into law on August 2.[6] Other countries have limited their response to strong statements, however. The Secretary General concludes that a lack of consensus among Security Council members or a lack of information prevents a punitive response. If left unchecked, this will undermine both the resolution and the nuclear agreement.

[1] Valerie Lincy is the executive director of the Wisconsin Project on Nuclear Arms Control. Behnam Ben Taleblu is a senior Iran analyst at the Foundation for Defense of Democracies. The authors wish to thank Meghan Peri Crimmins, Mark Dubowitz, Jonathan Schanzer, and Nicole Salter for their feedback and edits.

[2] “Iran Opens New Space Center with Launch of Satellite Carrier,” Tasnim News Agency (Iran), July 27, 2017. (

[3] Edith M. Lederer, “US and allies call Iran’s recent rocket launch ‘threatening,’” Associated Press, August 2, 2017. (

[4] United Nations Security Council, “Third report of the Secretary-General on the implementation of Security Council resolution 2231 (2015),” June 20, 2017. (

[5] U.S. Department of the Treasury, Press Release, “Treasury Sanctions Key Ballistic Missile Entities in Iran,” July 28, 2017. (

[6] Countering America’s Adversaries Through Sanctions Act, Pub. L. 115-44, H.R. 3364, codified as amended at 115 U.S.C. (