Dr. Shehab Al-Makahleh
The most consequential question emerging from the latest confrontation in the United Nations Security Council is no longer whether Iran should face additional sanctions, nor whether another round of international pressure can persuade Tehran to modify its nuclear policies. The more fundamental question is who, in an increasingly fragmented international system, has the authority to interpret the rules of that system and, more importantly, the political and institutional capacity to translate those interpretations into obligations that other states are expected to observe. The Russian and Chinese veto of the U.S.-backed effort to extend the mandate of the UN mechanism responsible for investigating and reporting on sanctions-related activity concerning Iran therefore deserves to be understood as something considerably larger than a procedural dispute over the continuation of an expert panel. It is another manifestation of a deeper struggle over the authority of the Security Council, the legitimacy of sanctions as an instrument of international governance, and the extent to which the institutions created after the Second World War can continue to function when the major powers no longer share a common understanding of the rules they are supposed to uphold.
At first glance, the mandate of an expert mechanism may appear technical and relatively insignificant compared with the broader strategic confrontation surrounding Iran’s nuclear program. Yet these mechanisms perform an important institutional function: they provide the evidence, reporting and verification upon which the implementation of Security Council decisions is supposed to rest. Their importance lies precisely in the fact that sanctions are not intended to operate merely as political declarations by powerful states. They are embedded in a system of monitoring, documentation and accountability designed to establish whether governments, companies and other actors are complying with internationally agreed restrictions. The weakening or disappearance of such mechanisms does not automatically invalidate sanctions previously adopted by the Council, but it can diminish the institutional infrastructure through which those measures acquire transparency and credibility. The dispute over extending the mandate is therefore not fundamentally about the number of experts involved or the duration of their assignment; it is about whether the Security Council retains the ability to sustain the machinery of collective enforcement when the permanent members themselves are divided over the legal and political foundations of the measures being monitored.
The controversy has become particularly significant because it intersects with the continuing dispute over the interpretation of Security Council Resolution 2231 and the so-called snapback mechanism associated with the 2015 nuclear agreement with Iran. In September 2025, Britain, France and Germany invoked the mechanism, arguing that Iran’s nuclear-related conduct had created the conditions for the reimposition of previously suspended UN sanctions. The European governments maintained that the relevant provisions of Resolution 2231 continued to provide a legal basis for the procedure, whereas Iran, Russia and China rejected that interpretation and argued that the mechanism could no longer be legitimately activated in the manner proposed. Moscow has maintained that the European notification was legally defective and could not produce the consequences claimed by the European powers. What might otherwise have remained a dispute among international lawyers has consequently become a test of the relationship between legal interpretation and political power within the Security Council, because there is no neutral authority capable of compelling the permanent members to accept a common interpretation when they fundamentally disagree about the meaning and continuing validity of a Security Council resolution.
This is where the Iranian case becomes particularly revealing. The underlying disagreement is not simply about whether Iran has complied with its nuclear obligations or whether sanctions are an appropriate response to its conduct. It concerns the more fundamental question of whether an international legal instrument can continue to generate binding consequences when the states that possess the greatest institutional authority within the Security Council disagree over its interpretation. The answer has traditionally depended on a combination of legal argument, diplomatic consensus and political power.
Increasingly, however, these three elements are moving in different directions. Western governments may advance one legal interpretation, Russia and China another, while each side possesses sufficient political and institutional leverage to prevent the other’s interpretation from becoming universally accepted. The result is a form of institutional ambiguity in which international law remains formally present but its practical authority becomes increasingly dependent on the geopolitical configuration surrounding each individual dispute.
Russia’s position is therefore better understood within the context of its broader confrontation with the Western sanctions system than simply as an expression of solidarity with Tehran. Moscow’s relationship with Iran has expanded across political, economic and security domains, but Russia’s strategic interest in the Iranian sanctions question extends beyond bilateral ties. Since Russia itself has become the target of an extensive Western sanctions regime, Moscow has a direct interest in resisting the normalization of sanctions as an increasingly permanent instrument of international statecraft. From the Kremlin’s perspective, the issue is partly whether Western governments can use multilateral institutions to transform measures that originate within a particular geopolitical coalition into obligations that acquire the authority of the international community as a whole.
Supporting Iran’s position in selected Security Council disputes can therefore advance a broader Russian objective: constraining the ability of the United States and its European partners to convert their preferred mechanisms of economic and political coercion into universally recognized instruments of international governance. This does not necessarily imply that Moscow has undertaken an unconditional commitment to protect Tehran regardless of its future conduct; rather, it reflects a convergence of interests in which Russia seeks to constrain Western institutional leverage while Iran seeks to preserve diplomatic and economic space.
China’s calculations are related but distinct. Beijing has developed an increasingly consequential economic and strategic relationship with Iran, including through energy, infrastructure and broader diplomatic engagement across the Middle East, but China’s opposition to particular sanctions mechanisms should not be reduced to a simple commitment to defend Tehran. Beijing is equally concerned with the precedent created when international institutions are used to formalize coercive policies without the agreement of all major powers.
China has spent considerable effort presenting itself as an advocate of state sovereignty, non-interference and a more representative international order, and it has an obvious interest in ensuring that the Security Council remains a negotiated institution rather than becoming a mechanism through which Western powers can internationalize policies that Beijing does not accept. The Iranian question consequently offers China an opportunity to reinforce a broader principle that will matter well beyond the Middle East: that the interpretation and implementation of international rules cannot be monopolized by a single geopolitical bloc.
For Iran, the Russian and Chinese positions provide important diplomatic and strategic breathing room, but Tehran should not be mistaken for the architect of the wider confrontation. Iran benefits from the divisions among the permanent members because those divisions reduce the probability that Western governments can translate their preferred policies into a unified UN response.
Yet the underlying dynamic is larger than Iran itself. Tehran is increasingly situated within a network of relationships involving Russia, China and a range of non-Western states that do not necessarily share identical interests but increasingly resist the concentration of international rule-making within Western institutions. The danger for policymakers in Washington and European capitals is therefore not simply that Russia and China will shield Iran from sanctions; it is that the Iranian file may become another precedent through which alternative approaches to international governance are gradually normalized.
The United States, meanwhile, faces a paradox of its own. Washington retains enormous capacity to impose sanctions independently of the Security Council, and the reach of the U.S. financial system, the centrality of the dollar, American secondary sanctions and the global exposure of banks and corporations to the U.S. market give Washington instruments of coercion that remain highly consequential even when multilateral diplomacy fails. The United States can therefore continue targeting Iranian institutions, companies, financial networks and foreign actors accused of assisting sanctions evasion without requiring authorization from the Security Council.
Unilateral capacity and multilateral legitimacy are not equivalent forms of power. An American sanction can be economically powerful while remaining an instrument of U.S. policy; a Security Council sanction carries a different kind of authority because it is formally embedded in an institution established to represent collective international action. When Washington cannot secure agreement in the Council, it does not necessarily lose its capacity to constrain Iran, but it does lose some of its ability to characterize that constraint as the expression of a broad international consensus.
This distinction is likely to become increasingly important as the international system moves toward a more openly competitive form of multipolarity. The post-Cold War period was characterized by an unusually high concentration of Western economic, institutional and political influence, but that concentration has progressively weakened as Russia has sought to challenge the European security order, China has expanded its economic and diplomatic reach, and middle powers have become increasingly reluctant to align automatically with either Washington or Beijing.
The Security Council was designed to manage disagreements among the major powers by giving each permanent member the ability to prevent decisions that it regarded as fundamentally threatening to its interests. The same institutional design, however, becomes a source of paralysis when the major powers no longer possess sufficient strategic convergence to negotiate outcomes on the most contentious international security questions. The veto, in such circumstances, ceases to be merely a procedural instrument and becomes a demonstration of the limits of one power’s ability to impose its preferred interpretation of international order upon another.
The consequences will extend beyond Iran. If the present trajectory continues, the international community is likely to witness the gradual emergence of a more fragmented sanctions architecture in which UN sanctions remain important where consensus can be achieved, while unilateral, bilateral and coalition-based sanctions become the principal instruments in disputes where the permanent members are divided. Western governments will increasingly rely on their own financial and technological leverage when Russia or China blocks action in New York, while Moscow and Beijing will have stronger incentives to develop alternative financial channels, trading arrangements and diplomatic mechanisms designed to reduce the vulnerability of their partners to Western coercion. Such a system would not amount to the disappearance of international law, but it would represent a significant shift from a relatively centralized model of international enforcement toward a competitive system in which different geopolitical blocs increasingly operate according to overlapping but incompatible interpretations of legitimacy.
The legal consequences could be equally significant. The dispute over Resolution 2231 demonstrates how legal interpretation itself can become an instrument of strategic competition. In a less polarized international environment, disagreements over the meaning of a resolution could be managed through diplomatic negotiation, institutional practice or compromise. In a more competitive environment, however, states have incentives to develop legal interpretations that reinforce their geopolitical positions, while the absence of a universally accepted mechanism for resolving disagreements among permanent members leaves the international system vulnerable to prolonged ambiguity. Similar disputes could emerge in future crises involving nuclear proliferation, cyber operations, maritime security, territorial disputes, sanctions enforcement and the use of economic coercion. The danger is not necessarily that international law will disappear, but that its authority will become increasingly contested precisely where it is most needed.
The Middle East will be one of the principal arenas in which this transformation becomes visible. Iran occupies a unique position at the intersection of American power, Russian strategic interests, Chinese economic ambitions, European security concerns and the calculations of the Gulf states. The Iranian nuclear question therefore cannot be separated entirely from the wider restructuring of the regional order. As Gulf governments pursue greater strategic autonomy, China expands its diplomatic role, Russia seeks to preserve its regional influence and the United States recalibrates its military and political commitments, the Middle East is becoming less a region dominated by a single external power and more an arena in which several major powers compete, cooperate and hedge simultaneously. The Security Council’s inability to maintain consensus over Iran is consequently a symptom of a broader transformation already taking place across the region.
The most plausible future is not the sudden collapse of the Security Council, nor its disappearance as an instrument of international diplomacy. The institution remains too deeply embedded in the international system for either outcome to be likely in the foreseeable future. The more consequential development is likely to be functional fragmentation: the Security Council will continue to produce resolutions and provide a diplomatic forum, but its capacity to generate binding consensus on the most strategically sensitive questions will become increasingly uneven. Its relevance will persist, while its effectiveness will depend more heavily on whether the permanent members perceive sufficient common interest to compromise. Where that common interest exists, the Council will remain capable of collective action; where it does not, states will increasingly move outside the UN framework and construct parallel mechanisms of enforcement, financing, security cooperation and diplomacy.
That trajectory would have consequences for Washington, Moscow and Beijing alike. For the United States and its European allies, the challenge will be to preserve the credibility of multilateral institutions without assuming that Western economic power automatically translates into multilateral political authority. For Russia and China, the challenge will be different: exercising their veto power to constrain Western initiatives may advance their immediate interests, but excessive institutional obstruction could also contribute to the erosion of the very multilateral system in which they retain privileged positions. For Iran, the divisions among the major powers create opportunities, but they also create a more complicated environment in which Tehran cannot assume that Russian or Chinese diplomatic support will always override their own national interests.
Ultimately, the question emerging from the dispute over Iran is not simply how much pressure the international community can place on Tehran. It is whether the international community can still agree on the rules through which that pressure should be legitimized, monitored and enforced. That distinction goes to the heart of the future of the Security Council. The immediate dispute may concern Iran, sanctions and the mandate of an expert mechanism, but the larger struggle is over whether the United Nations can remain an effective institutional expression of collective international authority at a time when the distribution of global power is becoming more contested and the major powers increasingly disagree not only over policy, but over the rules themselves.
The outcome of that struggle will determine whether the Security Council adapts to the emerging multipolar order or gradually becomes a forum that reflects geopolitical divisions without possessing the institutional capacity to overcome them. Iran is therefore not merely another item on the Council’s agenda. It is a test case for a much broader question: whether the institutions of the postwar international order can retain authority when the great powers that created and sustained them are no longer prepared to agree on what that order should mean.
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