Sanctions against Qassem Soleimani “will stay forever,” Secretary of State John Kerry said Tuesday. Soleimani is head of the Quds Force, the arm of Iran’s Islamic Revolutionary Guard Corps (IRGC), responsible for “exporting the revolution” abroad.

Soleimani has a long history of involvement in Iran’s most destabilizing activity. He oversaw its plot to assassinate the Saudi ambassador to Washington, its efforts to destabilize Iraq, its support for Bashar al-Assad’s brutal repression in Syria, and the IRGC’s proliferation of weapons of mass destruction. The Quds Force supports the Houthis in Yemen, Hezbollah, Shi’ite militants in Iraq, and Palestinian terrorist groups like Hamas and Palestinian Islamic Jihad. A 2013 New Yorker profile describes Soleimani as leading efforts to “reshape the Middle East in Iran’s favor, working as a power broker and as a military force.”

Kerry’s statements about Soleimani have been imprecise. The U.S. imposed sanctions on Soleimani in 2007 for proliferation, and those sanctions will remain in place even after the nuclear deal runs its course. But the EU and UN are another story.

The UN also designated Soleimani in 2007, along with other key IRGC officials involved in nuclear or ballistic missile activities. And yet, the UNSC passed a resolution last month that lifts sanctions on him on “Transition Day” eight years from now, or when the IAEA submits a report (a so-called “broader conclusion”) that it has adequately accounted for Iran’s nuclear program – whichever comes first. In other words, even if the IAEA cannot confirm that Tehran’s program is exclusively peaceful, UN nuclear-related sanctions against Soleimani will disappear.

While the EU’s designation of Soleimani for terrorism and for Syria-related issues won’t be affected by the Iran deal, the EU’s nuclear sanctions on Soleimani will also be lifted on Transition Day.

But sanctions are already unraveling. Soleimani traveled to Russia in violation of UN, U.S. and potentially EU sanctions.

The purpose of Soleimani’s Moscow visit was reportedly to discuss the purchase of S-300 surface-to-air missiles. The high-tech projectiles have a 90-mile range that provides Tehran the ability to harass military or civilian aircraft flying near its airspace, just as it has done in the past to cargo ships transiting the Strait of Hormuz.

Soleimani’s visit violates the UN-imposed travel ban on him, as well as U.S. secondary sanctions that ban foreign entities from transacting with designated individuals. If European banks were in involved in the trip’s planning – anything from flight tickets to hotels – they may be in violation of EU sanctions, as well.

Until now, neither Washington, Brussels, nor the UN has taken any steps to hold Tehran (or Russia) accountable. This violation of sanctions, even before the deal is implemented, is a crucial test case. Failure to act will signal to Iran that it can get away with incremental violations of the agreement, not to mention illicit activities across the region and around the world.

Toby Dershowitz is vice president for government relations and strategy at the Foundation for Defense of Democracies. Find her on Twitter: @TobyDersh

Annie Fixler is a policy analyst at its Center on Sanctions and Illicit Finance. Find her on Twitter: @AFixler