For those interested in discerning opportunities for renewed trade with or investment in Iran, one of the key elements of a potential nuclear deal with Iran is the pace at which U.S. and multilateral sanctions are lifted. Under the April 2nd Joint Statement reached in Lausanne, Switzerland, between the U.S., other major world powers, and Iran, little was revealed. Instead, the Joint Statement merely declared that the U.S. would “cease the application of all nuclear-related secondary economic and financial sanctions, simultaneously with the IAEA-verified implementation by Iran of its key nuclear commitments.”

Based on news coming out of Vienna, where the latest (and perhaps last) round of talks are being held, it looks like the negotiating parties have fleshed this out a bit more.

According to a U.S. diplomat, the U.S. and Iran have agreed to a “three-part process” for implementation of a Joint Comprehensive Plan of Action (“JCPOA”). Under this “three-part process”, as reported by Bloomberg News, the U.S., its P5+1 partners, and Iran would first agree to the JCPOA, which would detail each of the parties’ various obligations under a deal. Following this, the U.S. and Iran would both enter what is discussed as a “preparatory” phase, where Iran would take steps to constrain and roll-back its nuclear program as required under a deal while the U.S. and the P5+1 would start to undertake the difficult work of figuring out how to actualize the relief promised Iran as part of a deal. This “preparatory” phase may take place during the same period in which Congress is reviewing a nuclear deal, as provided under the Iran Nuclear Agreement Review Act.

After Congress has had a chance to review the agreement (a period which should last 30-60 days, depending on when the agreement is presented before Congress) and the International Atomic Energy Agency verifies that Iran has taken the steps required of it, then the nuclear deal would become operational (perhaps with a signing ceremony?) and the sanctions relief, as drafted during the interim, would become effective.

The Iranians have suggested that this could take place “within weeks”, while U.S. officials have suggested it could be a few months before a deal is operationalized.

Regardless, the interim period where Congress is reviewing a deal will be a busy one for U.S. officials tasked with figuring out how to effectuate the promised sanctions relief. Broadened licensing schemes; the removal of certain designations; and proactive guidance to the private sector will all be part of OFAC’s work in the weeks ahead should a nuclear deal be reached. As Treasury officials are keen to note, the Iran sanctions program is the most complicated sanctions program ever administered by OFAC. Unspinning the web will prove difficult work. A U.S. official speaking on background in Vienna confirmed as such:

“We have a lot of preparation to do. [The sanctions are] not something you just turn a switch and all of a sudden [they’re] gone. There’s not only paperwork but a lot of interaction with financial institutions, developing regulatory guidelines, guidance to banks – tons and tons of stuff. We have to prepare as well. So everybody will get ready, everybody will take their steps, and then when the IAEA has verified virtually simultaneously whatever commitments we make about the first phase of the lifting of sanctions will occur.”

Nonetheless, the basic contours of a timeline for sanctions relief looks to be worked out. Those interested in the extent of the sanctions relief will get their first viewing later this week or into next week when the negotiating parties potentially finish a JCPOA (whose text will be dozens of pages long and will contain one annex dedicated to the sanctions issue). Following this, major financial institutions can expect to start to receive some guidance from U.S. authorities shortly thereafter. This process will culminate when the deal is ready to be operationalized and OFAC unveils the new authorities that will govern the post-deal world.