The US and Russia have both expressed expectations that Implementation Day may occur “as early as January” 2016. Implementation Day denotes the verification of Iran’s implementation of specified nuclear-related measures and the consequent beginning of sanctions relief under the Joint Comprehensive Plan of Action nuclear deal (the “JCPOA”) (see Issue 44 of the Sanctions Alert).

These expectations coincide with the publication of a report on 2 December 2015 by the International Atomic Energy Agency (the “IAEA”), the body responsible for verifying Iran’s implementation, on the history of Iran’s alleged attempts to develop nuclear weapons.

The report concluded that “a range of activities relevant to the development of a nuclear explosive device were conducted […] prior to the end of 2003 as a coordinated effort”, but “no credible indications of activities in Iran relevant to the development of a nuclear explosive device after 2009” were found. The IAEA also highlighted areas in which Iran’s cooperation with investigators was limited; little information was provided on some occasions, and some misleading responses were given.