It looks like sanctions relief for Iran may come as soon as late this week or next week, according to officials from both Iran and the major powers that negotiated with Iran (the so-called “P5+1” countries).  Iran’s government claims it has completed the removal of the core of the Arak heavy water reactor and filled it with cement, one of the key remaining steps Iran was obligated to take to fulfill its commitments under the Joint Comprehensive Plan of Action (JCPOA).   The Wall Street Journal, however, reports that there is some lingering doubt about whether that work has been completed.  Iran had already removed nuclear material from the country and taken other required steps under the JCPOA.

Whether or not the Arak work is fully complete, sources appear to agree that Implementation Day is not far off.  The spokesperson for Iran’s atomic energy agency has said the JCPOA will be implemented “in the next seven days.”  Similarly, Iranian President Hassan Rouhani said on Monday, “We are hopeful that the sanctions against Iran would be lifted in the next few days.”

Officials from the P5+1 countries do not appear to be refuting the statements coming out of Iran.  Federica Mogherini, the EU’s foreign affairs representative, said on Monday that Implementation Day “could come rather soon.”   The Wall Street Journal reports other unnamed Western officials as saying implementation could occur as early as Friday, but more likely a few days later.  And U.S. Secretary of State John Kerry said last week that Iran may be “days away” from meeting its commitments.

Implementation Day will not occur until the International Atomic Energy Agency (IAEA) confirms that Iran has met the first round of its commitments under the JCPOA, but it is looking increasingly likely, based on these public statements, that this may occur within days.  It has been widely reported that Iran is pushing for implementation well before its parliamentary elections on February 26th.

The U.S. Government and the other P5+1 governments have been working to have legal measures and guidance in place once Implementation Day is announced so sanctions relief can take effect on the intended day.  See our earlier advisory for a more detailed look at what the deal provides for.  Among the key points to keep in mind: the U.S. embargo on Iran will remain largely intact, with the exception of some expected loosening of restrictions on foreign subsidiaries.  The EU sanctions relief will be more extensive and will allow the resumption of significant trade with Iran.