I’ve been getting a lot of questions recently as to when we can expect OFAC to start issuing guidance related to the U.S.’s provision of sanctions relief under the recent nuclear agreement with Iran.

The short answer: Soon.

Little more than two weeks ago, on October 18th, the U.S., other major world powers, and Iran began the implementation phase of the nuclear agreement (also known as “Adoption Day”), in which all parties are obligated to undertake certain steps to realize commitments in time for Implementation Day.

Implementation Day, however, has no fixed date. Instead, it will be dated according to the International Atomic Energy Agency’s verification that Iran has completed its key nuclear-related steps. Until that time, no sanctions relief will be provided above and beyond that provided in the Joint Plan of Action.

Nonetheless, major questions remain unresolved as to how quickly Iran can meet those commitments. Furthermore, the U.S. does have major responsibilities of its own during this implementation phase, including consultation with the Iranians as to what the guidance it will provide on sanctions relief will look like and the drafting and issuance of said guidance.

It is clear that OFAC will be providing guidance on sanctions relief prior to Implementation Day, in order for parties interested in engaging in otherwise prohibited trade-related activities with Iran or Iranian parties to prepare themselves for re-entry into the Iranian market. As such, clarity as to the timeline for Iran’s implementation can elucidate the timeline for when we can expect OFAC to start issuing guidance.

On the U.S. side, the predicted timeline for Iran to complete its key nuclear-related steps has always been 6-9 months from the time of Adoption Day (so, roughly, between April-July 2016). Iran, however, expects itself to finish implementation much sooner with most officials predicting completion of key nuclear-related steps by the end of the year (i.e., before January 2016). A couple of weeks ago, the Joint Commission of the JCPOA met in Vienna, where I am certain some of these details were hashed out and timelines re-adjusted.

Still, the differing projected timelines likely means that OFAC will need to issue guidance quicker than it might have initially expected. While expert teams from all parties to the JCPOA continue to meet to work out the logistics of implementation and will thus receive more clarity as to the actual timeline, OFAC must remain cautious and ensure that its guidance predates Iran’s completion of its nuclear-related steps.

Therefore, if the U.S. starts to see major action on Iran’s part to meet or come close to meeting the January 2016 deadline Iran has set for itself, then we could see OFAC issuing guidance as early as December, if not mid-to-late November this year. I understand OFAC has an extensive set of Frequently Asked Questions (FAQs) in the works, so this is likely to be a race to the finish line (though OFAC has resolved staffing problems by peeling off persons from different departments at OFAC to concentrate on the Iran sanctions file).

In short, as I’ve said, we can expect guidance related to the U.S.’s provision of sanctions relief to Iran sooner than later. Lots of interesting questions remain unresolved as to the sanctions relief – not least of which is the details of the expected license authorization for foreign subsidiaries of U.S. companies.