Yesterday, I said that we can expect guidance relating to the U.S.’s provision of sanctions relief sooner rather than later. Yesterday’s news suggests I was right.

First, Iran’s Deputy Foreign Minister for Legal Affairs, Abbas Araghchi (who also served as the political director for Iran during the nuclear talks), stated to Iran’s press that the U.S., the EU, and Iran would resume discussions on November 12th regarding public guidance for sanctions relief.   In consideration of the fact that Araghchi talked about discussions “resuming” and not just “beginning,” it is clear that the process for drafting and revising sanctions guidance is well under way.

Few have paid it much heed, but pursuant to Annex V § 13 of the Joint Comprehensive Plan of Action, the United States and its European partners are obligated to “begin consultation[s] as appropriate with Iran regarding the relevant guidelines and publicly accessible statements on the details of sanctions or restrictive measures to be lifted under this JCPOA.”

This particular provision was a big ask of Iran’s – as Iran was all-too-well aware of how the United States and its officials in charge of the administration of sanctions either withheld guidance so as to create ambiguities in U.S. sanctions laws that had the effect of furthering limiting trade-related dealings with Iran or, at times, privately expressed U.S. opposition to trade that might have been otherwise permissible under existing sanctions laws. As such, Iran inserted into the nuclear agreement a provision whereby the U.S. and its European partners would have to consult with Iran as to the content and form of public guidance for the U.S. and EU’s provision of sanctions relief.

The fact that those consultations are happening sooner than later signals that all parties are keen on making public such guidance at the earliest possible date.

The second big news item is that Iran is beginning to implement its obligations under the nuclear agreement, according to remarks from the head of Iran’s Atomic Energy Agency, Ali Akbar Salehi. Reportedly, Salehi said that Iran had actively begun reducing its number of centrifuges as required under the nuclear agreement. That process, he said, could take a number of weeks.

As I noted in the earlier post, the United States will have to play close attention to the speed at which Iran is undertaking its obligations. The Obama administration has advertised the fact that it would begin to release public guidance on the U.S.’s provision of sanctions relief prior to Implementation Day. The quicker Iran’s progress implementing its nuclear-related commitments under the JCPOA, the quicker the U.S. will have to release such guidance.

It should come as no surprise, then, that the U.S., Europe, and Iran are prepared to ramp up discussions on what sanctions relief guidance will look like.