Recent indications say yes.

Last Friday, Secretary of State John Kerry took the podium at the daily State Department press briefing to give short remarks on the year ahead. Out of the gate, Secretary Kerry praised the recent nuclear agreement between the United States, other major world powers, and Iran and noted that the parties “are days away from implementation…” As a result, Secretary Kerry said, the United States is “currently engaged [] in making certain that [the U.S. is] prepared to move on that day [lifting sanctions].” Secretary Kerry further remarked that he believed Implementation Day “could come – without being specific – sooner rather than later.”

Evidencing this timeline, the parties to the Joint Comprehensive Plan of Action (“JCPOA”) – the formal title of the nuclear agreement – reportedly had their final consultative meetings prior to implementation of the nuclear accord in Geneva, Switzerland this past weekend. According to translated remarks from Iran’s lead negotiator at the consultative meetings, the Director General for Political and International Affairs at Iran’s Foreign Ministry Hamid Baedinejad, on Instagram – a common posting forum for Iran’s political leadership – “the countdown to Implementation Day…has already started. The successful meeting between the parties in Geneva to resolve the remaining issues with respect to lifting of sanctions is another important step towards Implementation Day.”

Do these developments point to the imminent release of sanctions relief guidance from OFAC, as promised by U.S. officials? I had been told that such guidance would predate Implementation Day, perhaps “by weeks”, according to a U.S. official, but considering the speed at which Iran realized its own nuclear-related commitments under the JCPOA – weeks, if not months, ahead of the expected timeline – the release of such OFAC guidance will likely be much closer-in-time to Implementation Day.

Those in the sanctions world might thus have some interesting reading ahead for us shortly. Stay tuned.

Update: Since I posted this last night, subsequent events provide further evidence that Implementation Day is upon us.  This morning, Iran President Hassan Rouhani stated that, “in the coming days,” Iran would witness the “termination of sanctions,”  and EU foreign policy chief Federica Mogherini noted that, despite the fact that there is “no set date” for Implementation Day, it could come “rather soon”.  It seems to me no coincidence that U.S., European, and Iranian officials are all repeating the same line regarding the imminence of Implementation Day.