It was announced over the weekend that the technical details of how the Joint Plan of Action (JPA) will be implemented have been worked out and will go into effect on January 20, 2014. For those readers unfamiliar with the JPA it is the document that constitutes the mandates of the interim nuclear deal reached between Iran and the West over its disputed nuclear program. As part of that deal Iran is supposed to take steps to limit its ability to develop a nuclear weapon and in exchange will receive relief from sanctions that have been imposed by both the United States and the EU.

As I have written previously on this blog, although the categories of sanctions relief were indicated in the JPA the details of that sanctions relief and how it would impact transactions with Iran was not included as technical experts from both sides still had to meet to determine how implementation would actually occur. It was later noted that when sanctions relief was actually instituted the public would be made aware of such relief by revisions to the U.S. sanctions regulations administered by the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) or by guidance issued by OFAC.

So the question is: now that the details have been worked out will we see new guidance from OFAC this week on how the sanctions relief will look? Possibly, but I don’t believe so. While the details on the suspension of sanctions related to the release of $4.2 billion of Iranian funds held at foreign banks were released, I don’t believe there will be any further details before January 20th or even immediately thereafter. My reason for saying this is because in order for the sanctions relief to kick in, Iran has to take certain measurable steps. As the U.S. sees that such measures are being taken by Iran, then it will begin to implement the specific sanctions relief it has promised in the JPA. As such, it is unclear when the formal guidance and changes constituting the sanctions relief will come out, but I would bet that it won’t be for at least a few months.