Hopes that nuclear-related sanctions on Iran could be relaxed by the end of the 2015 have been lifted by the completion of the 60-day congressional review of the Joint Comprehensive Plan of Action (JCPOA) on 17 September and the announcement that the White House is preparing to issue conditional sanctions waivers as early as 18 October.

The possibility that the US congress would block the JCPOA ended when a resolution of disapproval of the deal failed to secure the required majority in the senate earlier this month. This made it unnecessary for President Barack Obama to exercise his veto against the disapproval resolution, which had been supported by 247 votes to 186 in the House of Representatives. The resolution would have prevented Obama from waiving, suspending or reducing sanctions under the nuclear agreement.

The State Department is now preparing sanctions relief plans including waivers of nuclear-related sanctions legislation. An unidentified State Department official told a background briefing in Washington on 17 September that the waivers will not be effective until the International Atomic Energy Agency (IAEA) verifies Iran has taken all steps required by the JCPOA to reduce its nuclear capacity.

“These waivers will be… issued and they will take effect on the day that the IAEA verifies that Iran has completed all of its specific steps – specific steps with respect to its nuclear programme,” the official is quoted as saying in a State Department summary of the briefing. “So this is kind of our first procedural step that we’ll take. That will eventually take effect later.”

President Obama is expected to start issuing the first conditional sanctions waivers from 18 October. This is named Adoption Day in the JCPOA. It is 90 days after the UN Security Council passed a resolution approving the deal on 20 July.

The final hurdle is approval by the IAEA of Iran’s measures to scale back its nuclear capacity. Its director general Yukiya Amano told the IAEA’s board of governors on 21 September that access had been granted to a location at the Parchin site which the IAEA regards as essential for the clarification of outstanding issues concerning Iran’s nuclear programme. Previously, the IAEA had been able to observe the site only using satellite imagery.

Under the JCPOA, Iran is obliged to allow the IAEA access to nuclear sites and provide information about its nuclear programme by 15 October. The IAEA board of governors is due to receive the final report on the agency’s review by 15 December. Experts say it is possible that Implementation Day, which is when all nuclear-related sanctions imposed by the US, the UN and the EU will be relaxed, could be before the end of the year. 

An EU spokesman told MEED on 22 September the EU will adopt an EU regulation on Adoption Day that will end the provisions implementing all nuclear-related economic and financial EU sanctions, including the embargo on Iranian oil.

“This Regulation – and the termination of the provisions implementing all nuclear-related economic and financial EU sanctions - will only take effect on Implementation Day, simultaneously with the IAEA-verified implementation by Iran of agreed nuclear-related measures,” EU foreign affairs and security policy press officer Nabila Massrali said in a statement.

The State Department background briefing on 17 September was told that the announcement of Implementation Day now mainly depends upon Iranian action. “…. the ball’s in Iran’s court, and until they do that, sanctions relief will not be provided,” a State Department official said.