On January 16, 2016, following a favorable report from the International Atomic Energy Agency, the P5+1 powers (the United States, United Kingdom, China, France, Russia, and Germany) and Iran declared that “Implementation Day” had occurred under the Joint Comprehensive Plan of Action (“JCPOA”), bringing into force agreed relief from sanctions against Iran.[1] The scope of relief was largely as expected, but the timing of the declaration was significantly earlier than unofficial estimates provided last…