Noticed that the State Department announced today that HR 158 is officially being implemented effective immediately with very few waivers - though it looks like a BBC reporter found out the hard way that implementation was already occurring as early as Monday, or at least Immigration Advisory at LHR was considering it to be in force by then. I was a bit surprised that they didn't exempt ESTA nationals with only tourism or family visits, given all the talk about how Obama could issue waivers to minimize effects on Iran. I really want to believe that DOS is acting in good faith, but it sure feels a little sneaky to wait until literally right after JCPOA implementation and the prisoner swap.

Am I naive to be surprised that there's evidently no grace period at all? Not even a week to run to an embassy for those who were expecting some sort of waiver? My impression was that the Iranian-American community was very hopeful of more substantial waivers from Obama, so this sudden mass ESTA cancellation and mandate must be creating a lot of frustration and extra work for IAP and consular staff in countries with large Iranian populations...

I'm also wondering how this is affecting people with active ESTAs who have visited Iran for non-permitted reasons but did not disclose dual nationality on the ESTA questionnaire. Are their presumably still active ESTAs theoretically nullified at this moment, even though thus US would likely have no way of knowing of an Iran visit in the absence of a physical passport stamp?

Now it will be interesting to see what Frontex and other VWP immigration agencies do in response. One hopes that they'll take pity on the Persian people and find some other demographic to impose visas upon if they want to go down the reciprocity route. Not sure how Schengen borders would even positively identify a US-Iran dual national, since they don't (yet) have any equivalent to the ESTA questionnaire...