Gibraltar Rejects US Request to Detain Grace 1 Because of Differing EU, US Sanctions Regimes

Gibraltar's recent release of an Iranian oil tanker that had been seized by British authorities in July for potential sanctions violations came despite requests from the U.S. to continue to detain the ship, according to a statement released Aug. 18 by the United Kingdom territory.

The announcement came days after the Justice Department announced the U.S. was unsealing a seizure warrant and forfeiture complaint against the tanker, Grace 1. In the complaint, the U.S. said the oil tanker had violated the International Emergency Economic Powers Act and said Iran tried to illegally access U.S. banks to “support illicit shipments to Syria from Iran.”

Gibraltar said it could not “provide the restraining assistance required by the” U.S. because of the differences in European Union and U.S. sanctions regimes. “The EU sanctions regime against Iran -- which is applicable in Gibraltar -- is much narrower than that applicable in the US,” Gibraltar said.

Grace 1 was originally seized by Gibraltar Port and Law Enforcement in Gibraltar territorial waters after authorities suspected it of shipping oil to Syria, which would have violated EU sanctions (see 1907080022). Gibraltar later released the ship after it said Iran said it provided “written assurance” it would not be transporting oil to Syria (see 1908160034).