British-controlled Gibraltar has refused to aid a US effort to seize Iranian oil tanker "Grace 1," originally detained on 4 July 2019 under suspicion that it was transporting oil to the Syrian regime, a violation of European Union sanctions against Iran. It has been docked in a Gibraltar port since its seizure.
The US Justice Department on Friday made public a seizure warrant and forfeiture complaint for the supertanker, alleging that it was controlled by Iran's Revolutionary Guard as part of a wider scheme to illegally access the US financial system. According to a press release from the Justic Department, "a network of front companies allegedly laundered millions of dollars in support of such shipments."
It alleges that this constitutes "unlawful use of US financial system to support and finance IRGC's sale of oil products to Syria," and sought forfeiture of the tanker, the 2.1mn barrels of crude oil that it was carrying, and $999,950 in what it says are illicit bank funds.
It sent a mutual legal assistance request to Gibraltar. The Gibraltar Central Authority denied the request, citing that the request was "intrinsically linked to the US sanctions regime against Iran. The EU sanctions regime on Iran is fundamentally different to that of the US."
It noted that EU sanctions against Iran are far narrower than those set by the US. Although the tanker may have violated US sanctions, it was based in Gibraltar at the time and did not violate the terms of EU sanctions against Iran. As such, the tanker will be allowed to leave the Gibraltar port.
When captured, the tanker deceptively flew a Panamanian flag, and has now been renamed the Adrian Darya 1, with an Iranian flag.