Why did Gibraltar reject the US demand to seize the Iranian oil tanker?

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Gibraltar Rejected US Demand to Seize Iranian Oil Tanker Due to EU Sanctions Limitations

Gibraltar's government stated it could not comply with the US demand to seize the Iranian oil tanker Grace 1 because US sanctions against Iran are not applicable within the European Union. The EU sanctions regime, which applies in Gibraltar, is significantly less extensive than the sanctions imposed by the United States. This legal distinction prevented Gibraltar from obtaining a court order to detain the vessel, despite the US Justice Department's request.
European Union Sanctions Precedence

The primary reason for Gibraltar's refusal to detain the Grace 1 was the difference in sanctions regimes. Gibraltar operates under EU sanctions law, which has a narrower scope regarding Iran compared to the unilateral sanctions enacted by the United States. Consequently, the legal basis for seizure under EU law, which had led to the tanker's initial detention on suspicion of breaching European sanctions by attempting to deliver oil to Syria, did not extend to the broader US allegations.
US Allegations and Forfeiture Request

The US Justice Department had filed a request to detain the Grace 1, which had been renamed the Adrian Darya. This request was based on allegations that the tanker was involved in facilitating illicit shipments to Syria, purportedly on behalf of Iran's Islamic Revolutionary Guard Corps. According to the US Justice Department, the vessel and its cargo were subject to forfeiture due to violations of US sanctions.
Diplomatic Ramifications of Initial Seizure

The initial seizure of the Grace 1 by Gibraltar authorities had already led to a significant downturn in relations between Tehran and London. This deterioration culminated in Iran detaining the British-flagged tanker Stena Impero in what was widely perceived as a retaliatory measure. The ongoing dispute highlights the complex geopolitical tensions surrounding Iran's oil trade and international sanctions.

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Why did Gibraltar reject the US demand to seize the Iranian oil tanker?

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