U.S. sanctions on the high seas test European allies’ patience

Crew members walk down a ladder on Grace 1, an Iranian tanker seized by Gibraltar.
Crew members walk down a ladder aboard Grace 1, a tanker carrying Iranian oil that was seized by Gibraltar, in July 2019.
(Jorge Guerrero / AFP/Getty Images)

In the escalating tanker wars between the West and Iran, Washington is facing resistance from its traditional international partners.

The Trump administration wants to take its “maximum pressure” campaign to the high seas, blocking Tehran’s ability to export oil via its tanker fleet while safeguarding international shipping from Iranian attacks.

But the plans have run aground because of legal constraints and the qualms of European allies about engaging in a pressure campaign as they mount their own diplomatic efforts to engage with Tehran.


“The Europeans largely share U.S. views that Iran’s activities in a number of areas are challenging, to say the least, but they split with the Trump administration on the best course of action,” said Ariane Tabatabai, an associate political scientist at Rand Corp., in a phone interview Friday.

She added that pressure on the high seas wouldn’t hurt just Iran, but also European interests.

“And as these countries find themselves in the middle of the crossfire between the two sides,” she said, “they further object to a policy they already didn’t subscribe to.”

The release of the Grace 1, the tanker carrying Iranian oil that was seized last month by Gibraltar, has become a test case for whether European nations will assist in the enforcement of U.S. sanctions in their maritime waters or restrict themselves to applying their own policy, said Esfandyar Batmanghelidj, founder of Bourse & Bazaar, a media company that focuses on business in Iran.

The top court in Gibraltar, a semiautonomous British territory, ordered the tanker released after receiving assurances from Iran that the ship was not headed to Syria, which is the target of European Union sanctions. (Iranian officials later denied giving any such assurances and have yet to release the Stena Impero, a British tanker they hold.)

The release comes despite an eleventh-hour request from Washington to impound the tanker for violation of U.S. sanctions. The government in Gibraltar issued a statement Sunday saying it had handled the U.S. request “with great care in order to be able to assist ... in every way” but could not do so because European Union sanctions could not be applied to the Grace 1.


The U.S. sanctions regime is aimed at strangling Iranian energy sales. It has hobbled Iran’s tanker fleet by threatening to sanction Tehran’s oil deliveries and any parties associated with the transaction. The U.S. has pushed its allies to do the same.

Iran has not taken the measures lightly: This year, it reacted by launching a bevy of nonlethal attacks on tankers in the Persian Gulf. When Gibraltar seized the Grace 1, suspecting it was delivering fuel to Syria, Tehran commandeered a British tanker as it passed through the Strait of Hormuz near Iran’s coast.

“A strait for a strait,” said Iranian President Hassan Rouhani in a meeting with reporters this month, by way of explanation for the capture of the British tanker.

“It can’t be that the Strait of Hormuz is free for you and the Strait of Gibraltar is not free for us.”

To protect shipping from Iranian attack, Washington has called on 60 countries to join a U.S.-led naval mission that would organize convoys to escort vessels as they pass through the Strait of Hormuz, which is considered the world’s most important oil transit choke point.

Yet the challenges before such a mission are considerable, said Lawrence Brennan, a professor in maritime law at Fordham University and a former Navy captain who served in the Persian Gulf.


“How do you protect ships in these bodies of water? You need multiple ships, with close proximity, with air support,” said Brennan in a phone interview.

Hormuz’s distance from U.S. naval ports means a transit time of weeks, Brennan added. As well, the force would have to comprise 15 to 20 ships, along with support and replacement ships, with a unified command, communications system, and rules of engagement.

“You just don’t have that there,” he said.

Few European countries have signed on to the effort; Germany has outright refused. Israel has said it would provide intelligence to the coalition, spurring a quick condemnation from Iraq, whose foreign minister said in a tweet that “the presence of Western forces in the region will raise tensions.”

Meanwhile, the heightened volatility in Hormuz has already pushed up insurance rates, said Richard Mallinson, an analyst and co-founder of Energy Aspects, an energy consultancy, with insurers employing a 10% to 15% war risk premium on vessels and their cargo journeying through the strait.

It also has made companies look for other ways to transport their oil.

“The question is, are you after a deterrent effect, which you could achieve with a manageable number of vessels, or actively expecting to have to counter a real threat or respond?” asked Mallinson.

If it’s the latter, he said, “you would probably see a lot of shippers preempting and refusing to pass, because the dangers and the complications look too high.”


For Iran, said Jon Alterman, director of the Middle East program at the Center for Strategic and International Studies think tank in Washington, the presence of coalition ships could be used as a reason for heightening tensions, but avoiding war.

“Iran’s goal is crisis without war, and there are endless ways to create tension,” he said.

For U.S. partners, he said, it’s the “worst of both worlds.”

“The question on everyone’s mind,” he added, “is what are we signing up for? If it’s just information and not protection, not only does that not get you protection, it could make you more vulnerable. And there is fear the U.S. would get involved in a hostile action that [allies] don’t want and didn’t sign up for.”