Gibraltar rejected on Sunday a U.S. effort to seize an Iranian supertanker held in the British territory’s port, despite allegations from the United States that the ship helped the Islamic Revolutionary Guard Corps transport oil from Iran to Syria.

In an unusual move, the Justice Department unsealed a seizure warrant and forfeiture complaint on Friday for the Grace 1 supertanker, which the U.S. says is controlled by the Revolutionary Guard, and the Justice Department sent a mutual legal assistance request to British-controlled Gibraltar.

The Justice Department alleged that the oil tanker was part of a “scheme” to “unlawfully access the U.S. financial system to support illicit shipments to Syria from Iran” by the Revolutionary Guard and that this plot was aided by multiple parties as well as a “network of front companies” that laundered millions of dollars connected to the “deceptive voyages” of the ship. Therefore, the U.S. asked for the tanker, all of its 2.1 million barrels of crude oil, and $999,950 in allegedly illicit bank funds be turned over.

A court in Gibraltar said no earlier today.

The supertanker, which originally deceptively flew a Panamanian flag before being captured, has been sitting in a Gibraltar port since July 4, when the British navy seized it on suspicion that it was violating sanctions put in place by the European Union, which do not allow the transport of oil to Syrian dictator Bashar Assad. But the British gave the green light for the ship to be released last week after Iran said the oil would not be brought to Syria. The ship has been renamed the Adrian Darya 1 and is now flying an Iranian flag.

The Justice Department then moved to seize the ship late last week, alleging in a 20-page complaint filed in D.C. District Court and unsealed a few days ago that the ship was attempting to evade sanctions placed against Iran by the U.S.



The Gibraltar Central Authority declined the request to hold the ship and to hand it over to the U.S., saying its inability to follow through with the request from the U.S. “is a result of the operation of European Union law and the differences in the sanctions regimes applicable to Iran in the E.U. and the U.S.” Gibraltar admitted that the sanctions placed by the EU against Iran are “much narrower” than those placed against the regime by the U.S. Gibraltar also noted the Revolutionary Guard “is not a designated foreign terrorist organisation in Gibraltar, the U.K., or in the E.U. generally” unlike it is in the U.S.

It is not known whether the freeing of this allegedly Revolutionary Guard-controlled vessel will result in the Iranians releasing the British tanker — the Stena Impero — which Iran seized in the Persian Gulf in July. It is also not known whether the U.S. Navy will take further action once the Iranian supertanker sets sail again.

State Department spokesperson Morgan Ortagus had warned on Thursday that the U.S. intended to use “all the tools at its disposal to deny Iran and its proxies the resources they need to engage in malign and destabilizing activities in Syria and elsewhere.” Ortagus emphasized that meant “the full enforcement of U.S. sanctions with respect to Iran and the IRGC.” The U.S. designated the Revolutionary Guard a “foreign terrorist organization” in April.

The Revolutionary Guard, along with its specialized Quds Force, supports terrorists around the world, carries out cyberattacks and assassinations, funds illicit missile development, and wields huge influence both inside the country and around the region. The Revolutionary Guard also plays an integral role in funding, training, and guiding Iran’s global proxies — including Hezbollah in Lebanon, Shiite militias in Iraq, and the Houthis in Yemen — and in propping up Bashar Assad in Syria. And the Revolutionary Guard

played a significant role in the deaths of hundreds of U.S. soldiers in Iraq.