Mr Rushford, Legal Adviser
Reference
→c.c. M. A Pryor SPD
207
Mr. Ayling DOTS
SANCTIONS AGAINST IRAN: SHIPPING IMPLICATIONS FOR THE DEPENDENT TERRITORIES
1.
Please see the attached exchange of minutes on this subject. The problem appears to affect principally Hong Kong and Bermuda.
2.
The Iran (Temporary Powers) Bill appears to apply to ships (and aircraft) registered in the UK or in a Dependent Territory. It would not appear that the Bill requires us to ensure that the provisions apply to shipping which is owned by a company in a Dependent Territory but registered in a third "flag of convenience" · state. I should be grateful for your comments.
3.
If my interpretation is correct, MED will wish to be aware of this loophole. However the political difficulties in closing it would be enormous from Hong Kong's point of view.
9 May 1980
Cc:
стий
P Morrice
Hong Kong and General Department K247
233 4381
Mrs Denza, Legal Adviser (K194)
Mr Wood, MAED (G63/1) (without enclosures) Mr Wallace, WIAD (G 123/3)
Mr Lamport, MED
(W92)
: