From (MAED)

Mr Avidgwood

HKG 122/324/1

Reference

FD. STC

1. consider de s2 MAY 1980

angle in the Light of thes

Mr Pryor

shel, see

INDEX

REGISTRY Action Fami's Rame

ver $12.6

nhưng

My Eday

915.

Mr Brown

Mr Wood

17

P. Morice ESS HKCD

Mrs. Denza Legal

Ouiser

M. Wallace, WIAD

H. Lamport MED

Regustirng Pse return to me with &

PROPOSED SANCTIONS AGAINST IRAN

188 12.5

I am taking your minute of 8 ay as an invitation to the Foreign Office to say whether and to what extent the sanctions orders

should extend to the dependencies and colonies. My working assumption will be that the principal order should extend to the United Kingdom only.

I also take your minute to say that the principal order should apply only to British ships registered in the United Kingdom and ships chartered to UK nationals. But it should not apply to UK owned ships under foreign flag which are not operated by

the UK owner. UK owners who do operate seem to fall in the

same category as UK charterers.

Is this assumption correct?

On extraterritorial sanctions, you will see that the Bill enables orders to provide that certain persons connected with the United

Kingdom may be made guilty of offences for acts or omissions commited outside the territory. Just because we have the powers of course does not mean that they must be used and the extent to

which the orders should create extraterritorial offences must have

regard to the attitude taken by our Community partners. Doubts have been voiced in Brussels by some ember States about the

justification for extraterritorial penalties but I am not sure that these doubts have extended to offences commited by persons in control of ships of their registry. It would be very odd I think if we prohibited UK registered ships from trading with Iran and failed to provide penalties if the prohibition was violated. Indeed without a penalty I doubt whether it would be appropriate to impose a prohibition at all. In paragraph 5 of your minute you

CODE 18-77

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