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other member states' measures is sufficiently parallel to what we are proposing to enable our Orders to be justified in Parliament. A summary of our present information on the main points is attached.
EXPORT OF GOODS
4. No other member state is specifically banning contracts for the supply of goods, but merely exports through the intro- duction of a licensing requirement. Belgium, Luxembourg and the Netherlands appear to require licences for all exports. France, Germany and Denmark will not require licences for food and medical supplies, but only for embargoed goods. None of the other member states has so far published detailed guidance as to the circumstances in which licences will be awarded or refused, and there have been indications that, e.g., Germany intends to rely to a considerable extent on administrative discretion to ensure that any sanctions do not hurt Germany more than they hurt Iran.
TRANSPORTATION
5.
Only the German decree provides for the application of the full range of transport sanctions set out in the Security Council draft Resolution, including banning cross-trading to Iran by German registered ships and aircraft, unless authorised by the German Government. Belgium is prohibiting the transit through Belgium of goods bound for Iran. France and Denmark appear to be applying no measures at all in the field of transportation.
6. The proposed British measure does not include all the elements envisaged in the Security Council draft Resolution. The draft Resolution would prohibit not only transportation of goods directly from the UK to Iran, but also cross-trading by UK ships and aircraft, from a third state, to Iran and also the chartering by UK companies of ships to transport goods to Iran. The failure of the British Order to include these elements is defensible in view of the very half-hearted appli- cation of the sanctions on transportation by our Community colleagues, particularly considering that it is British shipping which has a far bigger stake in cross-trading to Iran than any of the other European member states.
SERVICE CONTRACTS
7. Only the Germans and Danes cover service contracts in their decrees. The French and Belgians appear not to be covering these at all (the former apparently do not intend to do so).
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