Gibraltar announced on Sunday Washington was seeking to seize the ship on grounds “intrinsically linked” to US sanctions against Iran.
“The Gibraltar Central Authority [for Mutual Legal Assistance] is unable to seek an Order of the Supreme Court of Gibraltar to provide the restraining assistance required by the United States of America,” a Gibraltar government statement said.
"The Central Authority's inability to seek the Orders requested is a result of the operation of European Union law and the differences in the sanctions regimes applicable to Iran in the EU and the US," it added.
“The EU sanctions regime on Iran is fundamentally different to that of the US," according to the statement.
Gibraltar's Supreme Court on Thursday ruled in favour of releasing the vessel seized weeks ago. Hours before the announcement, the United States had launched a last-minute legal move demanding that the British overseas territory detain the ship.
Late on Thursday, the United States threatened a visa ban on the crew of the released supertanker, claiming, without providing any proof, that Grace 1 "was assisting the Islamic Revolution Guards Corps (IRGC) by transporting oil from Iran to Syria" and this "could result in serious consequences for any individuals associated with the Grace 1".
On Friday, Washington ordered the seizure of Grace 1, charging the ship with illegally using the US financial system to sell oil to Syria after Gibraltar released the vessel.
The Justice Department has sealed a warrant ordering the seizure and forfeiture of the Iranian oil tanker, all of the oil it is carrying, and $995,000, claiming the Iranians illegally used the US banking system to finance the shipment of oil to Syria to support the IRGC.
Accusing the ship of violations of bank fraud and money laundering laws, the International Emergency Economic Powers Act, and terrorism statutes, the US complaint alleges “multiple parties affiliated with the IRGC” used voyages like that of Grace 1 to support illegal activities and claims “a network of front companies” laundered millions of dollars through these shipments.
In early July, British marines and Gibraltar police seized the Iranian tanker off the Southern coast of the Iberian Peninsula. Picardo had claimed that the ship was transporting crude oil to Syria “in violation” of the EU sanctions placed on Damascus. Washington has applauded the move, hailing it as a sign that Europe is on board with the US’ unilateral sanctions against Iran.
Iran condemned the “illegal move” of London and described it as “tantamount to piracy”. Tehran accused the UK of doing Washington’s bidding and helping the US attempt to stifle the Islamic Republic’s oil exports, rejecting London's claim that the supertanker was carrying crude for Syria.