France: U.S. Sanctions on Iran, Russia Look Illegal

European Commission President Jean-Claude Juncker. (Reuters/Vincent Kessler)

France’s foreign ministry on Wednesday said new U.S. sanctions against Iran, Russia and North Korea appeared at odds with international law due to their extra-territorial reach.

The U.S. House of Representatives voted overwhelmingly on Tuesday for these sanctions, which could affect European firms.

The foreign ministry said in a statement that French and European laws would need to be adjusted in response and added that discussions would be necessary at European Union level because of the potential impact on European citizens and firms.

The European Union warned that it was ready to act within days to counter proposed new U.S. sanctions on Russia, saying they would harm the bloc’s energy security.

Brussels also fears the new sanctions will harm European firms and oil and gas projects on which the EU is dependent.

“The U.S. bill could have unintended unilateral effects that impact the EU’s energy security interests,” EU chief executive Jean-Claude Juncker said in a statement issued after a meeting at which European commissioners were united in their views, according to a senior EU official.

“If our concerns are not taken into account sufficiently, we stand ready to act appropriately within a matter of days. ‘America First’ cannot mean that Europe’s interests come last,” he said, mentioning President Donald Trump’s guiding slogan.

European Commission officials say the bloc could use EU regulations allowing it to prevent the application of extraterritorial measures by the United States; demand a U.S. promise to exclude EU energy companies; or impose outright bans on doing business with certain U.S. companies. In addition, the EU could file a complaint at the World Trade Organization.

However, most measures taken by Brussels would require approval from all 28 EU member governments, which could expose potential differences in individual nations’ relations with Moscow and Washington.

Despite changes to the U.S. bill that took into account some EU concerns, Brussels said the legislation could still hinder upkeep of the gas pipeline network in Russia that feeds into Ukraine and supplies over a quarter of EU needs. The EU says it could also hamper projects crucial to its energy diversification goals, such as the Baltic Liquefied Natural Gas (LNG) project.

The sanctions target the disputed Nord Stream 2 project for a new pipeline running from Russia to Germany under the Baltic Sea, bypassing traditional transit routes through Ukraine.

A list prepared by the EU executive, seen by Reuters, shows eight projects including those involving oil majors Anglo-Dutch Shell, BP and Italy’s Eni that risk falling foul of the U.S. measures.

Voicing frustration at the fraying in the joint Western approach to Moscow, Juncker said “close coordination among allies” was key to ensuring sanctions are effective.

The EU, the Commission said, is raising its concerns via “all diplomatic channels.”

It was unclear how quickly the U.S. bill would reach the White House for Trump to sign into law or veto. The bill amounts to a rebuke of Trump by requiring him to obtain lawmakers’ permission before easing any sanctions on Moscow.

Rejecting the legislation – which would potentially stymie his wish for improved relations with Moscow – would carry a risk that his veto could be overridden by lawmakers.

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