So the EU leapt into action and passed a ridiculous "law to forbid [European] companies from complying with US sanctions", very much at the behest of the French". They also tried to establish a bypass mechansim to facilitate inernational payments using a "non-transparent SPV" device - which, I predicted at the time, wouldn't work.
And, it doesn't. In fact, none of it works. Total has thrown in the towel. SWIFT has thrown in the towel.
Like almost all other EU states, France has so far received no exemptions for doing business with Iran. Leading French companies, including Peugeot parent PSA and oil group Total, have already announced plans to curb their Iran activities. [FT]So much for the EU's much vaunted foreign-policy strength and expertise, to say nothing of its *understanding of markets* (=0).
"Almost all ..." Anyhow, in the middle of all this is the UK with a very specific problem. The Iranians hold a major stake in a substantial North Sea asset-base which represents 5% of our gas production, much needed in winter.** The main operator involved is BP (and funnily enough, Total is also involved.) As mentioned before, I can tell you that no bugger in the mainstream energy industry (we are excepting the outright pirates) will step over the US sanctions line: which meant that gas production from the relevant fields (Rhum, Keith and Bruce) was set to be shut down - unless something could be negotiated.
Fortunately, BP is experienced in the ways of the world and, with a little help from HMG, has calmly negotiated a waiver from the US authorities. The gas still flows.
UK - 1, EU - 0. These things can be done. There are people who know the score (the first half of this podcast is worth listening to). If only the right people had taken May in hand back in 2016.
** stand by for some scary days for energy supply if Jan-Feb-March 2019 turn out cold, whether or not this gas is flowing.