European Scrutiny Committee Contents


19 Restrictive measures against Iran

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Council Decision 2012/35/CFSP amending Council Decision 2010/413/CFSP concerning restrictive measures against Iran

Council Implementing Regulation (EU) 54/2012 of 23 January 2012 implementing Regulation (EU) No.961/2010 on restrictive measures against Iran

Council Regulation (EU) 56/2012 of 23 January 2012 amending Regulation (EU) 961/2010 on restrictive measures against Iran

Legal base(a)  Article 29 TEU; unanimity

(b)  Article 215 (2) TFEU; QMV

DepartmentForeign and Commonwealth Office
Basis of considerationMinister's letters of 18 and 30 January 2012 and EM of 30 January 2012
Previous Committee ReportNone; but see (33388) — and (33389) —: HC 428-xliii (2010-12), chapter 23 (17 December 2011); (31779) —: HC 428-i (2010-11), chapter 61 (8 September 2010); (31905) —: HC 428-ii (2010-11), chapter 24 (15 September 2010); and (31937) —: HC 428-iii (2010-11), chapter 15 (13 October 2010)
Discussion in Council23 January 2012 Foreign Affairs Council
Committee's assessmentPolitically important
Committee's decisionCleared

Background

19.1 As the Committee's previous Reports under reference illustrate in detail, the EU has been engaged since December 2006 in a "dual track" strategy — engagement and restrictive measures — regarding Iran's nuclear activities, not simply implementing in the EU, but also strengthening in that context, successive UN Security Council Resolution (UNSCRs).[87]

19.2 UNSCR 1929 of 9 June 2010 imposed a number of further restrictive measures which in broad terms:

—  reaffirmed that Iran shall cooperate fully with the IAEA;

—  banned new Iranian nuclear facilities and banned Iranian nuclear investment in third countries;

—  banned exports of several major categories of arms, and further restricted Iran's ballistic missile programme;

—  froze the assets of 40 entities, including one bank subsidiary, several Islamic Revolutionary Guard Corps companies, and three Islamic Republic of Iran Shipping Lines subsidiaries, which had been involved in multiple sanctions violations cases;

—  froze the assets of and banned travel by one senior nuclear scientist;

—  implemented a regime for inspecting suspected illicit cargoes and authorising their seizure and disposal;

—  placed restrictions on financial services, including insurance and reinsurance, where there was suspicion of a proliferation link;

—  banned existing and new correspondent banking relationships where there were proliferation concerns;

—  established a Panel of Experts to advise and assist on sanctions implementation; and

—  reaffirmed the dual track strategy (of pressure and diplomacy).

19.3 Consequently, the EU implemented the measures contained in UNSCR 1929 and imposed additional EU sanctions in the following areas:

—  the energy sector, including the prohibition of investment, technical assistance and transfers of technologies, equipment and service;

—  the financial sector, including additional asset freezes against banks and restrictions on banking and insurance;

—  trade, including a broad ranging ban on dual use goods and trade insurance;

—  the Iranian transport sector in particular the Islamic Republic of Iran Shipping Line (IRISL) and its subsidiaries and air cargo; and

—  new visa bans and asset freezes, especially on the Islamic Revolutionary Guard Corps (IRGC).[88]

The most recent draft Council Decision and Council Implementing Regulation

19.4 This Council Decision and Council Implementing Regulation enabled the European Union to add further additional individuals and entities to the Annex of Council Regulation 960/2010, subjecting them to an assets freeze and travel ban.

19.5 In his Explanatory Memorandum of 24 November 2011,[89] Minister for Europe (Mr David Lidington) reiterated the Government's commitment to "tough additional EU sanctions against Iran, aimed at halting its proliferation sensitive activity and making it comply with its international obligations". He noted that:

"Iran has continued to flout its international obligations. As the November 2011 International Atomic Energy Agency report and the subsequent Board of Governors resolutions demonstrates, Iran continues on its path towards developing nuclear weapons capability. In response to this, HMG announced on 21 November that it was requiring the UK financial sector to sever all ties with Iranian banks, including the Central Bank of Iran, with immediate effect.

"The United Kingdom is determined to press for further robust action against Iran in the UN and EU to send a clear message to the Iranian regime that its continued violation of UN Security Council resolutions and Nuclear Non Proliferation Treaty obligations is unacceptable and that the Iranian government must resume serious and meaningful negotiations without delay.

"The designation by the European Union of further individuals and entities who contribute to the development of Iran's nuclear proliferation sensitive activity or those who assist in the circumvention of sanctions is an important step. The UK Government believes that targeting key individuals and entities is among the most effective measures to target Iran's proliferation sensitive activity. For individuals, in addition to the stigma of being internationally blacklisted, being subject to sanctions prevents travel to acquire new knowledge and contacts. The asset freezing of entities is an effective tool to impact the revenue available for proliferation sensitive activity and will also helped disrupt the transport of goods for use in Iran's nuclear programme.

"We are pressing for these measures to be backed with a further expansion of the scope of the EU sanctions, as mandated by Heads of Government in the Conclusions of the October European Council.[90]

"We remain clear that the dual track policy of pressure and engagement remains in place. Sanctions in place are targeted, proportionate and reversible. Iran is faced with a stark choice: further international isolation and increased economic pressure, or, respect for international obligations and the lifting of sanctions."

19.6 The Minister concluded by noting that the Council Decision and Regulation were due to be adopted at the 1 December 2011 Foreign Affairs Council.

The Minister's letter of 24 November 2011

19.7 The Minister wrote to express his regret that due the urgency of the measures to be adopted he found himself having to agree to the adoption of this Council Decision and Regulation before the Committee had had an opportunity to scrutinise the documents.

19.8 He then continued as follows:

"The recent November IAEA report[91] and the subsequent Board of Governors resolution[92] demonstrate the further progress of the possible military dimensions of Iran's nuclear programme. In the wake of the IAEA report the British Government acted on 21 November to sever all financial ties between the UK financial sector and Iranian banks. We believe it is an urgent priority that the European Union agree a robust response to Iran, including acting to prevent Iran acquiring the goods needed to develop its nuclear programme and halting the financial flows that fund the programme. The Decision and Regulation in question allow further entities and individuals to be subject to an assets freeze and travel ban in all 27 EU Member States. On 23 October, the European Council invited the Foreign Affairs Council to prepare new restrictive measures on Iran and we are, therefore, considering proposals in this regard in the finance sector, the transport sector and oil and gas sectors".

Our assessment

19.9 Although these measures raised no questions in and of themselves, we reported them to the House because of the importance of the political situation that had given rise to them.

19.10 We noted that relations between the United Kingdom and Iran had deteriorated drastically in the wake of the subsequent overrunning of the British Embassy compounds and Residence in Tehran and the consequent expulsion from the United Kingdom of all Iranian diplomats, and that on 1 December 2011, the Foreign Affairs Council had issued the following statement:

"The Council is outraged by the attack on the British Embassy in Tehran and utterly condemns it. It is a violation of the Vienna Convention. It also deplores the decision to expel the British Ambassador from Tehran. The Council considers these actions against the UK as actions against the European Union as a whole. The EU is taking appropriate measures in response."[93]

19.11 On the same day, the Foreign Affairs Council had also issued Conclusions that:

—  reiterated its serious and deepening concerns over the nature of Iran's nuclear programme, and in particular over the findings on Iranian activities relating to the development of military nuclear technology, as reflected in the latest IAEA report;

—  strongly supported the resolution adopted by the IAEA Board of Governors, which the Council says expresses deep and increasing concerns about unresolved issues and stresses the grave concern posed by Iran's continued refusal to comply with its international obligations and to fully co-operate with the IAEA;

—  confirmed that it had designated a further 180 entities and individuals to be subject to restrictive measures, which include entities and individuals directly involved in Iran's nuclear activities, which are in violation of UNSC resolutions; entities and individuals owned, controlled or acting on behalf of the Islamic Republic of Iran Shipping Line (IRISL); and members of, as well as entities controlled by, the Islamic Revolutionary Guards Corps (IRGC);

—  further agreed that, given the seriousness of the situation, including the acceleration of the near 20% uranium enrichment activities by Iran, in violation of six UNSC resolutions and eleven IAEA Board resolutions, and the installation of centrifuges at a previously undeclared and deeply buried site near Qom, as detailed in the IAEA report, the EU should extend the scope of its restrictive measures against Iran;

—  agreed to broaden existing sanctions by examining, in close coordination with international partners, additional measures including measures aimed at severely affecting the Iranian financial system, in the transport sector, in the energy sector, measures against the Iranian Revolutionary Guard Corps, as well as in other areas;

—  tasked preparatory Council bodies to further elaborate these measures for adoption, no later than by the next Foreign Affairs Council;

—  again reaffirmed the longstanding commitment of the European Union to work for a diplomatic solution of the Iranian nuclear issue in accordance with the dual track approach;

—  called upon Iran to respond positively to the offer of negotiations in the EU High Representative's latest letter by demonstrating its readiness to seriously address existing concerns on the nuclear issue;

—  reaffirmed that the objective of the EU remains to achieve a comprehensive and long-term settlement which would build international confidence in the exclusively peaceful nature of the Iranian nuclear programme, while respecting Iran's legitimate rights to the peaceful uses of nuclear energy under the NPT.[94]

19.12 In the meantime, we cleared the documents, and, in the circumstances and on this occasion, did not object to the Minister having agreed to their adoption prior to scrutiny.[95]

The Minister's letter of 18 January 2012

19.13 The Minister wrote to forewarn the Committee of what, by the time we were able to consider it, was then headline news: the imposition by the 23 January Foreign Affairs Council of further restrictive measures against the Iranian regime. As he anticipated, the Council:

—  banned the import, purchase and transport of crude oil and petroleum products from Iran into the EU as well as related finance and insurance; already concluded contracts can still be executed until 1 July 2012; a review will take place before 1 May 2012;

—  banned imports of petrochemical products from Iran into the EU;

—  banned exports of key equipment and technology for this sector to Iran;

—  banned new investment in petrochemical companies in Iran as well as joint ventures with such enterprises;

—  froze the assets of the Iranian central bank within the EU, while ensuring that legitimate trade can continue under strict conditions;

—  banned trade in gold, precious metals and diamonds with Iranian public bodies and the central bank;

—  banned the delivery of Iranian-denominated banknotes and coinage to the Iranian central bank;

—  banned a number of additional sensitive dual-use goods;

—  subjected three more persons to an asset freeze and a visa ban, and froze the assets of eight further entities.[96]

19.14 The Minister regretted and apologised for the scrutiny override (measures then still "subject to intense negotiations", could still change, and in any case were in many aspects classified to impede pre-emptive action), and undertook to submit whatever was finally agreed with an Explanatory Memorandum immediately after the FAC meeting.

19.15 The Minister also explained some of the Government's thinking, viz., that these strong additional sanctions were necessary to persuade the Iranian regimes to step away from its pursuit of its illegal nuclear programme, against a background that had not seen any positive moves from the Iranian regime in recent months, notwithstanding: the November 2011 IAEA report and the subsequent Board of Governors resolution (which set out further progress of the possible military dimensions of Iran's nuclear programme); the subsequent response by the Government on 21 November 2011 to sever all financial ties between the UK financial sector and Iranian banks; and the measures taken on 1 December 2011 by the EU against a further 200 individuals and entities. Instead, the Minister noted, this month Iran had demonstrated further defiance of its international obligations, by announcing the start of uranium enrichment at the Qom facility — which "provocative act further undermines Iran's claims that its programme is entirely civilian in nature" (the Foreign Secretary on 9 January).

19.16 The Council Conclusions[97] also note that Iran's acceleration of enrichment activities are "in flagrant violation of six UNSC Resolutions and eleven IAEA Board resolutions and contributes to increasing tensions in the region", and call upon Iran to fully cooperate with the IAEA, including in the context of the planned visit by its Deputy Director General for Safeguards. They also reaffirm the EU's longstanding commitment to work for a diplomatic solution to the Iranian nuclear issue in accordance with the dual-track approach; and that a comprehensive and long-term settlement which would build international confidence in the exclusively peaceful nature of the Iranian nuclear programme, while respecting Iran's legitimate rights to the peaceful uses of nuclear energy in conformity with the NPT, remains the EU's objective. The Council accordingly urges Iran to reply positively to the offer for substantial negotiations, as set out in the High Representative's letter of 21 October 2011, by "clearly demonstrating its readiness to engage in confidence building measures and, without preconditions, in meaningful talks to seriously address existing concerns on the nuclear issue."

19.17 In its response of 25 January 2012 the Committee asked the Minister, in his Explanatory Memorandum to put some flesh on these bones, for example, by outlining what key equipment and technology for the petrochemical sector, and which additional sensitive dual-use goods would be affected; and what sort of legitimate trade was envisaged, under what sort of strict conditions. We also asked how did these measures left British companies, both in the EU and in the USA, with regard to important oil exploration activities that had a degree of Iranian participation.

19.18 Also, looking at the Council Conclusions, we asked the Minister to explain not just the Government's thinking but also that of the Union as a whole. We noted that the Conclusions emphasised that a comprehensive and long-term settlement that would build international confidence in the exclusively peaceful nature of the Iranian nuclear programme, while respecting Iran's legitimate rights to the peaceful uses of nuclear energy in conformity with the NPT, remained the EU's objective; and that the Council also urged Iran to reply positively to the offer for substantial negotiations, as set out in the High Representative's letter of 21 October 2011, by "clearly demonstrating its readiness to engage in confidence building measures and, without preconditions, in meaningful talks to seriously address existing concerns on the nuclear issue." We suggested that the House would benefit from an explanation of what the HR's letter said, how these measures related to other international action (by the US and the IAEA), and how the EU action was likely to lead to constructive negotiation rather than — as some critics had already said — prompting the Iranian regime instead to "race for the bomb".

The further Council Decision, Council Implementing Regulation and Council Regulation

19.19 In his Explanatory Memorandum of 30 January 2012, the Minister for Europe (Mr David Lidington) explains these measures as follows:

"The Council Decision under scrutiny introduces the following new measures against Iran:

"Energy sector

- Prohibition on the import of Iranian crude oil and petroleum products. It will also be prohibited to provide financial assistance related to the import, purchase or transport of Iranian crude oil or petroleum products. There will be a phased implementation, whereby existing contracts will be allowed to continue until 1 July 2012. There will be a review of this measure by 1 May 2012.

- Prohibition on the import of Iranian petrochemicals. The Decision prohibits all news contracts, but allows for existing contracts to continue for a period of three months.

- Prohibition on the sale of key equipment to, the import from, and the investment in, the Iranian petrochemical sector. The Decision will allow Member States to develop a list of key equipment, which will be adopted in the Council Regulation, which will now be negotiated.

"Financial measures

- Asset freeze on the Central Bank of Iran. Assets of the Central Bank will be frozen with immediate effect. But there will be exemptions for trade finance with non designated entities.

- Asset freeze against Bank Tejerat. Assets will be frozen immediately, but there will be a period of two months in which trade contracts will be able to continue.

- Prohibition on Iranian access to EU gold and precious metals markets and the transport to Iran of these goods.

- Prohibition on the export of printed, minted or unissued currency to Iran.

"Trade measures

- Additional dual use goods will be subject to a prohibition, where previously they were licensable by Member States.

"Action against the Iranian Revolutionary Guards Corps and companies involved in circumventing sanctions

- Amendment to the designation criteria. The Council will now be able to impose sanctions against any member of the Iranian Revolutionary Guard Corps or any individual or entity that provides support for the Iranian regime.

- In addition to the CBI and Bank Tejerat, a further 10 individuals and entities will now be subject to an asset freeze and travel ban.

"The Council Regulation implementing Regulation 961/2010 enables Member States to automatically freeze the assets of newly designated individuals and banks. This is necessary to prevent the risk of asset flight, because asset freezing is an EU competence.

"The Regulation amending Regulation 961/2010 gives legal effect to the exemptions against the Central Bank of Iran and Bank Tejerat. This will ensure that Member States are able to give effect to the measures as set out in the Council Decision i.e. to permit trade contracts to continue for a period of two months for Bank Tejerat and to allow the CBI to continue to provide trade finance for legitimate trade."

19.20 With regard to Fundamental Rights, the Minister says that:

—  the procedures for designating individuals are compliant with fundamental rights: provision is made for competent authorities of Member States to authorise the release of frozen funds where necessary in certain circumstances, for example, to satisfy the basic needs of listed persons or their dependents and where necessary for extraordinary expenses; decisions by competent authorities of Member States in this regard would be subject to challenge in Member State's courts; prohibitions on transfer of funds and financial services are exempted where necessary for humanitarian purposes, or where necessary for supply of foodstuffs, medical equipment or provision of health care; and provision is also made for exemptions to the travel ban on grounds of urgent humanitarian need;

—  the principal Decision and Regulation respect the fundamental rights and observes the principles recognised in particular by the Charter of Fundamental Rights of the European Union and notably the right to an effective remedy and to a fair trial and the right to the protection of personal data; and

—  the principal Decision and Regulation say that the Council shall provide designated persons and entities an opportunity to present observations on the reasons for their listing; that where observations are submitted, the Council will review its decision in the light of those observations and inform the person or entity concerned accordingly; and, in addition, the measures will kept under review.

The Government's view

19.21 The Minister goes on to comment as follows:

"The Government is committed to the dual track policy of increasing pressure against Iran in order to persuade it to negotiate seriously about its nuclear programme.

"In January, Iran announced that it had begun to enrich uranium to near 20% at its underground facility at Qom. This is the latest example of Iran continuing to choose a path of provocation. This is an enrichment programme that has no plausible civilian use, in a site that the Iranian authorities hoped to keep secret. The International Atomic Energy Agency has repeatedly expressed its concerns about the possible military dimensions of Iran's nuclear programme, including it its latest report of November 2011 and the subsequent Board of Governors resolution. In response to this report, HMG announced on 21 November 2011 that it was requiring the UK financial sector to sever all ties with Iranian banks, including the Central Bank of Iran.

"The new measures adopted by the EU on 23 January 2012 represent a significant strengthening of sanctions against Iran. They reflect growing concerns about the nuclear programme and determination to increase peaceful legitimate pressure on Iran to return to negotiations. As well as changing the political calculation for the regime, the sanctions are aimed at preventing Iran acquiring the goods needed to develop its nuclear programme and halting the financial flows that fund the programme. The oil import ban is particularly significant as the EU previously imported 20% of Iran's oil exports. The Government and EU partners have been working with consumer and producer countries around the world to ensure there is no shortage to EU markets and not to undermine the ban. The Council Decision will allow for prior contracts until 1 July 2012 to allow consumers and markets to adjust. And there will be a review of the measure no later than 1 May 2012.

"The new sanctions also restrict the EU's financial cooperation with Iran and protect the EU financial sector from Iran's illicit financial activity. Bank Tejerat was the last major Iranian bank operating in the EU. And while the EU has taken the decision not to impose a full restriction on all ties with the Central Bank of Iran, the asset freeze sends a clear signal that this option remains on the table. Another strand of this latest sanctions package is action against the IRGC, who have become increasingly prevalent in the Iranian economy and are closely associated with decision making on Iran's nuclear programme.

"We remain clear that the dual track policy of pressure and engagement remains in place. Sanctions in place are targeted, proportionate and reversible. Iran has the power to end sanctions and further international isolation by changing course."

19.22 The Minister concludes by noting that the Council Decision and implementing and amending Regulations were adopted at the Foreign Affairs Council on 23 January 2012.

The Minister's letter of 30 January 2012

19.23 In response to the Committee's letter of 25 January 2012, the Minister says that:

—  with regard to the Committee's questions on details of key equipment for the petrochemical sector and on additional dual use goods to be prohibited, these issues will be addressed in a further Regulation that will be under negotiation in the EU in the coming weeks. The Regulation will implement those measures in the Council Decision that fall under EU competence. But it has been agreed to move over half of the dual use goods items that were previously subject to licensing in the EU to a full prohibition. In addition, he has proposed some 36 further dual use goods be added to the EU Annex that requires licensing;

—  with regard to the restrictions against the Central Bank of Iran, the measure requires all EU Member States to freeze the assets of the bank with the Union; but will allow funds frozen after the date of designation for non-sanctioned trade and its trade finance function to continue, with the proviso that this does not take place with designated entities and is authorised by competent authorities, on a case by case basis;

—  with regard to the impact of the oil measures on British companies involved in joint ventures with Iranian entities, in the lead up to agreeing these measures in the EU the Government has consulted closely with industry and with the range of interested Government Departments to ensure that it understood "the impacts for UK Plc"; the EU measures will not hit joint ventures in third countries, though any interests in Iran or involving designated entities will no longer be able to continue in their current form. The Minister does not anticipate any impact from these new EU sanctions on the strategically important Shah Deniz joint venture in the Caspian Sea;

—  "The EU has liaised closely with international partners on these measures, including the US. The recent 'Kirk-Menendez' amendment agreed by the US has the effect of requiring countries to make a 'significant reduction' of their Iran oil purchases over a 180-day period, starting from 31 December; this ties in closely with the EU timetable of banning Iranian oil by 1 July. We will be lobbying other countries globally to join the EU and US in these measures."

—  Baroness Ashton's letter of 21 October 2011 was released by her office into the public domain last week (which we reproduce at the Annex to this chapter of our Report);[98] the Minister adds that "we are still waiting for a response to this letter from Iran";

—  with regard to how the EU action is likely to lead to constructive negotiations, rather than "a race to the bomb":

"The government believes the dual track strategy of pressure and engagement is the policy most likely to lead to constructive negotiations with Iran. The EU action is fully in line with that strategy. As the Foreign Secretary said in the house on 24 January,

'If there were a reasonable hope of [another] policy succeeding, of course there would be a case for it. In the Foreign Office, I regularly review our overall policy and the alternatives to it. However, at every stage, I and my colleagues on the National Security Council reached the view that this is the right policy, as have the Governments…of the entire western world.'"

Conclusion

19.24 We are grateful for the Minister's endeavours to be as forthcoming as he can in what the Committee acknowledges are very challenging circumstances, and on this occasion and in these circumstances, does not object to his having over-ridden scrutiny.

19.25 Although the documents raise no issues in and of themselves, we are again reporting these developments to the House because of the widespread interest in relations between the West and Iran, and are otherwise content for Members to use the many means at their disposal to pursue these matters further, should they so wish.

19.26 We now clear the documents.


87   See headnote. Back

88   For further information, see "FACTSHEET The European Union and Iran" at

http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/EN/foraff/127511.pdf. Back

89   See (33388) - and (33389) -: HC 428-xliii (2010-12), chapter 23 (17 December 2011) Back

90   The European Council's Declaration is reproduced at the Annex to this chapter of our Report. The European Council Conclusions are available at http://register.consilium.europa.eu/pdf/en/09/st15/st15265.en09.pdf. Back

91   Available at http://www.guardian.co.uk/world/interactive/2011/nov/09/iran-nuclear-programme-iaea-report. Back

92   According to the IAEA Division of Information: "At the end of deliberations beginning 17 November, the IAEA Board of Governors adopted a resolution on the Implementation of the NPT Safeguards and Relevant Provisions of the UN Security Council Resolutions in the Islamic Republic of Iran.

"The resolution expresses deep and increasing concern about the unresolved issues regarding the Iranian nuclear program, including those which need to be clarified to exclude the existence of possible military dimensions. It also stresses the need for Iran and the Agency to 'intensify their dialogue' aiming at the urgent resolution of all outstanding substantive issues for the purpose of providing clarifications regarding those issues.

"The resolution urges Iran once again to comply fully and without delay with its obligations under relevant resolutions of the UN Security Council, and to meet the requirements of the IAEA Board of Governors. Expressing continuing support for a diplomatic solution, the resolution calls on Iran to engage seriously and without preconditions in talks aimed at restoring international confidence in the exclusively peaceful nature of Iran's nuclear program.

"It further requests the Director General to include in his progress report to the March 2012 meeting of the Board of Governors an assessment of the implementation of this resolution.

"The resolution on the implementation of safeguards in Iran was adopted by a majority." See http://www.iaea.org/newscenter/news/2011/iran-resolution.html. Back

93   See http://www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/EN/foraff/126492.pdf. Back

94   See http://www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/EN/foraff/126493.pdf. Back

95   See headnote: (33388) - and (33389) -: HC 428-xliii (2010-12), chapter 23 (17 December 2011). Back

96   The Council statement is available at http://www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/EN/foraff/127444.pdf. Back

97   Available at http://www.consilium.europa.eu/uedocs/cms_Data/docs/pressdata/EN/foraff/127446.pdf. Back

98   Available at http://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/EN/foraff/127394.pdf. Back


 
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