VZCZCXRO3378
PP RUEHBC RUEHKUK RUEHTRO
DE RUEHRL #0216/01 0561643
ZNY CCCCC ZZH
P 251643Z FEB 10
FM AMEMBASSY BERLIN
TO RUEHC/SECSTATE WASHDC PRIORITY 6626
INFO RUCNFRG/FRG COLLECTIVE
RUCNIRA/IRAN COLLECTIVE
RUEHGG/UN SECURITY COUNCIL COLLECTIVE
RUEHLO/AMEMBASSY LONDON 0786
RUEHFR/AMEMBASSY PARIS 1305
RUEHHT/AMCONSUL HAMILTON 0010
RHEHNSC/NSC WASHINGTON DC
RUEATRS/DEPT OF TREASURY WASHINGTON DC
RUEHRN/USMISSION UN ROME
RUCNDT/USMISSION USUN NEW YORK 0929

C O N F I D E N T I A L SECTION 01 OF 02 BERLIN 000216 
 
SIPDIS 
STATE FOR EUR/CE PETER SCHROEDER 
STATE FOR ISN/CPI KEVIN MCGEEHAN 
 
E.O. 12958: DECL: 02/25/2035 
TAGS: EFIN ETTC KNNP PARM PREL UK IR FR GM
SUBJECT: GERMANY ON-BOARD TO CLAMP DOWN ON IRANIAN SHIPPING 
 
REF: STATE 16219 
 
BERLIN 00000216  001.2 OF 002 
 
 
Classified By: Economic Minister-Counselor Robert Pollard 
for reasons 1.4 (b) and (d). 
 
¶1.  (C) SUMMARY:  Germany supports sanctions against the 
Islamic Republic of Iran Shipping Lines (IRISL) along with 
its affiliates and views denying Iran access to 
insurance/reinsurance as an excellent vehicle to do so.  On 
February 23, Emboffs delivered reftel demarche to the German 
Ministries of Foreign Affairs (MFA) and Economics (BMWi). 
BMWi Desk Officer for Foreign Trade Law, Martin Lutz, said 
Germany is pressing its EU partners to designate IRISL and 
deny IRISL financial services with an emphasis on insurance. 
The MFA said denying IRISL port access because of 
insufficient insurance coverage was a topic of a February 24 
inter-ministerial discussion, but no final position has been 
made.  END SUMMARY 
 
 
GERMANY BEATING THE LET'S DESIGNATE IRISL DRUM 
--------------------------------------------- - 
 
¶2.  (C) Lutz thanked the USG for the reftel nonpaper and said 
the German intelligence (BND) had already sensitized German 
agencies that the Hafiz Darya Shipping Lines (HDSL) and 
"Pacific Shipping Lines" (NFI) were acting on behalf of 
IRISL.  Lutz said sanctioning Iran by designating IRISL and 
its affiliates is something Germany is strongly pushing for 
with its EU partners and voiced optimism on this prospect. 
In addition, Lutz said that Germany is examining a move to 
deny the ability of Iranian shipping lines to charter ships 
flying a German flag.  (COMMENT: The M/V Hansa India was an 
IRISL chartered German flagged ship interdicted last October 
and found to have been shipping UNSCR sanction munitions 
destined for Syria.  END COMMENT)  As an example of recent 
action Germany has taken against IRISL, Lutz said Germany 
recently revoked the registration of the Hansiatische Schif 
Gesellschaft, a company he claimed was acting as an IRISL 
alias. 
 
¶3.  (C) Lutz, repeating what MFA officials have also 
expressed, voiced concern about the UK's decision to 
unilaterally designate IRISL stating that this move might 
actually violate EU law.  He did not want this to cast an 
impression that Germany was in any way opposed to an IRISL 
designation, only that Germany's preference would have been 
for a unified EU designation.  (COMMENT:  In a separate 
conversation, UK Poloff at the British Embassy in Berlin, 
told Econoff the UK's decision to go with unilateral action 
on IRISL stemmed from UK counter terrorism legislation and 
rejected the notion that it violated EU law.  END COMMENT) 
 
 
GERMAN INSURANCE GIANTS TO REJECT NEW IRANIAN BUSINESS 
--------------------------------------------- --------- 
 
¶4.  (C) During the week of February 15, German Insurance 
Giants Munich Re and Alliance announced their intention to 
suspend new reinsurance business with Iran and not renew 
expiring policies.  Hannover Re, the world's 4th largest 
reinsurer, took a softer tone and announced that it would 
renounce Iranian business in compliance with any new UN or EU 
Iranian sanctions.  Lutz, indicated that these seemingly 
coordinated announcements were no accident, and said that the 
German Finance Ministry sent a letter to the German Insurance 
Association last November requesting that German insurers not 
fill the void created by the UK government's decision not to 
insure IRISL.  (COMMENT: This presence of this letter was 
confirmed by MFA Director General von Fritsch in a meeting 
with EMIN on February 24.  END COMMENT)  Lutz said the 
genesis of the letter resulted from a meeting between BMWi 
Office Director for Foreign Trade, Wendling, EMIN, and his 
British counterpart in the wake of the UK's IRISL 
designation.  Lutz noted specifically that EMIN had impressed 
upon Wendling the importance that Iran not be able to turn to 
German insurers to replace dropped policies from Lloyd's of 
London. 
 
 
DENYING PORT ACCESS IS UNDER CONSIDERATION 
 
BERLIN 00000216  002.2 OF 002 
 
 
------------------------------------------ 
 
¶5.  (C) On the issue of denying IRISL German port access, 
Lutz was unclear about the legal situation regarding private 
German ports and underinsured ships making port calls.  He 
said that this may well be a matter for the ports themselves 
or the Ministry of Transportation to decide on, but undertook 
to seek further clarification on this issue.  In a subsequent 
conversation, MFA official acknowledged that as a result of 
reftel points this issue had been brought up in an 
inter-ministerial meeting and the GoG was still formulating 
its position. 
 
 
COMMENT 
------- 
 
¶6.  (C) Targeting Iranian access to insurance and a future 
IRISL designation appear to be an easy sell to Germany.  The 
German decision to apply "moral-suasion" to its insurance 
industry and the positive resultant response was a firm step 
in the right direction and demonstrates that the GoG's 
moral-suasion policy can be effective with specialized 
industries. 
Murphy