The Situation in the Gulf Debate
Full Debate: Read Full DebateLord Ahmad of Wimbledon
Main Page: Lord Ahmad of Wimbledon (Conservative - Life peer)Department Debates - View all Lord Ahmad of Wimbledon's debates with the Foreign, Commonwealth & Development Office
(5 years, 5 months ago)
Lords ChamberMy Lords, with the leave of the House, I shall now repeat a Statement given in the other place on the situation in the Gulf:
“At approximately 4 pm UK time on Friday, Iranian forces intercepted the British-flagged tanker, “Stena Impero”, in the Strait of Hormuz. The ship was surrounded by four fast boats from the Revolutionary Guard, supported by one helicopter. Iranian footage showed masked gunmen in desert camouflage descending from the helicopter on to the deck of the “Stena Impero”.
HMS “Montrose”, a Royal Navy Type 23 frigate currently deployed in the Gulf, tried to come to the tanker’s aid. She repeatedly warned the Iranians by radio that their actions were illegal, but “Montrose” was unable to reach the scene in time. Nine days earlier, she had successfully intercepted an attempt to board another tanker, “British Heritage”, but this time “Montrose” was not given the notice of passage requested, which would have allowed her to reach the scene more quickly. This, however, in no way excuses the illegal actions of the intruders, who took control of “Stena Impero” and compelled her to steer towards the Iranian port of Bandar Abbas, where she is now being held.
The tanker had a crew of 23 from various countries, including India, the Philippines, Russia and Latvia. No Britons were on board and there are no reports of any injuries. The vessel’s owners have confirmed that “Stena Impero” was exercising her legal right of transit passage when she was intercepted. She was passing through the Strait of Hormuz in the westbound traffic lane inside Omani territorial waters, in full compliance with international law and the rules of navigation. The tanker’s automatic identification system was switched on and her position was publicly available.
So let us be absolutely clear: under international law Iran had no right to obstruct the ship’s passage, let alone board her. It was therefore an act of state piracy, which the House will have no hesitation in condemning. But even more worryingly, this incident was a flagrant breach of the principle of free navigation on which the global trading system and the world economy ultimately depend. I therefore urge Iran to release the “Stena Impero” and her crew and observe the rules that safeguard commercial shipping and benefit Iran as much as any other country.
Iran has tried to present this as a tit-for-tat incident following the Government of Gibraltar’s action on 4 July to enforce EU sanctions by preventing the Iranian-chartered tanker, “Grace 1”, supplying oil to Syria. But there is simply no comparison between Iran’s illegal seizure of a vessel inside a recognised shipping lane, where the “Stena Impero” had every right to be, and the enforcement of EU sanctions against a tanker that had freely navigated into the waters of a British Overseas Territory.
Since 4 July we have made strenuous efforts to resolve the “Grace 1” issue. On 13 July, I spoke by phone to the Iranian Foreign Minister, Javad Zarif, and also made it clear in public that we would be content with the release of “Grace 1” if there were sufficient guarantees the oil would not go to any entities sanctioned by the EU. But instead of responding constructively Iran chose to seize the “Stena Impero”, so we must now take appropriate action to support the safe passage of vessels through the Strait of Hormuz.
As well as speaking again to my Iranian counterpart, I have also spoken this weekend and today to the Foreign Ministers of Oman, the United States, France, Germany, Italy, Finland, Spain and Denmark. COBRA meetings were held this morning and throughout the weekend, and the chargé d’affaires at the Iranian embassy in London was summoned to the Foreign Office on Saturday to receive a formal protest.
I can today update the House on further action we are taking. First, the Department for Transport has raised the security level for British-flagged shipping to level 3, advising against all passage in Iranian waters and, for the moment, in the entire Strait of Hormuz.
Secondly, because freedom of navigation is a vital interest of every nation, we will now seek to put together a European-led maritime protection mission to support safe passage of both crew and cargo in this vital region. We have had constructive discussions with a number of countries in the last 48 hours and will discuss later this week the best way to complement this with recent US proposals in this area. The new force will be focused on free navigation, bearing in mind that one-fifth of the world’s oil, a quarter of its liquefied natural gas, and trade worth half a trillion dollars pass through the Strait of Hormuz every year. It will not be part of the US maximum pressure policy on Iran because we remain committed to preserving the Iran nuclear agreement.
Thirdly, while we will seek to establish this mission as quickly as possible, the Government have in the meantime dispatched HMS “Duncan”—a Type 45 destroyer—to take over from HMS “Montrose”. She will arrive in the region by 29 July.
Fourthly, we will ask all British-flagged ships to give us notice of any intention to pass through the Strait of Hormuz to enable us to offer the best protection we can. We will then advise them as to the safest way to transit, which may involve travelling in convoy.
Finally, we are strengthening measures to protect ships flying the flags of other countries, but which have British crew on board. About 1,300 ships appear on the UK Ship Register. The combined British Red Ensign fleet is the ninth largest in the world. On an average day, two or three ships belonging to the Red Ensign group pass through the Strait of Hormuz. The Gulf spans an area of nearly 100,000 square miles. HMS “Montrose” covers an operating area of some 19,000 nautical miles. So far, she has escorted 30 merchant vessels through the Strait of Hormuz during 17 separate transits, travelling 4,800 nautical miles in the process. It is of course not possible for the Royal Navy to provide escorts for every single ship or indeed to eliminate the risks of piracy. But those risks can be substantially reduced if commercial shipping companies co-operate fully with the instructions from the Department for Transport, which we strongly encourage them to do. These changes, both short and medium term, are made possible because of the commitment this Government have already made to increase our security presence in the Gulf including the opening, in April last year, of the first permanent British naval facility in the Gulf for over 40 years. This establishment in Bahrain now hosts HMS “Montrose”, along with four mine countermeasure vessels and one supply ship.
Finally, let me say this: it is with a heavy heart that we announce this increased international presence in the Gulf, because the focus of our diplomacy has been on de-escalating tensions in the hope that such changes would not be necessary. We do not seek confrontation with Iran and have taken every available opportunity to reduce misunderstanding, while standing by our rock-solid commitment to the international rule of law, which is the foundation of global peace and prosperity. But we must also react to the world around us as it is, not how we would wish it to be. So if Iran continues on this dangerous path it must accept that the price will be a larger western military presence in the waters along its coastline, not because we wish to increase tensions but simply because freedom of navigation is a principle which Britain and its allies will always defend.
I commend this Statement to the House”.
My Lords, I thank the Minister for repeating the Statement. We must always uphold international law and freedom of navigation. This is an extremely dangerous situation. The region is a tinderbox. Many have said that Trump pulled out of the Iran nuclear deal and imposed further sanctions simply because Obama had signed the original deal. The President may not want a war but some of those around him are far more hawkish. That must cause us enormous concern, so can the Minister comment on where these developments leave the European determination to maintain the nuclear deal? Why did the UK decide to play a part in intercepting the Iranian tanker off Gibraltar, and, as mentioned by the noble Lord, Lord Collins, why did Gibraltar suddenly put in place sanctions legislation? Who proposed that that was suddenly needed, and why? What role might the US office for foreign asset management have had recently in advising the FCO on sanctions targets?
Can the Minister give us examples of previous incidents where our military or Navy have been used in sanctions enforcement which involved boarding and seizure? If we were to take such an action, what preparations have we already made—the noble Lords, Lord West and Lord Collins, have flagged this up—to protect ships flying under our flag that might then, predictably, be intercepted by the Iranians? Does the Minister agree with his colleague, the Defence Minister Tobias Ellwood, that the Navy is too small for a global role? Is the noble Lord, Lord West, not right to have warned time after time that our Navy is too small?
The position of this ship was publicly available, so what should we think of the UK as a global power when, at only the second attempt at an interception, a ship sailing under our flag was diverted and detained? Can the Minister say why the Department for Transport has only just raised the security level to 3 for ships sailing under our flag? Why is a European-led maritime protection mission only now being sought? Why was this not done before the “Grace 1” tanker was seized in Gibraltar? How optimistic is he that, in the middle of our battle over Brexit, such a mission will be forthcoming? Does he agree that our sanctions work best as part of multinational efforts, and that unilateral effort makes little sense?
Is it true that we feared American assistance, lest we ended up taking a more aggressive stance than we wished? That seems to be reflected in the statement that we will not be part of the US maximum pressure group. Does the whole situation not show that the UK is likely to be buffeted in the future, if we leave the EU, between a volatile ally and others, and that we are taking Gibraltar down that path? We have been unable to defend a ship sailing under our flag, and today we hear that Nazanin Zaghari-Ratcliffe has been transferred back to an Iranian prison. How are we defending her in this dangerous situation? We are appearing to warn against any passage through the straits, despite the huge value of that trade and the economic impact. Does the Minister not agree that this whole situation shows how vital it is to be part of a global bloc, and that any increase in defence spending will hardly make us a global player to rival the superpowers or, in fact, the EU? Therefore, we must work with everybody to de-escalate the situation and bring about a negotiated resolution, not only to this specific situation, but to the wider crisis affecting Iran and the region.
My Lords, first, I thank the noble Lord, Lord Collins, and the noble Baroness, Lady Northover, for their support for the main thrust of the Statement. They raised a raft of questions, which I will seek to answer. If I am unable to do so in the time allocated, I will write, because both raised some specific questions.
On the final point made by the noble Baroness, again, the Government’s response demonstrates the importance of working with our European partners. I do not share her belief that that has been sanctioned because we are members of the European Union. We are leading members of NATO. This morning, for example, I attended a briefing with the Baltic and Nordic ambassadors where, again, our co-operation, not just in maritime security but in other areas, was underlined by all the people around that table, not just by me, representing the British Government. It is important that we continue to work, but in a different way once we have left the European Union, and strengthen our co-operation over a raft of different areas. This example of maritime security is one such area.
The noble Lord, Lord Collins, raised various questions about direct engagement with Iran. He is right to mention that the Revolutionary Guard boarded the vessels. We deal with representatives of the Iranian Government at the highest level and, over the weekend, as the Statement said, my right honourable friend the Foreign Secretary continued to liaise and discuss with Foreign Minister Zarif.
The noble Lord and the noble Baroness talked about the action and asked: why now and not before? We have taken action, as the Statement indicated. HMS “Montrose” had already intercepted and prevented a similar incursion on “British Heritage” on 10 July. Equally, it has been a twin-track approach. I am sure the noble Lord and the noble Baroness will agree that, with the current backdrop of the region, we have sought to strengthen our diplomatic engagement with Iran, together with our European partners. This reflects the approach we have taken. We have continued to allow space for diplomatic dialogue.
The noble Lord and the noble Baroness mentioned “Grace 1”, which is the Iranian vessel that has been detained. There are some crucial facts. First, “Grace 1” was in Gibraltar’s territorial waters. The British-flagged ship “Stena Impero” was in Omani territorial waters, so the basis for any intervention is very different. Secondly, Iran has acted unlawfully, according to the law of the sea. Iran has acted illegally. Our detention of the ship was on suspicion of cargo being carried by “Grace 1” that was headed for Syria, breaking EU sanctions. I am sure the noble Lord and the noble Baroness have followed the countless attempts we have made to get guarantees from the Iranian Government that would allow the Gibraltese authorities to release “Grace 1”. We had to be given the assurance that it did not contravene the EU sanctions that had been imposed on Syria, but this was not forthcoming. It was disappointing that, while these negotiations were continuing with the Iranian Government directly, this action was taken. Iran describes this as tit for tat; the fact is that detaining the “Stena Impero” was not legal. It acted unlawfully.
The noble Lord, Lord Collins, asked a specific question about Turkey. I will write to him on that. He also raised the crew and our discussions with other countries, on which the noble Baroness also touched. I assure noble Lords that we are in touch, either at ministerial or official level, with all countries with crew on that ship. I understand that India has been in direct contact with the Iranians over its crew members, but we are also engaging with India at official level. I assure noble Lords that, while this is a British-flagged ship, our main concern is the safe return of not just the vessel but all crew members on it. I assure both the noble Baroness and the noble Lord that we are liaising with all parties in this respect.
The noble Baroness also raised the issue of the Department for Transport increasing security only now. I am sure she accepts how, as I alluded to earlier, we have taken the twin-track approach of diplomacy and increasing pressure. I assure the noble Baroness, and the noble Lord, Lord Collins—who both raised these issues—that we have detached this from the JCPOA and the detention of British nationals in Iran. We have not stopped our efforts on these two or three issues and have assured the Iranians that we do not link them in any way. However, the fact that the Iranians have acted in this way does not help the situation or the environment in which we operate.
We continue to work closely with our European colleagues, as on the European initiative on maritime security. We are talking to our French and German colleagues, as well as other European partners. Of course, we are liaising with the United States, but this initiative will be led by us, together with our European partners. There may be some specific questions I have been unable to answer but, after reviewing them, I will write to both the noble Lord and the noble Baroness.
My Lords, I thank my noble friend for repeating the Statement and answering these detailed questions thoroughly. I will press him further on two points; first, the seizure of “Grace 1”. Although we may have a completely different view legally—I believe ours is correct—was it appreciated before that was authorised that it would be regarded as piracy by the Iranians and that there was bound to be an attempt to retaliate? Was there diplomatic discussion before the seizure was authorised and were all diplomatic channels exhausted before that action was taken? However we look at it, it was, in effect, throwing a lighted match into an already dangerous sea.
On the statement that the Government will discuss later this week the best way to complement their plans with recent US proposals in this area, can the Minister be a little more explicit about what that involves, given that US policy and objectives at the moment are very different from ours? Beyond the general aim of preserving freedom of navigation on the high seas, which is vital, with what “recent US proposals” will we be co-ordinating?
I thank my noble friend for his questions and comments on the Statement and responses given. On “Grace 1”, the UK Government did a great deal to keep the diplomatic track alive. For example, my right honourable friend the Foreign Secretary and the Chief Minister of Gibraltar talked to each other on 13 July. My right honourable friends the Foreign Secretary and the Prime Minister met the Chief Minister when he visited the UK on 17 July. There was also a meeting between the Chief Minister and Iranian embassy officials. However, the detention of “Grace 1” was based on our belief that the cargo being carried was bound for Syria in defiance of EU sanctions. We have subsequently sought assurances from the Iranian Government.
We were in the midst of those negotiations when we saw this response to the action taken by the Gibraltar authorities. That is why we have deployed assets to the region. “HMS Montrose” and “HMS Duncan”, now going to the region, have been deployed to provide secure passage through the Strait of Hormuz. We have stepped up our efforts following Iran’s actions and will continue to review all elements of our policy regarding our exchanges with Iran, but we keep that diplomatic channel open.
My noble friend asked also about current US proposals. One proposal looks at the current combined taskforce in the region, which goes under the label of CTF 150 and has a mandate specifically to tackle terrorism and the illicit drugs trade. We are proposing an operation around maritime security. We are working on the details of that with our European colleagues.
My Lords, I have two questions for Minister. First, I think I am right in saying that the pretext offered to begin with for the arrest of the vessel was that she had been involved in some way in an incident with a fishing boat. Have steps been taken to find out whether there is any truth in that allegation and, if so, what was the result of that investigation?
Secondly, we have all seen the pictures of the way in which the vessel was taken control of by the Iranian forces. What rules of engagement, if any, have been provided for the Royal Navy in deciding how to manage an incident of that kind? It is extremely important for obvious reasons to minimise the risk of armed force being used, but it is extremely difficult to know what the Royal Navy is to do if it finds a vessel of that kind surrounded by small boats and people landing by helicopter on its deck. Can the Minister assure us that some attention will be paid to the rules of engagement and that they will be kept under careful review to minimise the risk of armed conflict at all costs?
The noble and learned Lord raises two important questions. On the first, when the “Stena Impero” was detained, it was empty. It was in Omani waters and there was no attempt to transcend international maritime boundaries. That is why we believe that the action taken by the Iranians was unlawful.
The noble and learned Lord referred to terms of engagement. We keep them under constant review. I am sure that he will appreciate that we cannot go into their detail, but I can assure him that the Ministry of Defence—which is proud of all our sailors and all our military, whichever force they represent—always acts in accordance with international law and upholds the laws of the sea through UNCLOS. The noble Baroness, Lady Northover, referred earlier to the size of the military and our assets. We will always strive to put diplomatic channels up front, but given the challenges faced by our Navy and the changing nature of our world and our environment, I think that there is a requirement to invest more in our naval assets to ensure that we can provide the protections needed.
My Lords, I welcome the commitment given in the Statement that the new force will not be part of the US maximum pressure policy on Iran. That will help to defuse the situation, but I have two brief questions for the Minister. First, he said that we are putting together a European-led maritime protection mission. Can he indicate how long he thinks it will be before the mission is completely operable?
Secondly, the Statement said that “HMS Duncan” is to “take over” from “HMS Montrose”. Does that mean that “HMS Montrose” will be standing down—in other words, we will again be reliant on only one vessel to cover the expanse of the Strait of Hormuz—or that “HMS Duncan” will supplement and augment the work of “HMS Montrose”?
On the second point, I shall write to the noble Baroness. We are reviewing all our military assets. “HMS Montrose” has been deployed for a while in the region; “HMS Duncan”, on arriving, will immediately take over the operations of “HMS Montrose”.
On how we further bolster military assets, we are looking at that carefully. It is directly linked to the noble Baroness’s first question, on the operability of the current scheme. I can assure her that we are working closely with colleagues, particularly our French and German colleagues, to see how quickly we can make this proposal operational. The noble Baroness will have heard in the Statement the series of steps that we have taken. We continue to work with the maritime industry and are keeping it informed. On the commercial side, I stress again that any ship seeking or planning to navigate the Strait of Hormuz should inform us in advance so that we can provide all appropriate protections. That includes working with our key European partners in the region.
My Lords, I was initially concerned about the Statement, in particular the contacts made by the Foreign Secretary over the weekend. It mentioned eight countries, with Iran’s Foreign Minister making it nine, but not India. I was significantly more encouraged by my noble friend’s response to the question asked by the noble Lord, Lord Collins. Can he confirm press reports in India that, of the 23 crew, 18 are Indian citizens? If so, does he accept that India is a critical Commonwealth partner for us in resolving this dispute, not only because it has so many of the crew but because of the strong historical and cultural ties between India and Iran and because India is the third largest consumer of oil and one of the largest receivers of gas and oil through the Strait of Hormuz? Could India not be an important partner in mediating a peaceful resolution to this dispute?
I agree with my noble friend. I reassure him that we have reached out to our Indian counterparts as part of wider engagement on this issue. We wish to ensure that anyone who can help de-escalate the current tensions is fully engaged. I agree with my noble friend also on the strength of our relationship with India, historically, currently and into the future, and on the importance of its presence in the region given its bilateral relationship with Iran. For all those reasons, India has an important role to play in de-escalating not just the current crisis but further tensions in that region.
My Lords, there is an issue that the Minister has not addressed: incompetence. Everybody in this Chamber thought, when the Iranian tanker was seized, that it was inevitable that Iran would respond in the way it has. It seems to me that the Government were completely distracted and are weak at this moment because of the various negotiations going on over Brexit. It was good to see the good support coming from Germany and France this weekend, but the Government have been incompetent in allowing this to happen with one naval vessel available. What was the action; what discussions took place in COBRA anticipating this would happen? Why did the Government not act to deal with it?
I am sorry, but I disagree with the noble Lord. The fact is that the Government did act. As I have already said quite succinctly, the fact that we did engage early on, in terms of assets in the region, prevented the impeding of the passage of a British-flagged commercial vessel, “British Heritage”, on 10 July. If the noble Lord feels that keeping diplomatic channels open is not a valid way of ensuring that we bring tensions down, then I again disagree with him. We have had a dual-track approach on this, ensuring that we can bring tensions down. The deployment of a large number of military assets into the Gulf, particularly around the Strait of Hormuz, which is a very small shipping channel, without fully exhausting diplomatic channels, would have been the wrong way to go about this.
Despite the political backdrop of Brexit, the Government continue to operate. The noble Lord shakes his head: perhaps he is casting doubt on my own efforts. I assure him that as a Minister of State at the Foreign Office, I and many other Ministers from the Ministry of Defence and other colleagues continue to ensure that we represent British interests to the best of our abilities. We will continue to work with Iran to ensure that tensions are decreased, to engage through diplomatic channels and to exercise our right to ensure that any vessel, British flag carrier or otherwise, is provided the protection it needs to ensure it can navigate the Strait of Hormuz. To say that we took our eye off the ball is inaccurate and I do not agree with the noble Lord.
My Lords, the noble Lord has just listed a series of diplomatic initiatives taken with Iran over the last few days and the last few years and said that Iran had behaved in an unacceptable fashion. Is it not the case that not a single one of those initiatives had any success whatever? It has been a complete and utter blank. To say, “Well, we needed to exhaust diplomatic initiatives before we did anything else”, is simply absurd in the light of the record we are facing today.
The Minister has also made the most momentous revelation today in the House, which is that we have only one frigate in the Gulf and will be able to maintain only one frigate in the Gulf, because when “Montrose” is relieved she will not be replaced. That is an absolutely devastating indictment of this Government’s record in defending our shipping interests around the world. When I was in the MoD we had 17 escorts: I think we now have 13 and the number is going down. It is a quite disgraceful record. My noble friend Lord West is absolutely right about this and it is about time that the Government did something about it.
This is a very troubling, alarming situation. We find ourselves, quite extraordinarily, in a military confrontation with Iran into which we have walked without any idea at all what we were doing. There was no planning at all, no one seems to have given any thought to what the consequences might be of an aggressive enforcement of Syrian sanctions on Syria’s trading partners—not least Iran—and we find ourselves in a shambles. The Government are good at running a shambles, we know that, and this is a particularly dangerous one. In my view, the only thing we can do in these difficult circumstances is to concentrate our naval resources, as far as we can, through the use of the convoy system, but we must urgently build, and not just build, but buy, more escorts for the Royal Navy, with a full range of capability—anti-submarine, surface-to-air and surface-to-surface, because the Minister has revealed today that gunboats were responsible for this latest incident. The surface-to-air must include a ballistic capability, because the Iranians have ballistics. It is a very worrying situation, and we need to respond with great urgency to deal with it.
First, suffice it to say that I disagree with the noble Lord. On the issue of our naval assets, I have already said, in response to a question from the noble Baroness, Lady Northover, that I accept that, in the changing environment in which we operate, it is important that we invest more in our defences and in the Navy. Indeed, my right honourable friend the Foreign Secretary also made this point. The noble Lord says that every diplomatic channel has been exhausted. Again, I am very saddened by what he said. I know he has insight and experience, but to my mind it is important that we keep diplomatic channels open: it is only because we have kept diplomatic channels open, working with our European partners, that the JCPOA has continued. While challenges remain on that, we are working with our European partners, through diplomatic channels, to ensure that a mechanism is in place to relieve some of the issues of the sanctions that are felt by the Iranian people.
The noble Lord raised the issue of operations. As I said, we are keeping things under review. I am not going to give chapter and verse from the Dispatch Box on every single movement of every asset of our military, nor would he expect me to do so, with his experience. There was a particular question raised about two of our vessels, which I have answered. We will keep the situation in the Gulf under review. Of course, we are not the only country; we are working in partnership with allies, including our European partners who also have assets in the region. There is one point on which I agree with the noble Lord: in the current climate it is important that we look at providing protection to all commercial vessels passing through the Strait of Hormuz. He suggested a convoy and that seems an inherently sensible proposal. It is being looked at, along with other ways of providing support and security for any vessel passing through there, but we must continue not only to support the vessels but to find a sustainable, peaceful outcome and to place emphasis on diplomatic channels. More than anything else, it is now for Iran to release the vessel “Stena Impero” and ensure that the crew are released. Several nationalities are represented in the crew of this ship, which is owned by the Swedes and flagged by the Brits, and which was in Omani waters. Iran has gone against UNCLOS. It needs to act now and release the vessel.
My Lords, I was particularly pleased to hear the commitment by the Minister to ongoing interaction with the Government in Tehran: that is very helpful. I have two questions. What is felt about where all this is heading? Is there a sense about what messages the Iranians are sending by their actions? If so, what are they, particularly in relation to the JCPOA? It would also be helpful if the Minister would confirm that these are EU-related sanctions. Intriguingly, if Brexit does indeed occur on 31 October, would the Gibraltarians legitimately enforce EU sanctions? What would happen if, on 1 November, we have left the European Union? Would the Gibraltarians be compelled to return the vessel anyway?
On the final, very practical question, my understanding is that we will be ensuring that there is no gap in enforcing sanctions, but that will require an agreement with our European partners. As I have said repeatedly on this issue of sanctions, it is absolutely inevitable and right that we continue to operate a co-ordinated sanctions strategy with our partners in Europe after we have left the European Union. Not doing so would mean that we would be unable—indeed, our European partners would be unable—to apply sanctions effectively. The noble Viscount asked a very practical question. It is certainly our intention that this will be the process, but it will require agreement between the European Union and the United Kingdom to ensure that there is no gap after we leave the EU.