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The payments channel Europe built and never used

In 2019 three of Europe’s largest economies built a mechanism to trade around US sanctions. Its near-total failure is the clearest lesson in dependency Europe has.

Martin Foerster
Co-founder
· 2 min read

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Some of the most instructive failures never make the headlines. In 2019, France, Germany, and the United Kingdom jointly created a company called INSTEX, short for the Instrument in Support of Trade Exchanges. Its purpose was narrow and deliberate: to let European firms continue trading with Iran, in commerce their own governments considered lawful, without passing through the US financial system that Washington had closed to them.

A mechanism backed by three governments

This was not a fringe initiative. Three of Europe’s largest economies, acting through their finance ministries, stood up a dedicated payments channel for the express purpose of routing around American sanctions. The political will was real, the legal basis was sound, and the institutional weight behind it was considerable. By any measure of intent, Europe was serious.

Almost nothing went through it

INSTEX processed a handful of transactions and effectively nothing of consequence. It was quietly wound down in 2023, having demonstrated the opposite of what it set out to prove. The reason was not a legal defect or a technical failure. It was that no serious European company would use it, because the risk of losing access to US banks and the dollar dwarfed whatever value the Iran trade offered.

Definition
Structural dependency
A dependency is structural when you feel it only at the moment you try to act against it. Washington did not need to block INSTEX. Its existence was enough: every company weighing the channel concluded on its own that the exposure was not worth it, and the mechanism starved.

The lesson worth carrying forward

INSTEX is the cleanest evidence Europe has that political will and legal cover are not the same as independence. A continent can have the institutions, the funding, and three governments behind an alternative and still find that no one dares to use it, because the underlying dependency does the disciplining without anyone issuing an order. That is why European sovereignty is not merely protectionism dressed up in principle. The people who lived through the SWIFT and INSTEX years are not being cautious for its own sake. They are being precise about a lesson they have already paid for, and it applies to every layer where Europe now finds itself dependent, including the software that reads its laws.