Sanctions and bans

Status marks printed next to bank names on CBI bank-list pages; also "(ممنوع من التعامل بالدولار)" marks for USD-barred banks.

"Majid Ali Akbar Namdar Al-Mandalawi uses a variety of Iraqi private banks to transfer funding through his hawala ... used to remit millions of dollars from Iraq to Iran via the UAE." Banks not named.

CBI: imposing guardianship is a preventive supervisory measure; appointed guardian to manage withdrawals gradually.

Removal of Fly Baghdad designated 22 January 2024.

CBI statement confirms the understanding but does not name banks; names come from Asharq Bloomberg's anonymous CBI source. USD access NOT yet restored as of the statement.

Baghdad-registered company (est. 29 Jun 2025) linked to Alaa Hassan Hamieh.

Maarij accused by Treasury of diverting Iraqi oil products to benefit Salim Ahmed Said and AAH.

Operational commanders; not financial.

Six-month suspended prison sentence over money-laundering and financial violations; Integrity Commission reportedly recovered >IQD 1.3bn from a defendant linked to NBI's currency-auction participation.

Treasury: Muhandis General Company is controlled by PMC Chief of Staff Abu Fadak al-Muhammadawi and "uses a sub-contracting method to divert funds from Iraqi government contracts"; SDN entry: established 26 Feb 2023, state-owned enterprise.

"three Iraqi bank executives ... abusing their positions within Iraq’s commercial banking sector to benefit the IRGC-QF, Kata’ib Hizballah, and Asa’ib Ahl al-Haq". Treasury did not name the banks.

Context for later financial designations.

KRG MoF removed IDB from the MyAccount salary programme "following restrictions imposed by the Central Bank of Iraq (CBI) on US dollar transactions". The Arab Weekly (anonymous source): IDB "is restricted by the federal, but the Central Bank didn’t name it on its website."

Blending Iranian oil with Iraqi oil; ~$300m value annually to Iran and partners (Treasury estimate).

Part of a large Iranian oil/shipping network action.

Network selling Iranian oil falsely declared as Iraqi; Treasury says Said bribed members of Iraqi government bodies including parliament.

Reuters (two sources) reported the ban; CBI denied that US sanctions had been imposed (The New Arab, 17 February 2025). Status of implementation not confirmed by a primary document; Al-Mashreq Al-Arabi was later named (July 2026) among restricted banks cleared to return to non-USD channels. The Wall Street Journal (31 May 2025) later reported that the US Treasury 'blacklisted' three Iraqi card issuers suspected of militia ties, including Al Saqi Electronic Payment Company, without naming a legal instrument; no OFAC designation has been found.

Prohibits covered US financial institutions from opening/maintaining correspondent accounts for Al-Huda and requires steps to block indirect access.

CBI cancelled the branch licence citing losses, limited activity and "its inclusion in international sanctions" (Reuters quoting CBI document).

CBI list gives 29/1/2024 for all eight; Reuters reported the ban on 4 February 2024.

Designated for materially assisting the IRGC-QF; Treasury says Al-Huda used forged documents to execute at least $6bn in wire transfers out of Iraq.

FinCEN found Al-Huda to be a foreign financial institution of primary money laundering concern; proposed prohibition on correspondent accounts. The bank itself was NOT placed on the OFAC SDN list.

Awqad al-Hamidawi "directs KH’s businesses and aspects of KH’s financial portfolio ... manages KH’s money laundering operations"; Al-Massal used to generate revenue and launder money.

Dates printed 11/12/2023.

Militia leadership designations; not bank-specific.

Effective 20/7/2023 per CBI list. The 14th bank in the CBI document is "مصرف المال الاسلامي للاستثمار / Al Mal Islamic Investment Bank".

"The ban, which was imposed by the Treasury Department and the Federal Reserve Bank of New York, is part of a crackdown on the siphoning of U.S. currency to Iran" (Reuters summarising WSJ).

Effective date printed as 3/11/2022 for all four.

Effective date printed as 24/12/2020.

OFAC treats the renamed Al-Ataa Islamic Bank as the same designated entity.

One of 18 Iranian banks designated; SDN address = Building 59, District 929, Street 17, Arasat al-Hindia, Al-Masbah, Baghdad (same address as CBI code BIQ036/2).

Fine for the gap between dollars transferred through the currency-sale window and customers' import declarations at the northern border crossings, for 2012 and 2015. The bank provisioned about IQD 1.01bn in its 2020 accounts; in 2021 the CBI reduced the fine by about IQD 558m and the bank recovered about IQD 381m from one of its customers.

ISIS-linked MSBs with Iraq links.

Effective date printed as 30/10/2019.

ISIS-linked exchange houses with Iraq addresses.

IRGC-QF front that "covertly facilitated the IRGC-QF’s access to the Iraqi financial system to evade sanctions"; commissions to Abu Mahdi al-Muhandis.

ISIS financial network node with Iraq address. CBI struck "Al Ardh Al Jadida" (Anbar) off register 7 April 2016; listed as barred from 8/1/2016.

Financial coordinator between IRGC-QF and armed groups in Iraq; oil smuggling; bulk cash to Lebanon.

Iraq-based MSB designated for supporting ISIS.

Designated as part of the Bonyad Taavon Basij network action; SDN entry covers "All Branches Worldwide".

Effective date printed as 16/5/2018 (day after OFAC designation).

Treasury: Aras Habib "enabled the IRGC-QF’s exploitation of Iraq’s banking sector to move funds from Tehran to Hizballah"; bank designated as owned or controlled by him.

Designated as part of Iraq-based ISIS financial facilitation network. CBI had struck "Al Kawthar" off its register 7 April 2016 and listed it as barred from 8/1/2016.

Designated as ISIL-linked money services businesses; both carry Iraq links in the SDN list. Note: CBI had already struck Selselat Al Thahab off its register on 7 April 2016 and barred it from USD on 15 May 2016.

Dates as printed in CBI list (15/5/2016).

Effective date printed in the CBI list as 8/1/2016 for the three Iranian-linked bank branches and most listed exchange companies.

Sanction lifted after Elaf froze EDBI accounts and reduced exposure to Iranian financial sector.

Treasury found Elaf knowingly facilitated significant transactions for the designated Export Development Bank of Iran; US banks barred from maintaining correspondent accounts for Elaf.