The Ledger

Al-Huda Bank

This page sets out what the record shows about Al-Huda Bank. It names the owners and managers, gives the dollars the bank bought from the Central Bank in the years whose records survive, lists the requests that the Central Bank refused and describes the action that regulators took against the bank.

مصرف الهدى

$10.3bn

bought from the Central Bank from 2012 to 2020, in the records that survive. This is a minimum.

Tier A

$1.1bn

asked for but refused by the Central Bank's committee from January 2013 to February 2015

Tier A

$371.4m

the value of the gap between the official and the market price on the dollars it bought, which went to whoever received the dollars

Tier B

Name, licence and status

Name in English: Al-Huda Bank
Name in Arabic: مصرف الهدى
Type: Islamic bank
Licence: No. 136/3/9 of 14 January 2008
Regulatory measures: Subject to a FinCEN Section 311 special measure (2024); its owner was designated by OFAC; barred from dollar dealing by the Central Bank (January 2024)

Ownership

Not listed on the Iraq Stock Exchange; US Treasury: Hamad al-Moussawi is "the owner and president of the board of directors" (designated by OFAC on 29 January 2024). The shareholder register is not in the record.

Political or armed-group links reported by sources

Treasury/FinCEN: bank controlled and operated by the IRGC and IRGC-QF since establishment; chairman established it in 2008 "specifically for the benefit of KH"; used by companies of Asa'ib Ahl al-Haq
According to: FinCEN final rule 89 FR 55051; Treasury jy2053Tier AFinCEN / Federal Register U.S. Department of the Treasury

Owners and managers

Being listed here records an ownership stake or a post at the bank. It is not an allegation. Next to each name is the exact legal status. Where the encyclopedia holds a record of the name, the status comes from that record. Otherwise it reads “Not charged as of the date of writing”.

Owners and managers
Name	Role	Share	As of	Legal status	Source
Hamad al-Moussawi حمد الموسوي	Chairman Reported beneficial owner US Treasury 29 January 2024	Not stated	Not stated	Under sanctions	U.S. Department of the Treasury FinCEN / Federal Register OCCRPCentral Bank of Iraq[1][2]
قيدار عبد الرحمن عبد الله	Managing director	Not stated	30 September 2026	Not charged as of the date of writing	cbi.iq

Dollars bought from the Central Bank

Dollars bought from the Central Bank, by year

In billions of dollars. Verified rows of the Central Bank's daily records.

Source: Central Bank of Iraq, daily records of the dollar sale, compiled from the verified rowsTier A

Dollars bought from the Central Bank
Year	Dollars bought	Cash	Transfers abroad	Share of the year's named sales	Refused	Value of the price gap
2012	$24m	$0	$24m	8.9%	Not stated	$420,000
2013	$2.8bn	$136m	$2.6bn	5.9%	$716.3m	$115.4m
2014	$3.2bn	$57.1m	$3.1bn	9.1%	$240.2m	$67m
2015	$2.2bn	$9.7m	$2.2bn	7.0%	$91.8m	$98.2m
2016	$1bn	$0	$1bn	3.8%	Not stated	$64.8m
2017	$488.6m	$3.4m	$485.2m	2.5%	Not stated	$22.4m
2018	$5.2m	$0	$5.2m	3.3%	Not stated	$164,060
2019	$542.9m	$0	$542.9m	4.8%	Not stated	$2.8m
2020	$7m	$0	$7m	3.9%	Not stated	$227,642
Total	$10.3bn	$206.1m	$10.1bn		$1bn	$371.4m

Source: Central Bank of Iraq, daily records of the dollar sale, compiled from the verified rowsTier A

Source: the price gap is our calculation from the Central Bank's price and the market priceTier B

Share of the year's named sales: the bank's part of all the dollars that the surviving records attribute to a named bank in that year.

Refused: the requests that the Central Bank's committee turned down. Its minutes survive only from January 2013 to February 2015. An empty cell means that no minutes survive for that year. The yearly figures come from the yearly ledger. The figure at the top of the page comes from the committee's minutes. The two can differ.

What the Central Bank refused

From January 2013 to February 2015 the Central Bank's committee recorded, day by day, which requests for dollars it turned down and why. Its minutes record 126 occasions on which the committee refused all or part of a request by this bank. On those occasions the bank asked for $2 billion, and $1.1 billion of it was refused.

The largest refusals

The largest refusals
Date	Asked for	Refused	The reason, as the committee wrote it	Category
2 June 2013	$38.1m	$34.1m	لعدم كفاية رصيد المصرف	Funds did not cover the request; Missing or defective documents
1 June 2013	$34.1m	$34.1m	لعدم كفاية رصيد المصرف	Funds did not cover the request; Missing or defective documents
date unreadable	$20.7m	$20.7m	20,727,000 لاغراض تدقيقية	Held for audit
date unreadable	$19.4m	$19.4m	الأموال 19,444,000 المرقمة 827/ في	Other
29 October 2014	$18.5m	$18.5m	لاغراض تدقيقية	Held for audit
28 May 2013	$18.4m	$18.4m	لتجزئة مبلغ الفاتورة	Old or invalid invoice
9 February 2015	$22.8m	$18.4m	18,419,000 الاغراض بدقيقية	Other
29 May 2013	$31.2m	$17.3m	1. لتقديمه طلبين حوالة احدهما يخالف موعد التقديم2. لتكرار الفاتورة لأكثر من طلب تحويل تسلسل ,!3) في كشف الحوالات (punctuation adjusted)	Same customer or name repeated
date unreadable	$31.9m	$17m	تم استبعاد احد طلبي الحوالة لعدم كفاية رصيد المصرف	Funds did not cover the request; Missing or defective documents
16 November 2013	$16.6m	$16.6m	ورود كتاب الا التحوول بنفس التسلمل ,1230)	Penalty on, or suspension of, the bank
date unreadable	$16.3m	$16.3m	العدم تقديم سوفتات	Missing or defective documents
11 September 2013	$15.4m	$15.4m	اغراض تدقيقية	Held for audit

Each reason is quoted in Arabic, in the committee's words. Where a reason is marked “punctuation adjusted”, only its punctuation was changed. The category is ours.

Source: Central Bank of Iraq, daily minutes of the committee that ran the dollar sale, from January 2013 to February 2015Tier A

All the refusals, day by day

Enforcement actions

29 January 2024FinCEN (US Treasury)
Finding of primary money-laundering concern, and proposed rule, under Section 311 of the USA PATRIOT Act
Against: Al-Huda Bank
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 OFAC's sanctions list.
Current position: Replaced by the final rule of 26 June 2024
Original
29 January 2024OFAC (US Treasury)
Placed on the US sanctions list as a supporter of terrorism
Against: Hamad al-Moussawi (owner and president of the board of Al-Huda Bank)
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.
Current position: Still on OFAC's sanctions list
Original
29 January 2024Central Bank of Iraq
Barred from the currency window and from dealing in dollars
Against: Investment Bank of Iraq; Union Bank of Iraq; Kurdistan International Islamic Bank; Ashur International Bank; Al-Huda Bank; Al-Janoob Islamic Bank; Al-Arabiya Islamic Bank; Hammurabi Commercial Bank
The Central Bank's list gives 29 January 2024 as the date for all 8 banks. Reuters reported the ban on 4 February 2024.
Current position: Investment Bank of Iraq, Kurdistan International Islamic, Al-Janoob, Al-Arabiya named (anonymous Central Bank source) among seven banks cleared July 2026 to return to non-dollar correspondent channels
Original
26 June 2024FinCEN (US Treasury)
Final rule under Section 311 of the USA PATRIOT Act: US banks barred from holding accounts for the bank
Against: Al-Huda Bank
Prohibits covered US financial institutions from opening/maintaining correspondent accounts for Al-Huda and requires steps to block indirect access.
Current position: In force
Original

Sources

The documents behind this page, with the words quoted from each.

U.S. Department of the Treasury29 January 2024Tier A
U.S. Treasury Takes Action to Protect Iraqi Financial System From Abuse (FinCEN Identifies Al-Huda Bank as a Primary Money Laundering Concern...)
Treasury is issuing a finding and notice of proposed rulemaking (NPRM) that identifies Al-Huda Bank, an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial institution of primary money laundering concern. ... In addition, the Office of Foreign Assets Control (OFAC) is imposing sanctions… Read the rest
on the bank’s owner. ... Today, OFAC designated Hamad al-Moussawi, the owner and president of the board of directors of Iraq’s Al-Huda Bank, for his support to the IRGC-QF ... Al-Moussawi has used partially witting, unaffiliated individuals to execute the purchase of U.S. dollars during currency auctions held by Iraq’s central bank by using their identity documents to circumvent limits on currency purchases. Since its inception, Al-Huda Bank has used forged documents to execute at least $6 billion in wire transfers out of Iraq. Hamad al-Moussawi is being designated pursuant to Executive Order 13224, as amended
Original
FinCEN / Federal Register3 July 2024Tier A
Imposition of Special Measure Regarding Al-Huda Bank as a Financial Institution of Primary Money Laundering Concern (Final rule), 89 FR 55051
This final rule is effective August 2, 2024. ... Al-Huda Bank is a private commercial bank registered and headquartered in Baghdad, Iraq, with five branch locations in Baghdad, Karbala, and Nasiriyah, Iraq. ... In 2008, the chairman of Al-Huda Bank established the bank specifically for the benefit of KH ... Since at… Read the rest
least 2012, Al-Huda Bank has used fraudulent documentation to purchase foreign currency, including USD, from the CBI at CBI dollar auctions. ... Following the issuance of the NPRM, the CBI banned Al-Huda Bank from accessing the CBI dollar auction.[10: Reuters, Iraq bans 8 local banks from US dollar transactions (Feb. 4, 2024)] ... Overall, IRGC and IRGC-QF use of Al-Huda Bank and several other Iraqi banks to access the CBI dollar auction resulted in approximately $70 billion USD in profit, from 2019 through 2020.
(punctuation adjusted)
Original
OCCRP8 October 2024Tier D
Iraq’s Dollar Auction: The ‘Monster’ Funneling Billions to Fraudsters and Militants Through the U.S. Federal Reserve
The money released by the New York Fed to Al-Huda, nearly $6.5 billion over three years, was not paid to the suppliers ... Instead, it was funneled into the accounts of three exchange companies, including nearly $5.8 billion to an exchange company co-owned by Al-Huda’s owner, Hamad al-Moussawi. ... In 2018, Moussawi… Read the rest
was elected to Iraq’s parliament ... At least a million dollars ... ended up sent to UBI’s chairman, Fadhil al-Dabbas. ... Lami and Hassan also hold just under 10 percent each in Iraqi Noor Islamic Bank, which was barred from the dollar auction in late 2019 at the Federal Reserve’s request ... UBI ... was never barred from the dollar auction. But in 2018, it was put under the guardianship of Iraq’s central bank for “failure to meet financial obligations.”
(punctuation adjusted)
Original
Central Bank of IraqAccessed 25 September 2026Tier B
المصارف الاهلية المحلية (Private local banks: licence numbers/dates, managers, status marks)
الأقليم التجاري للاستثمار والتمويل ( اميرالد سابقا ) ... 408/3/9 2007/3/1 | الهدى ( ممنوع من التعامل بالدولار ) ... 136/3/9 2008/1/14 | مصرف بابل ( تصفية ) ( ممنوع من التعامل بالدولار ) ... المصفي، د.أحمد عباس أحمد | دار السلام للأستثمار ( حراسة قضائية ) | الشمال للتمويل والاستثمار ( وصاية ) | الطيف الإسلامي للإستثمار… Read the rest
والتمويل ( وصاية )( ممنوع من التعامل بالدولار ) | المال الإسلامي للإستثمار ( ممنوع من التعامل بالدولار ) ... 845/3/9 في 2018/12/9
(punctuation adjusted)
Translation: Region Trade Bank for Investment & Finance (formerly Emerald) ... licence 408/3/9 of 1 Mar 2007 | Al-Huda (barred from USD dealing) ... licence 136/3/9 of 14 Jan 2008 | Babylon Bank (liquidation) (barred from USD) ... liquidator Dr Ahmed Abbas Ahmed | Dar Es Salaam (judicial receivership) | North Bank (guardianship) | Al-Taif Islamic (guardianship)(barred from USD) | Al-Mal Islamic (barred from USD) ... licence 845/3/9 of 9 Dec 2018
Original
Central Bank of Iraq23 October 2025Tier A
النشرة الإحصائية السنوية / Annual Statistical Bulletin (2024 data; PDF created 23 Oct 2025), banks' establishment year, total assets, paid-up capital (pages 116 to 117) and ISX listing table (p.113)
Region Trade Bank for Investment 2007 1,051,981 300,000 مصرف الاقليم التجاري( اميرالد) | AL-Huda Bank 2008 412,604 250,000 | Erbil Bank 2010 | International Development Bank 2011 | Hammurabi Commercial Bank 2020 | Ur Islamic Bank 2018 334,815 250,000
Original

In the press

Articles that name the bank, newest first. Each headline is given in the publication's own words. Some headlines describe the special measure as sanctions. The bank itself is not on OFAC's sanctions list.

9 October 2024مزاد العملة.. «غولal-aalem.com
June 2024FinCEN Finalizes Financial Measure Against Iraq-based Al-Huda Bank to Combat Terrorist FinancingFinCEN
30 January 2024العقوبات على مصرف الهدى بسبب أنشطته خلال 2022، توضيح من البنك المركزي964media.com
30 January 2024Central Bank discusses US sanctions on Al-Huda Banken.964media.com
29 January 2024U.S. Treasury Takes Action to Protect Iraqi Financial System From AbuseUS Department of the Treasury
29 January 2024Taking Financial Measures Against Iraqi Bank and Designating its OwnerUS Department of State
29 January 2024نص قرار الخزانة الأميركية بفرض عقوبات على بنك الهدى العراقي964media.com
29 January 2024U.S. Treasury imposes sanctions on Al-Huda Bank for "Terrorism Financing and Money Laundering"shafaq.com