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IRAQ'S CORRUPTION
العربية
Cases

Al-Huda Bank: FinCEN Section 311 finding and OFAC designation of its owner (2024)

On 29 January 2024 the US Treasury issued a finding that Al-Huda Bank is a foreign financial institution of primary money-laundering concern, proposing to cut it off from US correspondent accounts, and OFAC designated its owner and board president Hamad al-Moussawi for supporting the IRGC-Quds Force. FinCEN said the bank exploited the Central Bank of Iraq dollar auction to support designated terrorist organisations, including Kata'ib Hizballah and Asa'ib Ahl al-Haq. The final rule was published on 3 July 2024. The bank itself was not placed on the SDN list. The central bank barred Al-Huda from dollar dealing effective 29 January 2024.

Period
From January 2024 to July 2024
Sector
Banking, currency and dollar auctionUS Treasury action, dollar auction abuse
Kind of case
Section 311 finding and sanctions on the owner
Jurisdiction
United States

How the money moved, according to the sources

This account is the one given by the sources listed on this page. It is not the finding of a court.

Use of the dollar auction with front companies and fraudulent documents to move dollars abroad for the financing of militias and of Iran's Revolutionary Guards and money laundering.

What happened

US measures in force; no Iraqi criminal case is on record.

Open questions

  • Did Iraqi authorities open any case against Al-Huda or al-Moussawi after 2024?
  • Status of Al-Huda Bank licence in Iraq.

People and companies

The table lists everyone this case names, with their legal status on the date shown. A status in this case does not carry over to any other case, and an accusation is not a conviction. How to read the status.
People and companies
NameRole in the caseLegal statusDetailAs of
Hamad al-Moussawi
حمد الموسوي
Owner and president of the board, Al-Huda BankUnder sanctionsDesignated by OFAC on 29 January 2024 under Executive Order 13224, which concerns the financing of terrorism, for support to the Quds Force of Iran's Revolutionary Guards.25 September 2026
Al-Huda Bank
مصرف الهدى
Iraqi private bankDisciplined by an official bodyFinCEN Section 311 finding and notice of proposed rulemaking 29 January 2024 (89 FR 6074) naming it a primary money-laundering concern; final rule (special measure five: US correspondent accounts prohibited) published 3 July 2024; Central Bank of Iraq dollar ban effective 29 January 2024. Not on the OFAC SDN list.25 September 2026

Sources

These are the documents on which this case rests. Each quote is given in the language of the document.
  1. US Department of the Treasury29 January 2024Sanctions noticeTier A

    U.S. Treasury Takes Action to Protect Iraqi Financial System From Abuse (jy2053)

    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
    OriginalSHA-256 aa71d7ae9a02
  2. FinCEN / Federal Register31 January 2024Sanctions noticeTier A

    Proposal of Special Measure Regarding Al-Huda Bank (89 FR 6074)

    FinCEN assesses that Al-Huda Bank has deliberately embarked on a strategy that relies on exploiting the CBI dollar auction to support designated FTOs
    OriginalSHA-256 44624960fc21
  3. Central Bank of Iraq4 February 2024Government statementTier A

    قائمة المحرومين من التعامل بعملة الدولار الأمريكي (list created 4 Feb 2024)

    Investment Bank of Iraq BIQ012/2 بغداد Baghdad 29 1 2024
    OriginalSHA-256 e133e1786473
  4. FinCEN / Federal Register3 July 2024Sanctions noticeTier A

    Imposition of Special Measure Regarding Al-Huda Bank

    OriginalSHA-256 124cd6f3581e

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