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Elaf Islamic Bank: US CISADA sanctions for facilitating Iranian bank transactions, and 2013 delisting

On 31 July 2012 the US Treasury sanctioned Elaf Islamic Bank, a privately owned Iraqi bank, under the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), for knowingly facilitating significant transactions, worth 'tens of millions of dollars' over the prior year, for Iran's Export Development Bank (EDBI), which the US and EU had designated over Iran's proliferation activities. The sanctions barred US institutions from opening or maintaining correspondent or payable-through accounts for Elaf. Less than a year later, on 17 May 2013, Treasury removed the sanctions, crediting Elaf with a demonstrated change in behaviour, including freezing EDBI-linked accounts. No individual officer of Elaf was named or personally sanctioned in either Treasury release.

Period
From July 2012 to May 2013
Sector
Banking, currency and dollar auctionIran-sanctions correspondent-banking cases
Kind of case
Sanctions designation
Jurisdiction
Federal Iraq

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.

A privately owned Iraqi bank allegedly processed significant financial transactions for a US/EU-blacklisted Iranian bank, exploiting its access to the international financial system to move funds tied to Iran's proliferation network.

What happened

Sanctions formally lifted 17 May 2013; resolved from a US-sanctions standpoint.

Open questions

  • Whether any Elaf officer was named; whether Iraqi authorities took any parallel domestic action.

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
Elaf Islamic Bank
مصرف إيلاف الإسلامي
Privately owned Iraqi bank, BaghdadCharges dropped or case closedDesignated by US Treasury 31 July 2012 under CISADA for facilitating transactions for Iran's Export Development Bank (EDBI). Delisted 17 May 2013 after Treasury credited a demonstrated change in behaviour, including freezing EDBI-linked accounts. No individual owner or officer was named or sanctioned in either Treasury release.28 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 Treasury31 July 2012Sanctions noticeTier A

    Treasury Sanctions Bank for Supporting Iranian Bank Designated for Proliferation Activities (press release tg1661)

    Elaf Islamic Bank, a privately-owned Iraqi financial institution, [sanctioned] for knowingly facilitating significant transactions and providing significant financial services for the U.S. and EU-designated Export Development Bank of Iran (EDBI)
    OriginalSHA-256 227e8ad35009
  2. US Department of the Treasury17 May 2013Sanctions noticeTier A

    Treasury Removes Sanctions on Iraqi Bank (press release jl1949)

    Today we welcome Elaf Islamic Bank back into the U.S. financial system, and we urge other designated individuals and entities around the world to follow its positive example.
    OriginalSHA-256 b119ecabab78