Silsilat Al-Dhahab (Golden Chain) for Money Transfer
A money-transfer company that bought cash dollars directly from the Central Bank of Iraq at the official price from 2015 to 2016, according to the Bank's daily bulletins. This page shows what it bought, the estimated margin on it, what is on record against it, and the document behind each figure.
On record: Under US sanctions (OFAC, December 2016); Licence withdrawn by the Central Bank (February 2017); Barred from dollar dealing by the Central Bank (May 2016)
What is on record
- 13 December 2016Designated by the US Treasury's Office of Foreign Assets Control (OFAC)Tier A
In the Treasury's words: "Selselat al Thahab, which is based in Iraq, was designated for providing financial, material, or technological support for, and financial or other services to or in support of, ISIL". Basis: E.O. 13224 (SDGT) [SDGT]; Linked To: ISIL
Document (saved page)Original address - 15 May 2016Barred from dollar dealingTier A
Listed as barred from the CBI FX sale window and from any direct or indirect US-dollar dealing; the list gives no reason.
شركة سلسلة الذهب للتحويل المالي · CBI 'List of those deprived of dealing in US dollars', code TIQ026/1 (كربلاء, Karbala)
Document, p.4 - 19 December 2016Other actionTier A
OFAC (US Treasury) blacklisted this CBI-licensed money-transfer company for financing terrorist groups (ISIS), acting in coordination with the CBI; the CBI said it had barred the company from the Iraqi financial system and frozen its assets. Its licence was withdrawn in February 2017 (separate row).
شركة سلسلة الذهب للتحويل المالي / مساهمة خاصة · CBI press statement
Document, p.1 - 13 February 2017Licence withdrawnTier A
Company was placed on the US Treasury OFAC blacklist under Executive Order 13224 (terrorism financing); CBI withdrew its licence and asked the Companies Registration Department to strike it off the commercial register.
شركة سلسلة الذهب للتحويل المالي · CBI Banking Supervision letter 2394/9/9; Board decision 18 of 2017, session 1550 of 2017-01-29
Document, p.1 - 7 March 2017Other actionTier A
Assets frozen by the Committee for Freezing Terrorists' Funds, chaired by a CBI Deputy Governor, under the AML/CFT Law 39 of 2015 and Terrorist Asset-Freezing Regulation 5 of 2016. No specific reason is given beyond the terrorist-financing framework. Its board members and managing director (named; not copied) were also frozen.
شركة سلسلة الذهب للتحويل المالي (كربلاء) · Committee for Freezing Terrorists' Funds decision 1 of 2017
Document, p.2 - 9 August 2017Other actionTier A
Appeal by the company's managing director, deputy and board members against the 2017 asset freeze rejected, freeze upheld. Reasons given: unremedied violations reported by the CBI AML/CFT Office (letters 235 and 293 of 2017-05-17 and 2017-06-12), Foreign Ministry information, an Iraqi National Intelligence Service indicator that the company dealt with suspicious parties and smuggled money abroad to support ISIS, and its UN ISIS/al-Qaeda sanctions listing (QDe.154).
شركة سلسلة الذهب للتحويل المالي · Committee for Freezing Terrorists' Funds decision 13 of 2017 (session 11 of 2017-08-09), signed by the committee chair, a CBI Deputy Governor (acting)
Document, p.1
Year by year
| Year | Purchases | Cash dollars bought | Estimated margin |
|---|---|---|---|
| 2015 | 24 | $18.6 million | $0.4 million |
| 2016 | 13 | $7.9 million | $0.3 million |
The margin is the difference between what these dollars were worth at the market price on the day they were bought and what was paid for them at the official price. It went to the company, to its customers or to both, and it is not a finding that the company made that profit.