Iraq

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1. Does Iraq have a sanctions regime in place?

Iraq does not publicize what sanctions are in force, but sanctions will be enforced on an ad hoc basis upon the issuance of corresponding legislation or orders. An example of this is the legislation passed to implement the Arab League’s boycott of Israel.

2. Does Iraq implement UN sanctions?

Yes, Iraq may implement sanctions imposed by the UN on an ad hoc basis, upon the issuance of corresponding legislation or orders.

3. Does Iraq implement an autonomous sanctions regime?

No, other than the implementation of the Arab League’s boycott of Israel, which, on a primary level, prevents business transactions with either the Israeli government or an Israeli citizen.

4. What is the nature of the sanctions regime in Iraq?

There is no visibility of the overall sanctions regime in place, but sanctions may in theory comprise economic and non-economic measures.

5. Does Iraq maintain a list of sanctioned individuals and entities?

It is understood that there is a list of sanctioned individuals and entities, but that this is not made public. There is also what is commonly referred to as the “black list”, which is a list of individuals or entities whom the Iraqi Government has blacklisted for all purposes.

6. Are there any other lists related to sanctions?

Nothing that is publically available.

7. Does Iraq have a licensing or authorization system in place?

No.

8. What are the consequences for a breach of sanctions in Iraq?

Information regarding the Iraq sanctions regime is not readily available, but to the extent that sanctions are reflected in legislation or order, the corresponding penalties should be stated therein too.

9. Who are the relevant regulators in Iraq and what are their contact details?

There is no specific sanctions regulator, however the Ministry of Foreign of Affairs is likely to get involved in collaboration with other ministries where the subject matter falls within their remit.

Contributor law firm

Tawfiq Tabbaa

Regional Managing Partner

Sanad Law Group (in association with Eversheds),

Al Mansoor District

Baghdad

Iraq

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