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POL-39

This is a proposal for discussion, not an enacted law.

Ali Zuweid's Political Programme · Proposed legislation · Economy, Finance, Investment and Employment

Anti-Money Laundering, Counter-Terrorist Financing and Counter-Proliferation Financing Law

Comprehensive modernisation of Law No. (39) of 2015, preserving the Council and financial intelligence office while rebuilding the system around risk and effectiveness: verifiable beneficial ownership, virtual-asset regulation, effective supervision of non-financial professions, targeted financial sanctions aligned with current international regimes, financial investigation and confiscation, and specialised measures against proliferation financing.

Document number
POL-39
Version
1.0
Publication date
7 October 2026
Scope
Republic of Iraq
Document type
Proposed repeal-and-replacement legislation
Axis
Economy, Finance, Investment and Employment

Executive Summary

Since 2015, Iraq has had a relatively modern anti-money laundering and counter-terrorist financing law, followed by Terrorist Asset Freezing Regulation No. (6) of 2023, due diligence instructions, rules on politically exposed persons, and development of the sanctions platform and goAML. The 2024 FATF/MENAFATF assessment also found that many core technical requirements were present in Iraqi law, including the legal framework for proliferation-financing targeted financial sanctions. This document therefore does not begin by assuming the previous system was empty or a failure.

The problem revealed in 2024–2026 was the gap between legal provisions and effective implementation. The mutual evaluation identified weaknesses or deficiencies in aspects of non-financial professions, beneficial ownership, new technologies, value transfer services, proliferation-financing coordination, and the quality and use of financial reports. On 19 June 2026, FATF placed Iraq among jurisdictions under increased monitoring following a high-level political commitment to implement a joint action plan.

The 2026 plan does not seek a single formal amendment. It covers deeper risk understanding, detection of informal money transfer services, a legislative framework for virtual asset service providers, better implementation of politically exposed person and targeted financial sanctions requirements, improved quality and use of suspicious transaction reports, stronger beneficial ownership, more money-laundering and terrorist-financing investigations and prosecutions, improved non-profit organisation assessment, and stronger detection of evasion of proliferation-financing sanctions. Comprehensive modernisation is therefore more coherent than a series of fragmented amendments.

The proposal preserves the Anti-Money Laundering and Counter-Terrorist Financing Council and Office, strengthening the Office's independence rather than creating a new financial intelligence unit. It also temporarily preserves the freezing regulation, 2023 instructions and subsequent rules, allowing a transition while references and terminology are updated under the new law.

The most prominent legislative addition concerns virtual assets. For the first time, the proposal establishes an express legal basis for licensing or registering virtual asset service providers, due diligence, the travel rule, freezing and reporting, leaving regulatory detail to the Central Bank and competent bodies. This directly responds to the 2026 FATF plan and work begun by the Supreme National Committee for Regulating Virtual Assets in 2025.

The second addition is beneficial ownership. The proposal does not duplicate the Companies Law scheduled for modernisation in POL-40. It imposes the required anti-money laundering outcome: identify the natural person ultimately owning or controlling an entity, trace the ownership chain, disclose nominee relationships and make a reliable central register available to authorities, while referring institutional details to the Companies Law.

On proliferation financing, the proposal avoids anchoring the law to an international regime that may change. The 2024 mutual evaluation relied on the 1718 and 2231 regimes, but the situation later changed: from 27 September 2025, the Security Council reapplied earlier Iran sanctions resolutions and re-established the 1737 Committee and list. The proposal therefore provides for dynamic implementation of regimes currently in force, identifies 1718 and 1737 in their current status, and requires authorities to update lists following any subsequent international change.

The law does not treat all non-profit organisations as high risk. It adopts a risk-based approach focused on the subset genuinely vulnerable to terrorist-financing abuse, protecting legitimate humanitarian and civil society work from disproportionate disruption.

The framework through 2026

Anti-Money Laundering and Counter-Terrorist Financing Law No. (39) of 2015 remains in force and is published on the Office's official platform alongside regulations and instructions. The law reconstituted the Office and granted it independence, and established a national council chaired by the Central Bank Governor with government and law-enforcement bodies represented.

Due diligence instructions and politically exposed person rules were issued in 2023, together with Terrorist Asset Freezing Regulation No. (6) of 2023, which expanded the legal framework for targeted financial sanctions. In 2025–2026, the Central Bank continued issuing supervisory rules for banks, exchange companies, payment companies and non-bank institutions.

By 2026, Iraq had an updated official platform for domestic and international sanctions lists, grievances, match reports and frozen assets, alongside the goAML reporting system. The proposal therefore builds on existing operational infrastructure rather than replacing it with parallel systems.

FATF action plan and increased monitoring

In June 2026, Iraq committed to an action plan with FATF and MENAFATF after being placed under increased monitoring. The plan has nine linked directions: more precise risk understanding; detection of informal money transfer services and regulation of virtual asset service providers; implementation of politically exposed person and targeted sanctions requirements; improved suspicious reporting and use of financial intelligence; stronger beneficial ownership; increased money-laundering investigations and prosecutions; increased terrorist-financing investigations and prosecutions and remediation of technical deficiencies; proportionate assessment of non-profit organisation risks; and stronger capacity to counter evasion of proliferation-financing sanctions.

In July and September 2026, Iraqi authorities held specialised activities on implementing targeted sanctions and issued updated guidance for financial institutions and non-financial professions. This confirms that some 2024 gaps are already being addressed. The law is therefore designed to turn these measures into a permanent framework and prevent future inconsistencies between guidance and regulations.

Legislative policy

The most appropriate form is repeal and replacement of Law 39 of 2015 while retaining its principal institutions. Its scope has effectively expanded to include proliferation financing, and incorporating virtual assets, beneficial ownership, stronger non-financial supervision and detailed targeted-sanctions rules through dozens of amendments would make the law less clear.

The new law does not turn FATF into an Iraqi legislator. FATF recommendations and the action plan are an international standard and monitoring framework; domestic legal obligations arise from Iraqi legislation, binding Security Council decisions and applicable treaties. The proposal therefore preserves parliamentary, judicial and national authority while using the international plan to identify gaps requiring attention.

It also distinguishes prevention from investigation. Financial institutions are not law-enforcement bodies; their duty is to know customers, monitor risk and report. The Office analyses, investigators collect evidence, and courts determine liability and confiscation. This separation matters both for rights protection and for improving the quality of each stage.

Draft Anti-Money Laundering, Counter-Terrorist Financing and Counter-Proliferation Financing Law

Proposed promulgation formula: In the name of the people, Presidency of the Republic: pursuant to approval by the Council of Representatives and ratification by the President of the Republic, and under the Constitution, the following Law is issued.

Statement of reasons

This Law is enacted to modernise the Republic of Iraq's system against money laundering, terrorist financing and financing the proliferation of weapons of mass destruction; improve effective implementation of international standards and the 2026 FATF action plan; regulate virtual-asset risks and informal value transfer services; strengthen beneficial ownership transparency and risk-based supervision of financial institutions, non-financial professions and non-profit organisations; and develop targeted financial sanctions, financial investigation, confiscation and international cooperation while protecting rights, data and legitimate activity.

Explanatory memorandum

1. Why replace rather than amend the 2015 law?

The 2015 law marked a fundamental advance and created institutions that remain operational, but the legal environment has changed: the 2023 freezing regulation, new beneficial ownership standards, virtual assets, evolving proliferation risks, and a mutual evaluation and FATF plan in 2026. Consolidating these in one law is clearer than a chain of amendments and cross-references.

2. The Office remains in place

There is no need for a new financial intelligence unit. The current Office has a national platform, goAML and institutional relationships. What is needed is stronger independence, resources, information-request powers and feedback capacity, with financial oversight protecting operational confidentiality.

3. Virtual assets

The FATF plan expressly identified the need for a legislative framework for virtual asset service providers. The law defines core activities and obligations, leaving the Central Bank and competent authority to decide whether particular products are permitted, restricted or prohibited for monetary or financial reasons. It thus does not conflate anti-money laundering regulation with monetary policy decisions.

4. Beneficial ownership

The task is not merely to ask a company who owns it, but to identify the natural person ultimately controlling it, verify the information and keep it current. The proposal therefore links duties of companies and financial institutions with the central register, with details completed in Companies Law POL-40.

5. Suspicious reports

More reports are not an objective in themselves. A good report explains who conducted the transaction, what made it implausible, who the beneficial owner is and where funds went. The proposal therefore emphasises quality, feedback and investigative use of information, central elements of the 2026 plan.

6. Non-profit organisations

Risk-based assessment avoids subjecting every organisation to identical security treatment. Intensive measures target activities genuinely exposed to abuse, while legitimate humanitarian and civil society associations are protected from unjustified disruption of funding and services.

7. Financial sanctions are not confiscation

Freezing is a preventive measure prohibiting dealings in a designated person's assets; it does not automatically transfer ownership to the state. The proposal therefore provides for grievances, correction of false matches, basic-expense exceptions and bona fide third-party protection, while permanent confiscation still requires the appropriate judicial basis.

Proliferation financing and changes in the sanctions regime

The 2024 assessment found that Iraq had a legal basis for proliferation-related financial sanctions but recorded weaknesses in coordination, understanding and supervision outside some sectors. The international framework then changed after assessment. On 27 September 2025, the Security Council reapplied resolutions 1696, 1737, 1747, 1803, 1835 and 1929 concerning Iran and re-established the 1737 Committee list, while the 1718 regime for North Korea continued.

The proposal therefore does not repeat a fixed reference to resolution 2231 as in the 2023 regulation and 2024 assessment. It establishes a dynamic rule: institutions and authorities follow Security Council regimes in force at implementation and update lists and guidance immediately upon changes. This prevents freezing from continuing after its basis expires or a reinstated freeze being overlooked.

Reform also extends from name matching to evasion detection: indirect ownership and control, shell companies, third parties, trade finance, dual-use goods and unusual shipping routes. These indicators trigger examination but do not alone establish guilt.

Beneficial ownership and virtual assets

The proposal combines three layers: legal persons retain and update their beneficial ownership data; the Companies Registrar maintains a verifiable central register; and financial institutions independently verify rather than rely solely on a registry statement where inconsistencies arise. This design addresses the 2024 assessment's gap concerning ownership chains and control through other means.

Virtual asset service providers are subject to licensing, beneficial ownership, due diligence, reporting, targeted sanctions and the travel rule, with transition arrangements for existing activities. The law does not equate every digital use with crime; it regulates intermediaries according to risk.

Non-financial professions and non-profit organisations

A prominent 2024 finding was weak understanding and implementation by many non-financial businesses and professions of due diligence, beneficial ownership, reporting and targeted sanctions obligations, with very few suspicious reports from some. The proposal therefore moves supervision beyond naming a competent authority to an actual duty of risk-based inspection, sanctions and training.

At the same time, it prevents literal application of the banking model to small legal practices or charities. Requirements are proportionate to activities and risks and respect legitimate professional confidentiality and humanitarian work, without exempting genuinely risky financial transactions.

Investigation, confiscation and international cooperation

The proposal emphasises parallel financial investigation of proceeds-generating offences and terrorist financing so cases do not end in conviction while funds remain untouched. It regulates tracing, freezing, seizure, equivalent-value confiscation, asset management and recovery while protecting bona fide third parties and victims.

It also strengthens direct international cooperation between financial intelligence units and supervisors, retaining mutual legal assistance and extradition within judicial and treaty frameworks. The aim is to address slow requests and improve cross-border use of ownership and asset information.

Legislative alignment

FrameworkProposed remedy
Law No. (39) of 2015Repeal and replacement, with the Council and Office continuing by operation of law.
Terrorist Asset Freezing Regulation No. (6) of 2023Transitional continuation and updated references to current Security Council regimes.
Due Diligence Instructions No. (1) of 2023Continue where consistent, then update within 18 months.
Politically Exposed Persons Rules No. (2) of 2023 and 2026 updatesRemain an implementation reference, reviewed under the risk-based approach.
Companies LawBeneficial ownership registration, verification mechanisms and sanctions are completed in POL-40.
Central Bank Law and Banking LawRemain the licensing and financial-supervision reference; this Law provides anti-money laundering obligations.
Counter-Terrorism Law and criminal lawsRemain the reference for offences and penalties not specifically governed by this Law.

Financial and Implementation Implications

The proposal requires no new financial intelligence institution or council; both already exist. Additional costs focus on Office systems, the beneficial ownership register, the virtual-asset framework, data links, non-financial sector training and supervision, and proliferation-financing analysis and financial investigation tools.

A reliable total cannot be stated before specifying the ownership register's technical design, the scope of virtual-asset licensing and the number of supervisors needing added capacity. The law therefore requires implementation cost estimates within the budget instead of a hypothetical figure.

Reform may produce positive fiscal effects through asset recovery, reduced crime, better correspondent banking and greater international confidence. These benefits are neither guaranteed revenues nor a justification for a predetermined cost.

Transition and Implementation

Existing institutions and core regulations continue to prevent a legal vacuum. During the first nine months, priority goes to three areas directly tied to the 2026 FATF plan: the virtual-asset framework, beneficial ownership register and non-profit organisation risk assessment. The freezing regulation is also reviewed promptly for alignment with current international regimes after the Iran regime changed in 2025.

Increased monitoring is neither permanent status nor a judgement on the entire system. The law requires a national measurement plan linked to results permitting action items to close when genuinely achieved. After three years, a parliamentary report addresses effectiveness rather than merely regulations issued.

Sources and references

  1. Anti-Money Laundering and Counter-Terrorist Financing Office — LegislationThe official source for Anti-Money Laundering and Counter-Terrorist Financing Law No. (39) of 2015 and published regulations, instructions and guidance.
  2. Anti-Money Laundering and Counter-Terrorist Financing Office — Official website and national sanctions platformDocuments the Office's continuity and operational independence, sanctions-list platform, match reports, grievances and goAML through 2026.
  3. National Strategy Against Money Laundering, Terrorist Financing and Weapons Proliferation 2023–2027An official reference for the Council and Office structure and existing national strategy.
  4. Anti-Money Laundering and Counter-Terrorist Financing Council — Due Diligence Rules Instructions No. (1) of 2023The due diligence implementation framework for financial institutions and designated non-financial businesses and professions.
  5. Anti-Money Laundering and Counter-Terrorist Financing Council — Politically Exposed Persons Rules No. (2) of 2023A national reference for measures concerning domestic and foreign politically exposed persons and international-organisation officials.
  6. Central Bank of Iraq — Anti-money laundering and counter-terrorist financingIncludes supervisory rules against money laundering, terrorist financing and weapons proliferation, and due diligence instructions.
  7. Central Bank of Iraq — Banking supervisionDocuments 2026 updates on politically exposed persons, suspicious indicators, risk management and banking supervision.
  8. Central Bank of Iraq — Supervision of non-bank financial institutionsDocuments rules governing exchange, electronic payments and non-bank financial institutions through 2026.
  9. Central Bank of Iraq — FATF adopts Iraq's plan, 19 June 2026The official Iraqi source on the joint FATF action plan, including virtual assets, targeted sanctions, beneficial ownership, investigations and proliferation financing.
  10. FATF — Jurisdictions under Increased Monitoring, 19 June 2026Placed Iraq under increased monitoring in June 2026 and defined a nine-part plan to improve system effectiveness.
  11. FATF/MENAFATF — Mutual Evaluation Report of Iraq, 2024The latest comprehensive mutual evaluation, identifying effectiveness and compliance ratings and gaps in non-financial sectors, beneficial ownership and proliferation financing.
  12. MENAFATF — Mutual Evaluation Report of the Republic of IraqThe official regional publication reference for Iraq's second-round assessment.
  13. Central Bank of Iraq — Implementing targeted financial sanctions under the FATF plan, 16 July 2026Documents operational work towards immediate and effective targeted financial sanctions implementation.
  14. Central Bank of Iraq — Guidance on applying targeted financial sanctions, 20 September 2026The latest published official guidance for financial institutions and designated non-financial businesses and professions on implementation without delay.
  15. Central Bank of Iraq — Supreme National Committee for Regulating Virtual Assets, 14 December 2025Documents the start of government work on a comprehensive virtual-asset regulatory framework before the 2026 FATF plan.
  16. Security Council — Resolution 1718 Committee concerning the Democratic People's Republic of KoreaThe current international sanctions and weapons-of-mass-destruction proliferation-financing regime for North Korea.
  17. Security Council — Resolution 1737 Committee concerning IranThe international regime reinstated from 27 September 2025 concerning measures relating to Iran's proliferation programme.
  18. Security Council — 1737 list materialsDocuments re-establishment of the 1737 sanctions list after Security Council resolutions were reapplied in September 2025.
  19. Security Council — Consolidated sanctions listThe updated consolidated list of all persons and entities subject to Security Council measures.

Proposed legislation within Ali Zuweid's Political Programme · Prepared by

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