Crypto ATM / kiosk operator in Iraq

Decree: In February 2022 (and reiterated earlier), the Central Bank of Iraq (CBI) issued directives prohibiting the use, trading, and advertising of cryptocurrencies within Iraq. The CBI considers cryptocurrencies to be highly volatile, prone to fraud, and lacking proper regulatory oversight, posing risks to the financial system and national security.

Implication: This ban means that there are no legally operating cryptocurrency exchanges or virtual asset service providers in Iraq. Any entity engaging in such activities within Iraq would be doing so illegally.

Original Ban Directive (2021)

Re-affirmation and Enhanced Warnings (2023)

Outcome: All licensed banks, financial institutions, and payment service providers were prohibited from dealing in cryptocurrencies. This established the legal framework making crypto activities illegal in Iraq.

Outcome: Reinforced the existing ban, explicitly stating that using or dealing with cryptocurrencies is against Iraqi law and that violators would face legal consequences. It aimed to shut down any perceived loopholes or illicit operations. This was a significant re-emphasis of the country's hardline stance.

Law No. 39 of 2015 – Anti-Money Laundering and Combating the Financing of Terrorism Law: This is the primary legislation. It establishes the legal framework for combating money laundering and terrorist financing across all sectors of the Iraqi financial system. It aligns with international standards set by the Financial Action Task Force (FATF).

Iraqi Anti-Money Laundering and Counter-Terrorist Financing Office (AML/CFT Office): This office functions as Iraq's Financial Intelligence Unit (FIU). It is the central national authority responsible for receiving, analyzing, and disseminating suspicious transaction reports to law enforcement agencies. It is instrumental in investigating money laundering and terrorist financing cases, including those potentially involving virtual assets acquired or used illegally.

Central Bank of Iraq (CBI): The CBI is the primary regulator and supervisor for banks and other financial institutions in Iraq. It issues directives and guidelines related to AML/CFT for entities under its supervision and enforces compliance. It also issued the direct ban on cryptocurrencies.

Blanket Ban: Because crypto is outright banned, enforcement tends to fall under broader financial crime or anti-money laundering laws rather than specific crypto-related administrative fines.

Focus on Prevention: The primary "enforcement" has been through strong warnings and directives to prevent engagement rather than publicized actions against a large number of violators.