Self-custodial wallet / non-custodial software in Iraq
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is not permitted in Iraq.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
Key Restrictions
- The CBI has imposed a blanket ban on the use, trading, and advertising of cryptocurrencies (February 2021 and reiterated in February 2023).
- All financial institutions, payment service providers, and the general public are prohibited from dealing in cryptocurrencies.
- Even non-custodial software publishing may be construed as facilitating or promoting crypto activities, which is deemed illegal under the ban.
Key Risks
- Publishing self-custodial wallet software accessible to Iraqi residents could be treated as advertising/promoting crypto, which is explicitly prohibited.
- Legal consequences for violators include potential criminal liability under broader financial crime laws — no specific crypto-licensing regime exists to provide safe harbor.
- Lack of regulatory transparency and due process for crypto-related enforcement actions.
- The ban is comprehensive and not limited to custodial services — the CBI directives do not distinguish between custodial and non-custodial models.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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)
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.
Re-affirmation and Enhanced Warnings (2023)
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.
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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
No — self-custodial wallet software cannot be lawfully published or made available to Iraqi residents under the Central Bank of Iraq's comprehensive cryptocurrency ban, which prohibits the use, trading, and advertising of all cryptocurrency activities without distinguishing between custodial and non-custodial models.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?