Map the service and the movement of money
Prepare a product diagram showing the customer, merchant, platform, bank, payment provider and settlement accounts. Identify who receives funds, who owes the customer money and who can reverse or block a transaction. Include agents, distributors and overseas service providers where they are involved.
The Central Bank of Iraq has published Electronic Payment Services Regulation No. 2 of 2024 and additional technology, payments and compliance materials. These sources should be reviewed against the specific service and the latest applicable instructions. A company registration certificate alone does not establish the scope of financial services permission.
Build licensing into the launch plan
Financial services licensing in Iraq can influence the proposed ownership, governance, operating model and supplier arrangements. Identify the relevant approval questions before finalising customer terms or promising a launch date. Where the business intends to partner with a licensed provider, document exactly which party performs each regulated function.
The legal review should connect with technical and compliance design. Consider customer identification, complaints, transaction records, fraud escalation, cybersecurity responsibilities and business continuity. A contract assigning a task to a supplier should explain how the business will obtain the information needed to supervise that task.
Write terms that match the product
Customer-facing documents should describe charges, permitted use, transaction handling, complaints and termination in language consistent with the actual service. Avoid copying terms from a foreign platform whose licensing model and payment flow are different.
Fintech regulation in Baghdad also requires continuing attention after launch. Product changes, additional partners and new customer segments should trigger a fresh assessment rather than being treated as routine marketing decisions.
Contact Etihad Law with a product summary, funds-flow diagram and intended contractual structure to discuss the legal review. These documents help separate software questions from payment or other financial services issues and identify the decisions needed before launch.