Etihad Law

AML Reporting Requirements for Banks

Anti-Money Laundering (AML) reporting is a mandatory compliance function for banks operating in Iraq. The regulatory framework—shaped by the Central Bank of Iraq (CBI) and aligned with FATF international standards—requires banks to monitor, detect, and report suspicious financial activities. The system aims to mitigate risks associated with financial crime, terrorist financing, sanctions breaches, and illicit cross-border movements of funds.

In practical terms, AML compliance is not only a regulatory obligation but a condition for maintaining correspondent banking relationships, international credibility, and access to foreign payment channels.

Core AML reporting obligations:

  • Suspicious Transaction Reports (STR)
  • High-value cash or threshold transaction reporting
  • Cross-border transfers (when applicable)
  • Customer due diligence (initial & ongoing)

Internal controls required within banks:

  • Designated AML Compliance Officer
  • Written AML/CFT policies and procedures
  • Enhanced due diligence for high-risk cases
  • Sanctions, PEP and watchlist screening
  • Automated monitoring systems (if available)
  • Mandatory staff training
  • Audit and record retention requirements

CBI compliance expectations

  • Establish risk-based AML frameworks
  • File reports in accordance with deadlines
  • Provide records during regulatory audits
  • Cooperate with supervisory inspections
  • Maintain transaction data for prescribed retention periods
  • Implement minimum technology and screening capabilities

How Etihad Can Assist

Etihad provides legal and regulatory advisory services to banks, financial institutions, and businesses, supporting compliance with applicable laws, regulations, and regulatory guidance issued by any competent authorities.