Etihad Law

Capital and Ownership Requirements for EPSPs in Iraq

Electronic Payment Service Providers (EPSPs) must meet capital and ownership requirements imposed by the Central Bank of Iraq to ensure financial strength, transparency, and sustainable operations. These requirements protect the integrity of the payment ecosystem and ensure that only qualified and suitable investors can control regulated entities. Both domestic and foreign applicants must demonstrate financial capacity, proper governance, and lawful sources of funds before obtaining a license.

Capital Requirements

  • Minimum paid-up capital thresholds set by the CBI.
  • Capital must be contributed in cash and from legitimate sources.
  • Adequate capital must be maintained throughout operations not only at licensing.
  • Additional capital buffers may be required for expansion of activities.

Ownership & Shareholder Requirements

  • Shareholders and ultimate beneficial owners must be disclosed.
  • Controlling shareholders undergo suitability (fit & proper) assessment.
  • Foreign ownership may be permitted subject to regulatory review.
  • Transfers of ownership or changes in control require prior approval.

Source of Funds

  • CBI will verify the legitimacy of investor funds.
  • Documentation may include bank statements, financial records, and net worth statements.
  • Corporate shareholders must provide audited financials and legal documentation.

CBI compliance

  • Maintain required capital levels on a continuous basis.
  • Notify CBI of changes in ownership or capital structure.
  • Seek approval for restructuring or capital increases.
  • Ensure shareholder financial soundness and transparency.
  • Comply with reporting and inspection requirements.

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.