Etihad Law

Foreign Banks in Iraq: Branch vs Subsidiary vs Representative Office

Foreign financial institutions entering Iraq may structure their presence as a branch, subsidiary, or representative office, each with distinct regulatory and commercial implications.

Market Entry Models

  • Branch: operational presence allowing regulated banking activities; requires CBI licensing and minimum capital allocation.
  • Subsidiary: locally incorporated company fully subject to Iraqi banking regulations, tax, and corporate governance laws.
  • Representative Office: non-operational structure limited to market research, promotional and liaison functions; does not conduct financial transactions.

Strategic Considerations

  • Regulatory supervision & reporting
  • Capital adequacy & prudential requirements
  • Taxation and profit repatriation
  • Local management & staffing obligations
  • Long-term market strategy