Etihad Law

Iraq AML Update – Shareholder Disclosure Requirements

Recent regulatory correspondence requires joint stock companies to provide the Companies Registration Department with updated information on shareholders holding not less than 10% of the company’s shares.

 

Key Update Highlights

  • Companies must submit the names of shareholders owning 10% or more of company shares
  • The requirement applies to joint stock companies
  • The purpose is to support sectoral risk assessment updates
  • The measure aims to mitigate risks related to:
    • Misuse of legal entities
    • Money laundering
    • Terrorist financing

 

Regulatory Objective

  • Enhancing transparency of ownership structures
  • Identifying beneficial owners
  • Strengthening AML/CFT compliance frameworks

 

What Companies Should Do?

  • Review current shareholding structure
  • Identify shareholders meeting the 10% threshold
  • Ensure accurate and up-to-date disclosure to the Companies Registration Department
  • Align internal records with AML/CFT requirements

 

Why This Update Matters: Failure to maintain accurate ownership disclosures may expose companies to regulatory scrutiny, compliance risks, or penalties, particularly in the context of AML/CFT enforcement.

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.