Etihad Law

Senior Leadership Appointments in Banks

Appointments to senior leadership positions in Iraqi banks require regulatory clearance due to the impact these roles have on governance, risk oversight, and compliance. Positions such as Board Members, CEO, CFO, Chief Risk Officer, and Compliance/AML Officers are subject to CBI review to ensure competence, integrity, and suitability (“fit and proper”) of appointees. The process aims to strengthen governance and reduce financial stability risks.

In practice, banks cannot finalize key appointments without CBI approval, making planning and documentation essential for regulatory compliance.

Positions typically requiring CBI approval

  • Board of Directors (Executive & Non-Executive)
  • Chief Executive Officer (CEO / GM)
  • Chief Financial Officer (CFO)
  • Head of Internal Audit
  • Head of Risk Management
  • Compliance & AML Officers
  • Senior Management with control functions

Documentation typically required:

  • Curriculum Vitae and qualifications
  • Professional certificates (if applicable)
  • No-criminal-record certificates
  • Experience statements
  • Declaration of financial soundness
  • Conflict of interest declarations
  • Identification and corporate approvals

CBI compliance expectations

  • Conduct internal fit & proper checks
  • Ensure adequate experience in banking/finance
  • Verify integrity and financial standing
  • Submit documents for regulatory review
  • Notify CBI of changes in leadership roles
  • Maintain governance structures aligned with supervisory expectations

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.