Information as of: 31st July 2022

Latest Updates

Financial/Other Sanctions
UN S/Res/1483 (2003), updated 2010 S/Res/1956, effective 30 Jun 2011.
US EO 13350. Updated by EO 13668 - effective 27 May 2001. EO 13303 . Updated by EO 13315 , EO 13350 , EO 13364 , EO 13438 and EO 13668 .
EU 2003/495/ CFSP (most recently updated Feb 2011 - 2011/100/CFSP).
The Iraq (Sanctions) (EU Exit) Regulations 2020 wef: 31 Dec 2020. 
Arms Embargo
UN S/Res/1483 (2003, updated 2006).
US Yes
EU 2003/495/ CFSP (most recently updated Feb 2011 - 2011/100/CFSP.
The Iraq (Sanctions) (EU Exit) Regulations 2020 wef: 31 Dec 2020. 
Further Details
UN S/Res/1483 (May 2003) lifted trade / financial sanctions against Iraq (arms embargo remains), but freezes assets of designated individuals, prohibits trade of cultural artefacts, requires proceeds from petroleum etc. to be deposited into Development Fund for Iraq (lifted after 30 Jun 2011 (S/Res/1956), however 5% of proceeds from such exports to be paid into compensation fund (S/Res/687) & 5% of non-monetary payments of petroleum etc. to service providers to be paid into fund). List of designated persons regularly updated.
US May 2003 (EO 13303), July 2004, effectively lifted trade sanctions on Iraq, including financial transactions. Measures remain on designated entities & trade in cultural items (EO 13350). EO 13303 updated by EO 13315, EO 13438. On 21 May 2020 all restrictive measures under EO 13303 were renewed for a further year.  The US renewed all restrictive measures under EO 13303 until 22 May 2022 and again  renewed until 22 May 2023. Some U.S. exports require a license from government. Transactions with Iraqi State companies such as Iraq Reinsurance Company & Iraqi Airways now permitted in certain circumstances. Sep 2010 - amendment to existing measures - removal of the Iraqi Sanctions Regulations & addition of the Iraq Stabilization & Insurgency Sanctions Regulations ("ISISR"). EO 13668 - effective 27 May 2014: terminates prohibitions with respect to the Development Fund for Iraq and Iraqi petroleum, petroleum products, interests therein and the accounts, assets, investments, and other property owned by, belonging to, or held by, in the name of, on behalf of, or otherwise for, the Central Bank of Iraq.
EU Implemented UN requirements in respect of deposit of petroleum proceeds into Development Fund for Iraq (Reg 175/2009, Mar 2009). EU Council Reg 85/2013 (1 Feb 2013) amendment to the exception of freezing of funds & economic resources & UK implemented same 21 Feb 2013. Council Reg 791/2014, effective 22 Jul 2014, provides for specific exemptions for providing funds or economic resources to listed entities and persons. Commission Implementing Regulation 2016/1453 delists several entities from SDN list including Iraqi Airways Company effective 5 Sep 2016. Effective 23 Dec 2016 Reg 2016/2363 removes several entities related to the oil and gas industries. 20 Jul 2018 EU Reg 2018/1025 removes National Insurance Company (Iraq) and Iraqi Life Insurance Company from list. Designated entities list updated periodically.
The Iraq (Sanctions) (EU Exit) Regulations 2020 incorporates EU sanctions into UK law wef: 31 Dec 2020. 
This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.