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Iraq Imposes Stricter Sanctions and Compliance Regulations

New Regulations to Prevent Proliferation of Weapons of Mass Destruction

The Iraqi government has implemented a series of sanctions and compliance regulations aimed at promoting regional stability and preventing the proliferation of weapons of mass destruction.

Key Provisions of the New Regulations

  • Special Controls for Sensitive Items: Iraq has imposed special controls and license requirements for exports or reexports of sensitive items, including those controlled on the Commerce Control List (CCL) for national security, missile technology, nuclear nonproliferation, chemical weapons convention, and regional stability reasons.
  • License Requirements: A BIS license is required for the transfer within Iraq of any item subject to the EAR, unless specifically exempted. License exceptions are available for certain transactions, but only under stated conditions.

Types of Items Subject to Special Controls

  • Military End-Use or Military End-Users: Any item subject to the EAR that is intended for military end-use or military end-users requires a license from the US Department of Commerce’s Bureau of Industry and Security (BIS).
  • Civil Nuclear or Military Nuclear Activity: The Iraqi government has adopted a general policy of denial for license applications involving items destined for use in civil nuclear or military nuclear activity.
  • National Security or Nuclear Nonproliferation Reasons: Machine tools controlled for national security or nuclear nonproliferation reasons are also subject to special controls.
  • Production, Research, Design, Development, Support, Maintenance, or Manufacture of Iraqi Weapons of Mass Destruction: Items that would make a material contribution to the production, research, design, development, support, maintenance, or manufacture of Iraqi weapons of mass destruction are restricted.

Restrictive Measures for Listed Persons

  • Annex to Executive Order 13315 (E.O. 13315): Exports, reexports, or transfers of sensitive items to persons listed on the Annex to E.O. 13315 are restricted.
  • Designated by the Secretary of the Treasury: Items destined for persons designated by the Secretary of the Treasury pursuant to E.O. 13315 are also subject to restrictive measures.

Contact Information

  • Dedicated Hotline for Foreign Companies: Iraqi authorities have set up a dedicated hotline for foreign companies seeking clarification on specific aspects of the regulations: +1-202-482-4252.

Goal of the New Regulations

The move aims to strengthen Iraq’s commitment to non-proliferation and regional stability, while also ensuring compliance with international export control standards.