US Sanctions on Iraq: Exemptions and Immunities

The US Office of Foreign Assets Control (OFAC) has issued a notice outlining various exemptions and immunities for certain entities, individuals, and transactions in relation to the sanctions imposed on Iraq. This document provides key information on the exemptions, penalties, and reporting requirements related to these sanctions.

Exemptions

The following entities, individuals, and transactions are exempt from attachment under the sanctions:

• Cultural Property: Iraqi cultural property removed or suspected to be removed illegally is exempt from attachment.
• Central Bank of Iraq: Accounts, assets, investments, and other properties owned by the Central Bank of Iraq or the Development Fund for Iraq are immune from attachment, judgment, execution, or other judicial process in the United States.
• Iraqi Petroleum and Petroleum Products: Iraqi petroleum and petroleum products and interests are also exempt until title passes to the initial purchaser.

Penalties

Failure to comply with the sanctions may result in severe penalties:

• Civil Penalties: Up to $250,000 or twice the amount of the underlying transaction may be imposed for violating the sanctions.
• Criminal Penalties: Imprisonment for up to 20 years, or both, may be imposed upon conviction for willfully attempting to commit a violation.

Reporting Violations

If you have information about possible violations, please contact OFAC at 202/622-2430. This document serves as an explanatory notice and does not supersede the legally binding provisions of the Executive Orders and implementing regulations related to Iraq.