FINANCIAL SERVICES REGULATORY UPDATES IN IRAQ: SANCTIONS LIST ENTRIES REMOVED

United Nations Security Council Announces Updates to Iraq Sanctions List

As of October 6, 2023, the United Nations Security Council has announced updates to the Iraq Sanctions List. As a result, one entry has been removed from the list and is no longer subject to an asset freeze.

Removed Entry: Walid Hamid Tawfiq Al-Tikriti

Walid Hamid Tawfiq Al- Tikriti, also known as Walid Al-Nasiri, had been listed on the sanctions list since July 2003. He was designated for his involvement with the former Government of Iraq and its state bodies, corporations or agencies.

Financial Institutions’ Responsibilities

Financial institutions and other persons are required to:

• Check whether they maintain any accounts or hold funds or economic resources for, or provide financial services to, designated individuals
• Freeze such accounts or funds if found
• Report their findings to the Financial Intelligence Unit (FIU)

Removal of Al-Tikriti’s Entry

The removal of Al-Tikriti’s entry from the sanctions list means that his assets are no longer subject to a freeze. However, failure to comply with financial and trade sanctions legislation is a criminal offence.

Resources for Further Information

• The Foreign, Commonwealth and Development Office will update the Consolidated List, which provides details of those designated under sanctions legislation.
• Further information on the UN measures in respect of Iraq can be found on the relevant UN Sanctions Committee webpage.
• The Isle of Man Government has provided further details on the sanctions regime related to Iraq and links to other financial sanctions regimes on its website.

Action Required

Financial institutions and individuals are advised to:

• Check their records for any accounts or funds linked to Al-Tikriti
• Take necessary action in response
• The Treasury has emphasized that attempting to circumvent the provisions of financial and trade sanctions legislation is a criminal offence.