Iraq

Retail_Trading_Status

Banned Unknown

Analysis ID: #119
Version: Archived
Created: 2025-04-12 06:48
Run: 60bb81f1...
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Workflow Stage: Live

Executive Summary

The Central Bank of Iraq (CBI) has banned the use and trading of cryptocurrencies for individuals and financial institutions since 2017, citing risks and lack of legal tender status. The CBI prohibits banks and other financial entities from engaging in crypto transactions, as outlined in Circular No. (125/5/9) and subsequent directives. While informal peer-to-peer trading persists, it operates outside the legal framework, and the CBI is exploring a Central Bank Digital Currency (CBDC).

Key Pillars

The primary regulator is the Central Bank of Iraq (CBI), which prohibits financial institutions from engaging in cryptocurrency transactions. Core compliance requirements are based on the Anti-Money Laundering and Counter-Terrorist Financing Law No. 39 of 2015. There is no licensing or registration framework for cryptocurrency exchanges or related businesses.

Landmark Laws

Circular No. (125/5/9), issued by the Central Bank of Iraq (CBI) on November 22, 2021, explicitly prohibits supervised financial institutions from engaging in transactions involving virtual assets or cryptocurrencies. * Anti-Money Laundering and Counter-Terrorist Financing Law No. 39 of 2015: Violations of cryptocurrency trading regulations may potentially be penalized under this law.

Considerations

Cryptocurrencies are not recognized as legal tender in Iraq. The Central Bank of Iraq has warned about the risks of financial crimes, volatility, and lack of consumer protection associated with cryptocurrencies. Despite the ban, informal peer-to-peer trading persists, facilitated by methods such as VPNs and international bank accounts. The Central Bank of Iraq is exploring the possibility of introducing a Central Bank Digital Currency (CBDC).

Notes

The ban on cryptocurrencies has been in place since at least 2017, with reiterations and reinforcements through subsequent directives. The Kurdistan Regional Government's Supreme Fatwa Committee issued a ruling against the OneCoin cryptocurrency scheme in 2018. The CBI is exploring the possibility of introducing a Central Bank Digital Currency (CBDC). Enforcement against individuals engaging in informal cryptocurrency trading remains unclear, and many traders bypass restrictions using VPNs and international bank accounts. The Central Bank of Iraq issued a warning to cryptocurrency users or dealers in 2021, stating that it does not guarantee or provide legal protection for those who deal with cryptocurrencies.

Detailed Explanation

The retail trading of cryptocurrencies in Iraq is officially banned. The Central Bank of Iraq (CBI) has been the primary driver of this policy, issuing directives prohibiting financial institutions, including banks, non-bank financial intermediaries, and electronic payment service providers, from engaging in cryptocurrency transactions. Key directives include Circular No. (125/5/9) issued on November 22, 2021, and a follow-up directive on March 26, 2022. The CBI has also forbidden the use of payment cards, e-wallets, and other financial instruments issued by regulated entities for cryptocurrency transactions. On December 16, 2024, the CBI confirmed it does not grant licenses to companies trading cryptocurrencies, stocks, and metals. This ban was initially put in place around 2017 and has been consistently reinforced. The CBI justifies its stance by stating that cryptocurrencies lack legal tender status, are not guaranteed by any official authority, and pose significant risks such as financial crimes (money laundering, terrorism financing), high volatility, and a lack of consumer protection. The CBI's actions align with FATF recommendations, and violations could be penalized under Iraq's Anti-Money Laundering and Counter-Terrorist Financing Law No. 39 of 2015. There is no regulatory framework for licensing or overseeing cryptocurrency exchanges. Despite the official ban, informal peer-to-peer (P2P) cryptocurrency trading persists, with individuals using VPNs, international bank accounts, or intermediaries in neighboring countries to circumvent restrictions. Platforms like "Kurdcoin" claim to operate as exchanges within Iraq, particularly in the Kurdistan Region, suggesting potential inconsistencies in enforcement. The Kurdistan Regional Government's Supreme Fatwa Committee issued a ruling against the OneCoin cryptocurrency scheme in 2018. Although a ban applies to financial institutions facilitating crypto transactions, the direct criminalization of individual possession or P2P trading outside the formal financial system might lack explicit statutory backing beyond the AML/CFT law context. The CBI is exploring the possibility of introducing a Central Bank Digital Currency (CBDC), which is distinct from allowing private cryptocurrencies.

Summary Points

Here's a bullet-point summary of the Retail_Trading_Status in Iraq, based on the provided report:

Retail Cryptocurrency Trading Status in Iraq: April 12, 2025

I. Overall Regulatory Status:

Banned: Retail cryptocurrency trading is officially banned in Iraq for both individuals and financial institutions.

II. Key Regulatory Bodies and Roles:

Central Bank of Iraq (CBI):
- Primary regulatory body responsible for the ban.
- Prohibits banks, licensed non-bank financial institutions, and electronic payment service providers from engaging in cryptocurrency transactions.
- Does not grant licenses to companies trading cryptocurrencies, stocks, or metals.
- Justifies the ban due to risks associated with cryptocurrencies (financial crimes, volatility, lack of consumer protection, absence of legal framework).
- Exploring the possibility of introducing a Central Bank Digital Currency (CBDC).
Kurdistan Regional Government's Supreme Fatwa Committee:
- Issued a ruling against the OneCoin cryptocurrency scheme in 2018, reinforcing the cautious approach.

III. Important Legislation and Regulations:

CBI Circular No. (125/5/9) (November 22, 2021): Explicitly prohibits supervised financial institutions from engaging in cryptocurrency transactions.
CBI Follow-up Directive (March 26, 2022): Reaffirmed the ban.
Iraq's Anti-Money Laundering and Counter-Terrorist Financing Law No. 39 of 2015: Violations of the ban may potentially be penalized under this law.

IV. Requirements for Compliance:

Financial Institutions: Must refrain from all cryptocurrency-related transactions.
Payment Service Providers: Prohibited from allowing the use of payment cards, e-wallets, and other financial instruments for cryptocurrency trading.
General Public: Warned against using cryptocurrencies due to risks and lack of legal protection.

V. Notable Restrictions and Limitations:

No Legal Tender Status: Cryptocurrencies lack legal tender status in Iraq.
Lack of Licensing: No regulatory framework exists for licensing or overseeing cryptocurrency exchanges.
Prohibition of Payment Instruments: Use of payment cards, e-wallets, and other financial instruments for cryptocurrency trading is prohibited.
Lack of Legal Protection: The CBI does not guarantee or provide legal protection for those who deal with cryptocurrencies.

VI. Recent Developments and Changes:

December 16, 2024: CBI announced it does not grant licenses to companies trading cryptocurrencies (along with stocks and metals).
Ongoing: CBI is reportedly exploring the possibility of introducing a Central Bank Digital Currency (CBDC).

VII. On-the-Ground Reality:

Informal Trading Persists: Despite the ban, informal, peer-to-peer (P2P) cryptocurrency trading continues among Iraqi individuals.
Circumvention Methods: Traders use VPNs, international bank accounts, or intermediaries in neighboring countries to bypass restrictions.
Platforms Claiming Operation: Platforms like "Kurdcoin" claim to operate as crypto exchanges, suggesting activity in a legal grey area.
Significant Risks: Engaging in informal trading carries significant legal and financial risks due to the official prohibition and lack of legal recourse for victims of fraud.
Unclear Enforcement: Direct criminalization of individual possession or P2P trading outside the formal financial system might lack explicit statutory backing beyond the AML/CFT law context, but it remains highly discouraged and without legal protection.

Full Analysis Report

Financial Regulatory Analyst Report: Iraq

Report Date: April 12, 2025
Subject: Current Status of Retail Cryptocurrency Trading in Iraq

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

1. Current Status: Banned

2. Detailed Narrative Explanation:

The official stance of the Iraqi government, primarily through the Central Bank of Iraq (CBI), is a prohibition on the use and trading of cryptocurrencies for both individuals and financial institutions. This ban has been in place since at least 2017 and has been reiterated and reinforced through subsequent directives.

Central Bank Directives: The CBI explicitly prohibits banks, licensed non-bank financial institutions, and electronic payment service providers from engaging in transactions involving cryptocurrencies or virtual assets. Circular No. (125/5/9) issued on November 22, 2021, is a key document outlining this prohibition. The CBI reaffirmed this stance in a follow-up directive on March 26, 2022. Furthermore, the CBI has explicitly forbidden the use of payment cards, e-wallets, and other financial instruments issued by regulated entities for speculative trading or transactions involving cryptocurrencies. On December 16, 2024, the CBI announced it does not grant licenses to companies trading cryptocurrencies (along with stocks and metals), confirming its commitment to pursuing legal measures against unlicensed or fraudulent operators.
Legal Basis and Rationale: The CBI justifies the ban by stating that cryptocurrencies lack legal tender status in Iraq and are not guaranteed by any official authority. They cite significant risks associated with these assets, including their use in financial crimes (money laundering, terrorism financing), high volatility, lack of consumer protection, and the absence of a robust legal and regulatory framework for virtual asset service providers (VASPs) within the country. The CBI's position aligns with efforts to comply with Financial Action Task Force (FATF) recommendations regarding virtual assets. Violations may potentially be penalized under Iraq's Anti-Money Laundering and Counter-Terrorist Financing Law No. 39 of 2015.
Lack of Licensing and Regulation: There is no specific regulatory framework in Iraq for licensing or overseeing cryptocurrency exchanges or related businesses. The CBI has explicitly stated it does not issue such licenses. This lack of regulation contributes to the high-risk environment.
Kurdistan Regional Government Stance: Reinforcing the cautious national approach, the Kurdistan Regional Government's Supreme Fatwa Committee issued a ruling against the OneCoin cryptocurrency scheme in 2018.
On-the-Ground Reality vs. Official Stance: Despite the clear official ban targeting the formal financial system, reports indicate that informal, peer-to-peer (P2P) cryptocurrency trading persists among Iraqi individuals. Traders often use methods to circumvent restrictions, such as Virtual Private Networks (VPNs), international bank accounts, or relying on intermediaries in neighboring countries. Platforms like "Kurdcoin" claim to operate as crypto exchanges within Iraq and the Kurdistan Region, suggesting activity exists in a legal grey area or potentially faces inconsistent enforcement, particularly outside the formal banking sector. However, engaging in such activities carries significant legal and financial risks due to the official prohibition and lack of legal recourse for victims of fraud. While the ban clearly applies to financial institutions facilitating crypto transactions, the direct criminalization of individual possession or P2P trading outside the formal financial system might lack explicit statutory backing beyond the AML/CFT law context, but it remains highly discouraged and without legal protection.
Distinction from CBDC: It is important to note that while Iraq prohibits decentralized cryptocurrencies, the CBI is reportedly exploring the possibility of introducing a Central Bank Digital Currency (CBDC) as part of efforts to modernize the financial system and reduce cash reliance. This is a separate initiative from allowing private cryptocurrencies.

In summary, the official regulatory status is a ban. The Central Bank actively prohibits financial institutions from participating in or facilitating crypto transactions and warns the public against their use due to significant risks and lack of legal protection. While informal trading occurs, it operates outside the legal framework and against official directives.

3. Relevant Text Excerpts:

On the Ban via Financial Institutions: "The Central Bank of Iraq (CBI) issued Circular No. (125/5/9) on 22 November 2021, explicitly prohibiting supervised financial institutions—including banks, non-bank financial intermediaries, and electronic payment service providers—from engaging in transactions involving virtual assets (Vas) or cryptocurrencies." (Source: Al Nesoor Law Firm, citing CBI Circular)
On Lack of Legal Tender Status: "The CBI underscored that such assets lack legal tender status, rendering them unenforceable as obligations redeemable for fiat currency or tangible commodities (e.g., gold)." (Source: Al Nesoor Law Firm, citing CBI)
On Prohibition of Payment Instruments: "...the circular prohibited the use of payment cards, e-wallets, and other financial instruments for speculative trading or transactions involving cryptocurrencies." (Source: Al Nesoor Law Firm, citing CBI Circular)
On General Prohibition and Rationale: "The Central Bank of Iraq (CBI) imposed a ban on cryptocurrencies in 2017, citing risks such as financial crimes, volatility, and consumer protection concerns. Banks, financial institutions, and payment service providers are prohibited from dealing with digital assets." (Source: Shafaq News / CEOWORLD Magazine)
On Lack of Licensing: "However, on December 16, 2024, the Central Bank of Iraq announced that it does not grant licenses to companies trading in stocks, metals, and cryptocurrencies." (Source: BasNews / Rudaw, citing CBI announcement)
On AML Law Application: "The Iraqi Central Bank has issued a statement prohibiting the use of cryptocurrencies. It stated that currency traders who carry out transactions in cryptocurrencies would be punished by penalties cited in the country's anti-money laundering law." (Source: Freeman Law, citing CBI)
On Persistence of Informal Trading: "Despite these restrictions, informal cryptocurrency trading persists, as enforcement against individuals remains unclear." (Source: Shafaq News / CEOWORLD Magazine) and "Despite this prohibition, many traders bypass restrictions anyway using VPNs and international bank accounts or rely on middlemen in neighboring countries..." (Source: Shafaq News)
On Lack of Legal Framework: "Iraq lacks a legal framework for forex trading; there is no official regulatory body overseeing digital currency transactions..." (Source: Shafaq News, quoting economic expert Ali Dadoosh - context includes crypto)
On Lack of Legal Protection: "...the Central Bank of Iraq issued a warning to cryptocurrency users or dealers in 2021, stating that it does not guarantee or provide legal protection for those who deal with cryptocurrencies." (Source: ResearchGate / Hasanuddin Law Review)

4. Source URLs:

Al Nesoor Law Firm (Analysis of CBI Circulars): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAI1PVVVUixo7e3cw351LZhv-Urs5ytHhrTcm5a4IAwzX4_K9FQ9VgwafWiI3dXJ8BYnKElhw4IRE-6H5OD1Zbui7Rvw4h-M9GW7pGkXJXTTSWK0MRfxXxdgiD6sG065ENcoW4cO8G7ltwEgi154Yqznp6Nx (Note: This links to the search result snippet containing the law firm's analysis; the original firm website may contain the full article).
BasNews / Rudaw (Report on Dec 2024 CBI statement): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIbKhPOIgbTxmlUdBANymMLnBVeKj-KQ_nOB2WeQqmwNwfXnKjpHb5at8kI3QkyKOm4gMFyt1-7noIpSNjJRkmU1mFUzq5PB3fOKRpB-2ai-m-DPU4x_XLXut544kIvAcyz0yO_E5SLt3m31Vl-5sWaW1KPwkjHGKAAwiF6NEWJEITaQOSHhgW9M8IG-Vrifr7qfTcVHPqlDt8ybdgF2mTXPff_H5PMJdQ= (Links to search result snippet).
Shafaq News (Report on Ban and Informal Trading): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALYE6jszePng29ZtLkzDdiYZqbeEXEWZa_i1mhowbBFOQsETFq2hdiE2ePQ0FZlc9FiYEALmEfC5gcCVlAXiHMs3yHAmz43sBlaxHVH9he-KyUGyOSdOT0XH5ZKykQORP7_a2pThdOFKIRDPRy5GYC3Ru6FGCWucGCf8b8s_x7YGw== and https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKR7WPe8a6ukp4S84P5TZog7qX4Du8q_EZTgRb_E58kkK8f4dJTS2-5tG9cVAVndz9dKZyHcW3PwrmxHIZ4-px6B2ljgyeQ-Aef3uT5u0CjfnCkkPcX6Pvm070ATHQNDIglFgt30z2YtPRJM6e9R_r23-9RJGGMRsHADin0ITHPJgjJ8MD3AyA87dCcHizGhUgeXTlbICw=
Freeman Law (Summary of Ban and AML Law): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALKaqiM34hCRPIgckl4ZcrSKNxmV4Tk_rPhKNyCFJDaV0Xw08x3kWucYBBqV9E-96iPywDrwzmH7K80oMbEGq33R-QZlc2N8BzAVZRm0EMiuvo5W0xZLNewsjZpFvVlZ1vTPeROC2Hh_OmG9i5lhIFwlFY83A==
UPay Blog (Summary of Ban): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIvnm-AHzioFJe9QB6nQ49rdjru4U3UzOhAMcj6-SS5mGDLq3whdt9QUNaHeFN5jNvLl9_5_tBsCOvfjF3ujd3dpZFvx6JOiTP21Hih1Ck5JwtUUQdEQRYnO3GK4pHKngEhsw==
ResearchGate / Hasanuddin Law Review (Academic Analysis): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJCToGMBN75P2Zkr0qItObOloQ83_ccQlLMallmY36DZrT9UJJIH5oPR6Iew97DoLzMhw2_lx1MLkSZSvg2eWaSuFj9kHoVFIp9rg1XA_HdawcAZybreHq6aX3R57rEgmBKAkhpQC-n5q9dz_JGSmiTsEUL1f0ai8FwUe0dfTp439eoEVFWldK4Bp468rUOzLRe-IzbiAJRwfY5irYGVk51kPW4KAfnPyrKr2AbXIxRSM3XvqQSJOPC3vjd1G1KVhaXBj1c4-1MoxG0aGgOm96KirOFx72IJJPoSAmb6pHFWuxznUrGm73YwUrLT5szBykNGaDoRMb5qWV0lSYYeW5MjkOkqN_8Nqzq9T1DCxyrsG2PfVch2sglczP1OxIJ3uyEOxexoZuQtSNXjk2plNGLpe74yhQrgbWV0U4qJEIm_QObGYZ0zs0QszHAUJo3Yvhd5_sY-wgxkYzqInUnfidH8SoYUcs-w0YsTtn-aQ== (Link to abstract/article page on ResearchGate).
Kurdcoin Website (Example of platform claiming operation): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALQYdBvf5S5ZX6UCYoR5afciM71LEQXgS62nLlV7zW8nMsAbjDgyJ8xrLXWExPNNGl9RF16uyDC5RJ6voAYdiMUTePC6l-UUxG0-Jc= and https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKMWEYoKKh_4e3EVtPJxnNBCQ3AH2pLtefp4l8fxjRCTwz8AGE8BAlpxH7LB8p62u123F7hNtwVizP8rzEl3NKsEt-13JA00nVDwRMAZa-H1nASjvbz6vhMG8y8nM9IQSq7J5TpLHDI7h4Uuyc6OTHuUjoo9-m5HQ== (Note: Inclusion does not imply endorsement or confirmation of legal compliance, but illustrates market activity).

End of Report

**Financial Regulatory Analyst Report: Iraq**

**Report Date:** April 12, 2025
**Subject:** Current Status of Retail Cryptocurrency Trading in Iraq

---

**Topic: Retail_Trading_Status**

**Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

---

**1. Current Status:** **Banned**

**2. Detailed Narrative Explanation:**

The official stance of the Iraqi government, primarily through the Central Bank of Iraq (CBI), is a prohibition on the use and trading of cryptocurrencies for both individuals and financial institutions. This ban has been in place since at least 2017 and has been reiterated and reinforced through subsequent directives.

*   **Central Bank Directives:** The CBI explicitly prohibits banks, licensed non-bank financial institutions, and electronic payment service providers from engaging in transactions involving cryptocurrencies or virtual assets. Circular No. (125/5/9) issued on November 22, 2021, is a key document outlining this prohibition. The CBI reaffirmed this stance in a follow-up directive on March 26, 2022. Furthermore, the CBI has explicitly forbidden the use of payment cards, e-wallets, and other financial instruments issued by regulated entities for speculative trading or transactions involving cryptocurrencies. On December 16, 2024, the CBI announced it does not grant licenses to companies trading cryptocurrencies (along with stocks and metals), confirming its commitment to pursuing legal measures against unlicensed or fraudulent operators.
*   **Legal Basis and Rationale:** The CBI justifies the ban by stating that cryptocurrencies lack legal tender status in Iraq and are not guaranteed by any official authority. They cite significant risks associated with these assets, including their use in financial crimes (money laundering, terrorism financing), high volatility, lack of consumer protection, and the absence of a robust legal and regulatory framework for virtual asset service providers (VASPs) within the country. The CBI's position aligns with efforts to comply with Financial Action Task Force (FATF) recommendations regarding virtual assets. Violations may potentially be penalized under Iraq's Anti-Money Laundering and Counter-Terrorist Financing Law No. 39 of 2015.
*   **Lack of Licensing and Regulation:** There is no specific regulatory framework in Iraq for licensing or overseeing cryptocurrency exchanges or related businesses. The CBI has explicitly stated it does not issue such licenses. This lack of regulation contributes to the high-risk environment.
*   **Kurdistan Regional Government Stance:** Reinforcing the cautious national approach, the Kurdistan Regional Government's Supreme Fatwa Committee issued a ruling against the OneCoin cryptocurrency scheme in 2018.
*   **On-the-Ground Reality vs. Official Stance:** Despite the clear official ban targeting the formal financial system, reports indicate that informal, peer-to-peer (P2P) cryptocurrency trading persists among Iraqi individuals. Traders often use methods to circumvent restrictions, such as Virtual Private Networks (VPNs), international bank accounts, or relying on intermediaries in neighboring countries. Platforms like "Kurdcoin" claim to operate as crypto exchanges within Iraq and the Kurdistan Region, suggesting activity exists in a legal grey area or potentially faces inconsistent enforcement, particularly outside the formal banking sector. However, engaging in such activities carries significant legal and financial risks due to the official prohibition and lack of legal recourse for victims of fraud. While the ban clearly applies to financial institutions facilitating crypto transactions, the direct criminalization of individual possession or P2P trading *outside* the formal financial system might lack explicit statutory backing beyond the AML/CFT law context, but it remains highly discouraged and without legal protection.
*   **Distinction from CBDC:** It is important to note that while Iraq prohibits decentralized cryptocurrencies, the CBI is reportedly exploring the possibility of introducing a Central Bank Digital Currency (CBDC) as part of efforts to modernize the financial system and reduce cash reliance. This is a separate initiative from allowing private cryptocurrencies.

In summary, the official regulatory status is a ban. The Central Bank actively prohibits financial institutions from participating in or facilitating crypto transactions and warns the public against their use due to significant risks and lack of legal protection. While informal trading occurs, it operates outside the legal framework and against official directives.

**3. Relevant Text Excerpts:**

*   **On the Ban via Financial Institutions:** "The Central Bank of Iraq (CBI) issued Circular No. (125/5/9) on 22 November 2021, explicitly prohibiting supervised financial institutions—including banks, non-bank financial intermediaries, and electronic payment service providers—from engaging in transactions involving virtual assets (Vas) or cryptocurrencies." (Source: Al Nesoor Law Firm, citing CBI Circular)
*   **On Lack of Legal Tender Status:** "The CBI underscored that such assets lack legal tender status, rendering them unenforceable as obligations redeemable for fiat currency or tangible commodities (e.g., gold)." (Source: Al Nesoor Law Firm, citing CBI)
*   **On Prohibition of Payment Instruments:** "...the circular prohibited the use of payment cards, e-wallets, and other financial instruments for speculative trading or transactions involving cryptocurrencies." (Source: Al Nesoor Law Firm, citing CBI Circular)
*   **On General Prohibition and Rationale:** "The Central Bank of Iraq (CBI) imposed a ban on cryptocurrencies in 2017, citing risks such as financial crimes, volatility, and consumer protection concerns. Banks, financial institutions, and payment service providers are prohibited from dealing with digital assets." (Source: Shafaq News / CEOWORLD Magazine)
*   **On Lack of Licensing:** "However, on December 16, 2024, the Central Bank of Iraq announced that it does not grant licenses to companies trading in stocks, metals, and cryptocurrencies." (Source: BasNews / Rudaw, citing CBI announcement)
*   **On AML Law Application:** "The Iraqi Central Bank has issued a statement prohibiting the use of cryptocurrencies. It stated that currency traders who carry out transactions in cryptocurrencies would be punished by penalties cited in the country's anti-money laundering law." (Source: Freeman Law, citing CBI)
*   **On Persistence of Informal Trading:** "Despite these restrictions, informal cryptocurrency trading persists, as enforcement against individuals remains unclear." (Source: Shafaq News / CEOWORLD Magazine) and "Despite this prohibition, many traders bypass restrictions anyway using VPNs and international bank accounts or rely on middlemen in neighboring countries..." (Source: Shafaq News)
*   **On Lack of Legal Framework:** "Iraq lacks a legal framework for forex trading; there is no official regulatory body overseeing digital currency transactions..." (Source: Shafaq News, quoting economic expert Ali Dadoosh - context includes crypto)
*   **On Lack of Legal Protection:** "...the Central Bank of Iraq issued a warning to cryptocurrency users or dealers in 2021, stating that it does not guarantee or provide legal protection for those who deal with cryptocurrencies." (Source: ResearchGate / Hasanuddin Law Review)

**4. Source URLs:**

*   **Al Nesoor Law Firm (Analysis of CBI Circulars):** `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAI1PVVVUixo7e3cw351LZhv-Urs5ytHhrTcm5a4IAwzX4_K9FQ9VgwafWiI3dXJ8BYnKElhw4IRE-6H5OD1Zbui7Rvw4h-M9GW7pGkXJXTTSWK0MRfxXxdgiD6sG065ENcoW4cO8G7ltwEgi154Yqznp6Nx` (Note: This links to the search result snippet containing the law firm's analysis; the original firm website may contain the full article).
*   **BasNews / Rudaw (Report on Dec 2024 CBI statement):** `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIbKhPOIgbTxmlUdBANymMLnBVeKj-KQ_nOB2WeQqmwNwfXnKjpHb5at8kI3QkyKOm4gMFyt1-7noIpSNjJRkmU1mFUzq5PB3fOKRpB-2ai-m-DPU4x_XLXut544kIvAcyz0yO_E5SLt3m31Vl-5sWaW1KPwkjHGKAAwiF6NEWJEITaQOSHhgW9M8IG-Vrifr7qfTcVHPqlDt8ybdgF2mTXPff_H5PMJdQ=` (Links to search result snippet).
*   **Shafaq News (Report on Ban and Informal Trading):** `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALYE6jszePng29ZtLkzDdiYZqbeEXEWZa_i1mhowbBFOQsETFq2hdiE2ePQ0FZlc9FiYEALmEfC5gcCVlAXiHMs3yHAmz43sBlaxHVH9he-KyUGyOSdOT0XH5ZKykQORP7_a2pThdOFKIRDPRy5GYC3Ru6FGCWucGCf8b8s_x7YGw==` and `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKR7WPe8a6ukp4S84P5TZog7qX4Du8q_EZTgRb_E58kkK8f4dJTS2-5tG9cVAVndz9dKZyHcW3PwrmxHIZ4-px6B2ljgyeQ-Aef3uT5u0CjfnCkkPcX6Pvm070ATHQNDIglFgt30z2YtPRJM6e9R_r23-9RJGGMRsHADin0ITHPJgjJ8MD3AyA87dCcHizGhUgeXTlbICw=`
*   **Freeman Law (Summary of Ban and AML Law):** `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALKaqiM34hCRPIgckl4ZcrSKNxmV4Tk_rPhKNyCFJDaV0Xw08x3kWucYBBqV9E-96iPywDrwzmH7K80oMbEGq33R-QZlc2N8BzAVZRm0EMiuvo5W0xZLNewsjZpFvVlZ1vTPeROC2Hh_OmG9i5lhIFwlFY83A==`
*   **UPay Blog (Summary of Ban):** `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIvnm-AHzioFJe9QB6nQ49rdjru4U3UzOhAMcj6-SS5mGDLq3whdt9QUNaHeFN5jNvLl9_5_tBsCOvfjF3ujd3dpZFvx6JOiTP21Hih1Ck5JwtUUQdEQRYnO3GK4pHKngEhsw==`
*   **ResearchGate / Hasanuddin Law Review (Academic Analysis):** `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJCToGMBN75P2Zkr0qItObOloQ83_ccQlLMallmY36DZrT9UJJIH5oPR6Iew97DoLzMhw2_lx1MLkSZSvg2eWaSuFj9kHoVFIp9rg1XA_HdawcAZybreHq6aX3R57rEgmBKAkhpQC-n5q9dz_JGSmiTsEUL1f0ai8FwUe0dfTp439eoEVFWldK4Bp468rUOzLRe-IzbiAJRwfY5irYGVk51kPW4KAfnPyrKr2AbXIxRSM3XvqQSJOPC3vjd1G1KVhaXBj1c4-1MoxG0aGgOm96KirOFx72IJJPoSAmb6pHFWuxznUrGm73YwUrLT5szBykNGaDoRMb5qWV0lSYYeW5MjkOkqN_8Nqzq9T1DCxyrsG2PfVch2sglczP1OxIJ3uyEOxexoZuQtSNXjk2plNGLpe74yhQrgbWV0U4qJEIm_QObGYZ0zs0QszHAUJo3Yvhd5_sY-wgxkYzqInUnfidH8SoYUcs-w0YsTtn-aQ==` (Link to abstract/article page on ResearchGate).
*   **Kurdcoin Website (Example of platform claiming operation):** `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALQYdBvf5S5ZX6UCYoR5afciM71LEQXgS62nLlV7zW8nMsAbjDgyJ8xrLXWExPNNGl9RF16uyDC5RJ6voAYdiMUTePC6l-UUxG0-Jc=` and `https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKMWEYoKKh_4e3EVtPJxnNBCQ3AH2pLtefp4l8fxjRCTwz8AGE8BAlpxH7LB8p62u123F7hNtwVizP8rzEl3NKsEt-13JA00nVDwRMAZa-H1nASjvbz6vhMG8y8nM9IQSq7J5TpLHDI7h4Uuyc6OTHuUjoo9-m5HQ==` (Note: Inclusion does not imply endorsement or confirmation of legal compliance, but illustrates market activity).

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**End of Report**

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