How effective are Suspicious Transaction Reporting System in Iraq?
DOI:
https://doi.org/10.35246/ank2mv33Keywords:
Iraq, Suspicious, Money laundering, Office, AML/CTFAbstract
Purpose - A cornerstone of the global anti-money laundering framework is the requirement that financial institutions are obligated to file suspicious transactions reports (STRs) to financial intelligence units. This obligation has been established by the Financial Action Task Force (FATF) Recommendations, the European Community Directive, and also the Iraqi Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Act No.39 of 2015. The objective of this Article is to evaluate the effectiveness of the anti-money laundering reporting regime in Iraq in respect of suspicious transaction reports.
Design/methodology/approach - A descriptive approach is used to explore the result of the anti-money laundering (AML) process in Iraq. The research is based on the secondary data published in the Annual Reports of the Anti-Money Laundering and Combating the Financing of Terrorism Office in Iraq from 2016-2024 and Middle East and North Africa Financial Action Task Force (MENAFATF), Mutual Evaluation Report of Iraq in May 2024, which covers the period 2018-2022.
Findings - It is evident that the effectiveness of the Iraqi reporting suspicious transactions regime is questionable, given the relatively low number of STRs reported in light of the country's large exposure to high level of corruption, drug trafficking, fraud, human trafficking and other unlawful activities.
Research limitations/implications - The assessment of Iraqi STR regime is limited due to the lack of reliable statistics regarding the scope of money laundering (ML) activities.
Originality/value - There exists a considerable scarcity of scholarly research evaluating the reporting suspicious transaction regime under the Iraqi AML/CTF Act. Therefore, this Article seeks to provide an examination of the effectiveness of the Iraqi STRs regime. It is hoped that the study offers insights for researchers, banks, practitioners, and policymakers in Iraq.
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References
Books
I. Stressens, G, Money Laundering: A New International Law Enforcement Model (1st, Cambridge University Press 2000).
B. Journal Articles
I. Chaikin, D, ‘How effective are suspicious transactions reporting systems? ’ (2009) 12(3) Journal of Money Laundering Control.
II. Fleming, M, ‘Issues in measuring the efficacy of a suspicious activity reports (SARs) regime’ (2007) 70 Amicus Curiae.
III. Goldby, M, ‘Anti-Money Laundering Reporting Requirements Imposed by English Law: Measuring Effectiveness and Gauging the Need for Reform’ (2013) Journal of Business Law.
IV. Harvey, J, ‘Compliance and reporting issues arising for financial institutions from money laundering regulations: a preliminary cost benefit study’ (2004) 7 (4) Journal of Money Laundering Control.
V. Johnston, R, and Carrington, I, ‘Protecting the financial system from abuse: Challenges to banks in implementing AML/CFT standards’ (2006) 9(1) Journal of Money Laundering Control.
VI. Levi, M, ‘Money Laundering and Its Regulation’ (2002) 582 (1) The ANNALS of the American Academy of Political and Social Science.
VII. Mariappan, B, and Haq, I, ‘Suspicious transaction reporting: an Indian experience’ (2015) 18(1) Journal of Money Laundering Control.
VIII. Rahman, A, ‘The impact of reporting suspicious transactions regime on banks: Malaysian experience’ (2013) 16 (2) Journal of Money Laundering Control.
IX. Sarigul, H, ‘Money Laundering and Abuse of the Financial System’ (2013) 2(1) International Journal of Business and Management Studies.,
X. Suntura, J, ‘Improving the detection and reporting of suspicious financial transactions: the Spanish case’ (2022) 25(4) Journal of Money Laundering Control.
XI. Subbotina, N, ‘Challenges that Russian banks face implementing the AML regulations’ (2009) 12(1) Journal of Money Laundering Control.
C. Chapter Books
I. Campbell, A, and Campbell, E, ‘Money Laundering and the consent regime in the United Kingdom – time for change? ’ in Barry Rider (ed), Research Handbook on International Financial Crime (Edward Elgar Publishing Limited 2015).
D. Conventions
I. United Nations Convention against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (1988).
II. United Nations Convention against Transnational Organised Crime (2000).
III. United Nations Convention against Corruption (2003).
E. Laws
I. Coalition Provisional Authority Order Number 93 of 2 June 2004, Anti-Money Laundering Act of 2004.
II. Anti-Money Laundering and Counter-Terrorism Financing Act No. (39) of 2015.
F. Websites
I. Aidoo, S, ‘Case Studies of AML Compliance Failures: Lessons Learned and National Interest Implications’ (2025). Available at <https://www.researchgate.net/publication/393799079_Case_Studies_of_AML_Compliance_Failures_Lessons_Learned_and_National_Interest_Implications> (Accessed 20 November 2025).
II. Basel Committee on Banking Supervision, Prevention of criminal use of the banking system for the purpose of money-laundering (28 December 1988). Available at <https://www.bis.org/publ/bcbsc137.pdf > (Accessed 30 August 2025).
III. Council Directive 91/308/EEC of 10 June 1991 on Prevention of the Use of the Financial System for the Purpose of Money Laundering. Available at <https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:31991L0308 > (Accessed 30 August 2025).
IV. Financial Action Task Force on Money Laundering (1990). Available at <https://www.fatf-gafi.org/content/dam/fatf gafi/recommendations/FATF%20Recommendations%201990.pdf > (Accessed 30 August 2025).
V. Financial Action Task Force on Money Laundering, Report on Non-Cooperative Countries and Territories, (14th February 2000). Available at <https://www.fatf-gafi.org/content/dam/fatf-gafi/annual-reports/Initial%20Report%20on%20NCCTs%2002_2000.pdf> (Accessed 31 August 2025).
VI. Fleming, M., ‘UK Law Enforcement Agency Use and Management of Suspicious Activity Reports: Towards Determining the Value of the Regime’ (UCL 2005) p.27 Available at <https://www.ucl.ac.uk/news/2005/sep/anti-money-laundering-regime-comes-under-scrutiny > (Accessed 20 November 2025).
VII. Lander, S, ‘Review of the Suspicious Activity Reports Regime’ (Serious Organised Crime Agency), (2006). Available at (Accessed 1 October 2025).
VIII. Middle East and North Africa Financial Action Task Force, Anti-money laundering and counter-terrorist financing Measures (Mutual Evaluation Report of the Republic of Iraq, May 2024) p.69. Available at < https://www.fatf-gafi.org/en/publications/Mutualevaluations/MER-Iraq-2024.html > (Accessed 20 November 2025).
IX. Sun, M, Nordea to Pay $35 Million for Anti-Money-Laundering Violations, (27 August 2024) The Wall Street Journal, Available at <https://www.wsj.com/articles/nordea-to-pay-35-million-for-anti-money-laundering-violations-0916fddd > (Accessed 3 November 2025).
X. Tawfeeq, M, ‘Iraq Estimates That $150 Billion of its Oil Money Has Been Stolen From the Country Since the US-led Invasion of 2003’ (CNN 2021). Available at <https://edition.cnn.com/2021/05/23/middleeast/iraq-oil-money-us-invastion-intl > (Accessed 17 November 2025).
XI. The House of Commons Home Affairs Select Committee, ‘Proceeds of
Crime’ Fifth Report of Session 2016/2017.’ Available at <https://publications.parliament.uk/pa/cm201617/cmselect/cmhaff/25/25.pdf> (Accessed 4 September 2025).
XII. Transparency International, Corruption Perceptions Index (2024). Available at < https://www.transparency.org/en/cpi/2024/index/irq > (Accessed 17 November 2025).
XIII. The U.S. Department of Justice, (Press Release 10 October 2024). Available at < https://www.justice.gov/archives/opa/pr/td-bank-pleads-guilty-bank-secrecy-act-and-money-laundering-conspiracy-violations-18b> (Accessed 3 November 2025).
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