Regulatory AlertsIraq: fintech & payments regulation
Partially regulatedNo specific fintech license; CBN regulates payments under banking law; securities regulated by ISC
- Lead regulator
- Central Bank of Iraq (CBN)
- Also involved
- ISC (securities) · NFIU (AML reporting)
- Core law
- Law No. 94 of 1987 (Banking) & CBN Guidelines
- Entry capital
- IQD 1 billion (Commercial Bank)
- Approval timeline
- —
- Customer assets
- Not explicitly segregated for non-bank fintechs
- Data protection
- No specific data protection law identified
- Sandbox
- No
Iraq lacks a dedicated fintech or e-money licensing regime. Payment processing and money transfer activities are regulated under the Central Bank of Iraq's (CBN) banking and electronic payment guidelines. The CBN requires strict AML/CFT compliance for electronic payment providers. Securities activities are overseen by the Iraqi Securities Commission (ISC) under Interim Law No. 74.
Which licence do you need?
| Your activity | Requirement | Capital | Timeline | Authority |
|---|---|---|---|---|
| Payment processing / gateway | LicenceElectronic Payment Service Provider License CBN regulates electronic payments; specific fintech license details unclear | — | — | Central Bank of Iraq |
| E-money & wallet issuance | Uncertainverify with regulator No specific e-money license regime identified in documents | — | — | — |
| Domestic money transfer | LicenceMoney Transfer License Likely requires CBN approval as banking/payment activity | — | — | Central Bank of Iraq |
| Cross-border remittance | LicenceRemittance License Cross-border flows subject to CBN forex controls and AML rules | — | — | Central Bank of Iraq |
| Agent network | Uncertainverify with regulator Agent network rules not specified in provided documents | — | — | — |
| Open banking / account information | Uncertainverify with regulator No open banking framework identified | — | — | — |
| Foreign-exchange services | LicenceForex Dealer License Forex trading regulated by CBN; strict controls apply | — | — | Central Bank of Iraq |
New — what changed recently
- 2025-10-30ISC Membership Requirements for ADX Trading — New requirements for Iraqi brokers to trade on ADX via Tabadul platform established.
- 2025-09-09ISC Regulatory Bylaw No. 35 of 2025 — Licensing framework for trading in foreign securities and commodities markets updated.
- 2024-07-22ISC Board Decision on Ashtar Gateway Listing — Approval for listing shares of Ashtar Gateway on the Unlisted Companies Platform.
Market-entry checklist
- 1Secure CBN Approval for PaymentsApply to Central Bank of Iraq for electronic payment service provider authorization.
- 2Establish AML/CFT ComplianceImplement monitoring for suspicious transactions as per CBN 2020 guidelines.
- 3Register with ISC for SecuritiesIf offering securities, obtain license from Iraqi Securities Commission under Law No. 74.
- 4Meet Capital RequirementsEnsure sufficient capital for banking or brokerage activities as mandated by CBN or ISC.