Treasury Says a Baghdad Bank Passed Dollars to Iran. The Bank Says It Did Not.
Washington has sanctioned an Iraqi bank it says Iran built to supply itself with dollars. The bank denies it, and Treasury has shown no transaction records. If Treasury is right, it is one channel among several the US has named. What makes it worth your time is what the case shows about who holds the tap on Iraq's dollars.
This is a story about a pipe. Treasury says one Iraqi bank used it to pass dollars to Iran. Those are allegations. Treasury has published no transaction records, the bank denies them, and as of October 17 we found no on-record statement from Iraq’s central bank. What can be shown is the pipe itself, the other leaks Treasury has alleged in it, and why this one bank’s case looks different from the ones before it.
Why one bank is worth your time
On Thursday, October 15, the US Treasury said an Iraqi bank called the International Development Bank for Investment and Finance “provides financial facilitation services and U.S. dollar access for Iran.” It put the bank under sanctions the same day. The bank says it “categorically” rejects the claims.
Why should anyone outside Baghdad care about one bank? Four reasons.
First, the depositors. The bank held about 2.6 trillion dinars in current accounts and deposits at the end of March, according to Iraqi Securities Commission data cited by the Beirut outlet Almodon, a figure Kurdistan24 also reported. About 1.5 trillion of that, more than half, belongs to ordinary citizens and traders, by the estimate of a source inside the bank. Neither figure is audited. In dollars: at the official rate of 1,520 dinars that Iraq’s cabinet set on October 7, 2.6 trillion dinars is about $1.7 billion and 1.5 trillion is about $1 billion. At the Baghdad market rate Shafaq News reported on October 8, about 1,668 dinars, they are about $1.6 billion and $900 million. The people holding those accounts are accused of nothing, and Iraq’s next banking day is Sunday, October 18.
Second, Iraq’s dollars. Oil makes up “about 90% of the state budget,” Reuters reported on September 30, and Reuters describes the oil revenue as held in “the custody of the Federal Reserve Bank of New York.” When Washington cuts off an Iraqi bank, it is using a hand that already sits on the tap.
Third, Iran’s dollars. Treasury alleges this bank sends its profits to Iran “in the form of U.S. dollars each month.” It gives no amount. And if Treasury is right, this bank is not the only route. Treasury has spent eight years naming Iraqi banks, oil smugglers and money-transfer firms that it says move money to Iran, and Iraq legally pays Iran billions of dollars a year for gas. Nobody has published a total.
Fourth, American pressure. The designation is part of a campaign Treasury calls Operation Economic Outcast, which it says “will continue to identify these banks and remove their access to the U.S. dollar.” Treasury Secretary Scott Bessent framed it this way: “The noose is tightening around Iran’s economy, and not even Iran’s so-called allies can save it.”
Two more things make this bank interesting rather than routine. Treasury framed its closest earlier Iraqi case, Al-Huda Bank, as terrorism finance: a bank it said the Revolutionary Guards controlled, moving money with forged paperwork. It frames this one mostly as Iranian business: a bank it says Iranian companies founded, that runs on Iranian capital and that sends its dollar profits home every month, though it also alleges ties to Iran-aligned militias. And in July, an Iraqi newspaper reported that this same bank was among seven that Iraq’s central bank called eligible to return to correspondent banking outside the dollar. Eighty-nine days later, Treasury listed it.
Half a billion dollars, held at the door
In April, a cargo plane shipment “carrying nearly $500m in US banknotes” bound for Iraq “was blocked by the US Department of the Treasury,” Al Jazeera reported, citing the Wall Street Journal. Iraq’s central bank did not mention the halt, but said it had “sufficient US currency reserves.” US officials told the Journal the suspension “was temporary.” In August, Iraqi state news, citing an unnamed official, reported that a new $500 million cash shipment had arrived from the Federal Reserve. Nothing we read shows that was the same cash.
That shipment is the whole arrangement in one object. The money was Iraq’s. The delivery was not up to Iraq.
Here is the pipe, by Reuters’s account. Iraq sells oil. The proceeds go to an account that began as the Development Fund for Iraq, which “eventually became an account of the Central Bank of Iraq at the New York Federal Reserve, as it remains today.” In August, Reuters described the United States as having “held effective control over the country’s oil revenue dollars.”
Think of a worker whose paycheck lands in an account at a bank across town. The money is his. But the cash reaches his kitchen table only when that bank sends it.
One caveat belongs right here. An analyst writing an opinion piece for Rudaw in March said Iraq’s foreign reserves were about $97.6 billion and that “only $2 billion sits in its accounts at the New York Fed.” Reuters says the oil revenue is in New York Fed custody. Those two statements may measure different things, revenue passing through versus reserves parked, or one may be wrong. We could not reconcile them.
For years, Iraq’s central bank sold those dollars on to the country’s banks. Reuters calls the system “dollar auctions, formally known as the foreign currency window.” “Private banks and exchange houses could bid daily to purchase US dollars using Iraqi dinars.” In 2024 the sales came to “$81 billion,” according to Manar Al-Abidi of the Iraq Future Foundation. Spread across the year, that is about $221 million a day.
The auction is gone now. On September 4, 2024, the central bank announced “the cessation of its electronic platform for foreign currency transfers,” which it framed as a transition. Reuters says Iraq “formally ended the auction system at the start of 2025,” and adds that it did so after significant US pressure. Those are two accounts of why. Reuters also reports that in 2020, “Washington reportedly threatened to cut Iraq’s access to the New York Federal Reserve funds.” The word “reportedly” is Reuters’s.
What Treasury says, and what it leaves out
Treasury’s release makes five specific allegations about the bank. Each is an allegation, not a finding by any court.
- The founders. “IDB was initially established by Iranian companies to support the Iranian economy and supply Iran with U.S. dollars.”
- The capital. “U.S.-designated Bank Melli, which was located next to IDB in Iraq, closed due to U.S. sanctions and transferred its capital to IDB.” Note the wording: located next to it. Treasury does not call it a branch.
- The profits. “IDB uses Iranian capital to conduct business, then collects any profit made and sends it back to Iran in the form of U.S. dollars each month.”
- The auction. “IDB has abused its access to the now-dissolved U.S. dollar wire auction.”
- The owners. “The bank’s current leadership received ownership of IDB from a dual-Iranian Iraqi financier working for” Iran’s Islamic Revolutionary Guard Corps-Qods Force, the IRGC-QF. “The financier continues to use his familial relationships to exert influence over the bank.” Treasury does not name him, and neither do we.
The release also says the bank “maintains ties to Iranian government entities and Iran-aligned militia groups (IAMGs) in Iraq.” The legal hook is narrower. “IDB is being designated pursuant to E.O. 13902 for operating in the financial sector of the Iranian economy.” That is the executive order aimed at Iran’s financial sector, not the terrorism order. OFAC’s listing dates the bank to January 11, 2011. The same OFAC update added 16 individuals and 11 entities in all.
A general license, GL FF, authorizes transactions “ordinarily incident and necessary to the wind down” of any transaction involving the bank until “12:01 a.m. eastern daylight time, October 30, 2026.” It has conditions: any payment to a blocked person must go into a blocked account, and it does not authorize other transactions the Iran sanctions rules prohibit. That is 15 days from the designation, which makes October 29 the last full day.
Now the gaps. The release gives no amount for the monthly profits, no date or dollar figure for the auction abuse, no name for the financier and no transaction records. We also checked what it does not mention: the Popular Mobilization Forces, Kata’ib Hizballah, Iraqi exchange houses and the Central Bank of Iraq appear nowhere in it.
Iraq, Iran, and a word about faith
To see why Iran has reach in Iraq’s money at all, start with the country’s makeup, and handle it carefully. Iraq is a majority-Shia country. A 2011 survey by Pew found that “Shia Arabs made up about half of Iraq’s population (49%),” Sunni Arabs “about a quarter (24%)” and Sunni Kurds “a somewhat smaller share (15%).” Those numbers are fifteen years old. The US State Department’s 2022 religious freedom report says Shia Muslims “constitute 55 to 60 percent of the Muslim population” and Sunni Muslims “approximately 40 percent.” Estimates differ, and none is a census.
Politics follows part of that map. After the November 2025 election, analysis by the Royal United Services Institute (RUSI) found that the Coordination Framework, an alliance of Shia parties that declared itself the largest bloc in parliament, gained seats, while the movement of Muqtada al-Sadr boycotted the vote. RUSI’s heading on Iran’s role: “Tehran’s Influence is Weakening But Still Crucial.”
The armed side is where Treasury points. In September, Treasury called Kata’ib Hizballah “the most influential faction within Iraq’s militia-dominated Popular Mobilization Forces (PMF),” and said it is a major beneficiary of “more than $2.6 billion in annual Iraqi government funding allocated to the PMF.” That is Treasury’s characterization. If it is right, some Iran-aligned groups draw on Iraq’s own state budget, not only on Iran.
Being Shia is not the same as being loyal to Iran. Iraq’s own Shia religious establishment has competed with Iran’s. “Sistani argues that religion and state affairs should be separated,” the scholar Mehmet Alaca wrote in 2020 of Ali al-Sistani, the Najaf cleric, adding that “after the US invasion in 2003, Najaf aimed to overtake Qom in the battle for influence.” The split reaches into the militias themselves. When the PMF made an appointment that year, Alaca wrote, “Pro-Sistani militias within the PMF immediately rejected Abu Fadak’s appointment on the grounds that they had not been informed beforehand.” Sadr does not fit a simple label either. “Muqtada al-Sadr is not anti-Iranian, he is better described as an Iraqi nationalist,” the analyst Harith Hasan told Carnegie in 2018.
So hold two facts together. Iran, by Reuters’s description, “wields considerable military, political and economic influence” in Iraq. That influence runs through specific militias, companies and banks that Treasury names, not through a religious community. Treasury’s release on this bank says nothing about sect, and we found nothing linking the bank to any sect or party.
One pipe among many
If Treasury is right about this bank, is it the only way Iran reaches Iraq’s money? Treasury’s own record says no. Reuters put it in one line: Iran “has avoided U.S. sanctions via its neighbour’s banking system.” Here are the channels the public record documents, from the legal ones to the ones Treasury calls crimes. Not all of them run the same way. Some carry money into Iran; others, by Treasury’s account, use Iraq’s banks to move Iran’s money on to its allies.
The legal channel: gas and power. Iraq pays Iran “$4 billion to $5 billion a year for natural gas used to generate electricity, Iraqi energy officials say,” Reuters reported in August, and Iraq’s trade with Iran “topped $10 billion in 2025, according to official figures.” That money is not a leak. It is a bill. But as of 2023, it was supervised. AFP reported in 2023 that Iraq’s payments for Iranian energy had to be held in a bank account, that Washington had agreed to move them to Oman, that Tehran could use them for imports of “food and medicines,” and that transactions “need to be approved by the US Treasury Department in advance.” We could not confirm how that arrangement works in 2026. The US waiver for direct electricity imports “expired on 8 March 2025 and was not renewed.” Iraq’s electricity ministry said banning gas imports too “would cause Iraq to lose more than 30 percent of its electricity energy.”
Other banks. In 2018 Treasury named Iraq-based al-Bilad Islamic Bank in an action saying Iran’s then central bank governor “conspired with the IRGC-QF to move millions of dollars through the international financial system,” and that the bank’s chairman helped the Qods Force “move funds from Tehran to Hizballah.” That case ran out of Iran, not into it. In January 2024 it said Al-Huda Bank “has been controlled and operated by the IRGC and the IRGC-QF” since its establishment and “has used forged documents to execute at least $6 billion in wire transfers out of Iraq.” In October 2025 it designated three Iraqi bankers, saying two of them, brothers, had laundered “tens of millions of dollars” for Iran. Reuters adds that while Washington sanctioned several Iraqi banks, “some of the largest banks were spared.”
Oil. In July 2025 Treasury said one businessman “runs a network of companies that have been selling Iranian oil falsely declared as Iraqi oil since at least 2020,” and that his companies “blend Iranian oil with Iraqi oil.” The networks in that action “have collectively transported and purchased billions of dollars’ worth of Iranian oil,” Treasury said. It also said he “has bribed many members of key Iraqi government bodies, including parliament,” and that employees of his company, VS Oil, “smuggle hard currency into Iran via cars and trucks, some of which carry millions of dollars each.”
Cash and money-transfer houses. On September 10, 2026, Treasury said a Dubai-based firm, Shams & Bahr Trading Company, was “used to remit millions of dollars from Iraq to Iran via the UAE.” It was designated under the same Iran financial-sector order as this bank.
The state budget. Beyond the $2.6 billion a year for the PMF, Treasury said in October 2025 that a company called Muhandis General Company diverts money from Iraqi government contracts.
Muhanad Seloom of the Middle East Council on Global Affairs summed up the cumulative picture to the Christian Science Monitor in August: “Over the years they have perfected a money-laundering machine in Baghdad that gets U.S. dollars and takes them to Iran.”
No one we found has published a total for what flows from Iraq to Iran across all of these. Treasury’s own releases give scale in pieces: “millions,” “tens of millions,” “at least $6 billion,” “billions.” They count different things over different years, and they cannot be added up. A plumber who finds water on the floor can fix the leak he can see. He cannot tell you how much water left through the walls.
Why this bank stands out
So if the pipe leaks in many places, why does this case matter? Because of the test it sits under.
A pawnshop owner cannot tell a real watch from a fake, so he makes a rule: bring the receipt. The rule works, until receipts become the thing worth forging.
Iraq’s dollar auction ran on paperwork. Treasury’s case against Al-Huda is the receipt forger’s version: forged documents behind at least $6 billion in wires out of Iraq, and dollars bought at the central bank’s auctions through “partially witting, unaffiliated individuals.” Those are Treasury’s allegations about Al-Huda, not about the bank in this story. But they show what a paper test invites.
Treasury’s case against this bank does mention the auction. It says the bank “abused its access,” without saying how or when. The weight of the release sits somewhere else: who founded the bank, whose capital it runs on, and where its profits go. Ownership is not a new line of attack. Treasury said Al-Huda had been “controlled and operated by the IRGC and the IRGC-QF” since its establishment, and it sanctioned Al-Huda’s owner. The releases emphasize different conduct: forged paperwork at Al-Huda, Iranian capital and monthly dollar profits at this bank. Both also allege ties to the IRGC, direct in Al-Huda’s case and through an IRGC-linked financier in this bank’s, and links to Iran-aligned militias. Which leaves a question the release does not answer. What checks were made on this bank’s owners, capital and transactions, and what, if anything, did they miss?
The trap in any screen is that tests get gamed. There is a second trap in this one: the public cannot check the screener’s work, because Treasury has published no transaction records.
The case differs from the earlier ones in three more ways.
The law. Al-Huda itself was named a primary money laundering concern under the Patriot Act; its owner, like the 2018 al-Bilad action, was handled under the terrorism order, E.O. 13224. This bank is designated under E.O. 13902, the Iran financial-sector order, the same one used against the Dubai money-transfer firm in September.
The timing. Treasury announced Operation Economic Outcast on August 24. On September 10, 17 days later, it designated Kata’ib Hizballah members and the Dubai firm. Bessent said then that the operation “is targeting those who continue to stand with the failing Iranian regime.” This bank came 35 days after that, 52 days after the launch.
The sequence. This part needs the most care. On July 18, Iraq’s central bank governor said there were seven banks “currently eligible to return to work within the external correspondent banking channel not linked to the dollar.” That is our translation of the central bank’s Arabic statement. Note the last words. He did not name the banks. Two days later, the regional business outlet Enterprise reported: “The CBI hasn’t confirmed the names of the seven banks, but Iraqi daily Al Mustaqila says they include” a list with “International Development Bank” on it. That is one newspaper’s list, never confirmed by the central bank.
On July 22, Treasury’s Office of Terrorism and Financial Intelligence said, according to The National, that “no banned banks have regained access to foreign currency transactions.” An analyst quoted in the same article said the reform process would take “years rather than months.”
On September 6, the governor, Nizar Nasser Hussein, said, per the National Iraqi News Agency (NINA): “No sanctions from international entities on the banking sector after today.” That is our translation of NINA’s Arabic report. NINA’s headline said seven banks were preparing to deal in currencies other than the dollar, and the report said they “may begin their work soon,” also our translation.
On October 15, Treasury designated the bank. From July 18 that is 89 days. From the governor’s September remark it is 39.
Read it fairly. The governor spoke of sanctions from international entities, and NINA’s report does not explain how his words square with Treasury’s July statement that no banned bank had regained access to foreign currency transactions, or with the designation that followed. Nothing we found shows the designation answered the July track. It is a sequence, not a cause. Nor are the two steps the same kind of judgment. The July step was eligibility for non-dollar correspondent banking under an understanding the central bank says it reached with Treasury. As The National described that track, “Once a restricted bank satisfies the required compliance and governance standards, it may be reintegrated into non-US-dollar correspondent banking channels.” That is a stage in a reform process, not a finding that a bank had no Iranian ties. The October step was a sanctions designation. If the July list is right, the bank was called eligible for one stage of one process and then designated under another.
There is one more wrinkle. On October 15, The National reported that “Iraq in 2024 banned the IDB and seven other local commercial banks from engaging in US dollar transactions.” We could not confirm that. The eight banks Iraq barred from dollar dealing in February 2024, as VOA reported, do not include this bank in the lists we read. Nor does the central bank’s restricted list as republished by Iraq Business News in February 2026, which names 28 restricted banks and four blacklisted ones. Bank Melli Iran is on that blacklist. The International Development Bank is not. Either a restriction was never published, or the report is mistaken. We do not know which, and we do not state it as fact.
The bank’s answer, and the people holding its deposits
The bank answered on Friday, October 16. “We categorically reject the claims made in the statement,” it said, as translated by The New Region. “Protecting depositors and customers remains a priority,” it said, as reported by Shafaq News. We did not obtain the bank’s full statement, and outlets’ translations differ.
Iraq’s central bank has been quieter. Almodon quoted an unnamed source inside the central bank who confirmed the sanctions. We found no on-record statement about what the central bank will do.
Iraq has a recent example of what a frozen bank looks like. On September 2 the central bank placed Al-Taif Islamic Bank under guardianship, a form of conservatorship, and on September 6 depositors protested outside over frozen funds. One of them, Fatima Hameed, told Shafaq she had 220 million dinars, about $168,000, in the bank. That was a different bank and a different case. Nothing we have read shows a run on this one, and we do not predict one. It shows what Sunday could look like if trust breaks.
“Iraqis simply do not put money in banks,” Victoria Taylor of the Atlantic Council told the Christian Science Monitor in August. The citizens and traders who did put money in this one, about 1.5 trillion dinars by the reported figure, have the least say in what happens next.
The case against, and the case for
Against. Sanctions may not change the thing they aim at. “I don’t think sanctions as a tool will necessarily place pressure on Iranian interference in Iraq as we may wish,” Taylor said. Tom Keatinge of RUSI, quoted by Reuters in August, spoke of “a strategy based on carrots rather than sticks.” Iraq also cannot cut every tie with Iran at once: it needs Iranian gas to keep the lights on, by its own ministry’s account. And Hiba Abdulwahib, an Iraqi researcher and analyst, told The National the move should not be viewed as a punishment for Iraq.
For. Treasury’s record on Iraqi banks is long and specific, from al-Bilad in 2018 to the bankers in 2025, and its oil and cash cases describe money moving by several routes at once. The release also warns that dealing with anyone designated “may risk the imposition of secondary sanctions on participating foreign financial institutions.” That warning works without a court. A foreign bank deciding whether to keep handling this bank’s payments does not need to know whether Treasury is right. It only needs to know what being wrong would cost it.
Both cases can be true at once. A tool can hit its target and still miss the larger problem.
What we cannot show
We found no independent evidence for the monthly dollar transfers, the Iranian capital, the Bank Melli transfer or the financier’s identity. We cannot say what the central bank will do, whether this bank was among the seven in July, whether Iraq barred it in 2024, how much of Iraq’s money sits in New York, or how much moves from Iraq to Iran in total.
What to watch
- Sunday, October 18. The first banking day after the designation. Watch for a central bank statement, withdrawal limits or queues, as reported by Shafaq, Rudaw or the central bank itself.
- The night of October 29. GL FF lapses at 12:01 a.m. Eastern on October 30. Watch OFAC’s recent-actions page for an extension or amendment.
- The central bank’s next move. A new restricted list (the last we saw is from February 2026), or a guardianship like Al-Taif’s, the middle path between business as usual and closure.
- The next Iraqi name. Whether Treasury designates another Iraqi bank under Operation Economic Outcast.
- December 31, 2026. Our call resolves.
Our call
We put it at 88 percent that the Central Bank of Iraq will not revoke this bank’s licence or order it into liquidation by December 31, 2026.
The 88 is our judgment, not a computed base rate. No clean base rate exists. The pattern we can document in Iraq is restrict and keep running. Al-Huda, the closest precedent, still appeared on the central bank’s restricted list in February 2026, as a restricted bank, two years after Treasury’s action. Al-Taif went under guardianship in September, not revocation. We did not check every bank on the restricted list for revocations, so we cannot say none occurred. The 12 percent covers a deposit run that forces the central bank’s hand, or Washington pressing for a closure.
The call is wrong if, by December 31, the central bank announces a licence revocation or liquidation, or a court orders one. A guardianship or conservatorship, a withdrawal freeze, a merger or a sale does not count. We check the central bank’s news page, the Iraqi News Agency and Shafaq News by January 5, 2027, and score it in public either way.
The bottom line
The next time you read that Washington has sanctioned a bank somewhere, ask two questions. Where do that country’s dollars actually live? And what test was the bank failing?
For Iraq, the first answer is in a Reuters sentence about the oil money, which sits in “an account of the Central Bank of Iraq at the New York Federal Reserve, as it remains today.” The second answer is in Treasury’s release. The auction screened paperwork. Treasury’s case against this bank rests on who founded it, whose money it runs on, and where the profits go. Those allegations raise a question about how the bank was vetted. The bank denies all of it. The people with the most to lose are the ones who only kept their money there.
Sources
- Treasury designation of the bank; Operation Economic Outcast; E.O. 13902; “U.S. dollar access” heading; the allegations (founding, Bank Melli capital, monthly profits, auction abuse, ownership, militia ties); the warning on secondary sanctions; Bessent quotes; August 24 launch date: U.S. Treasury, Oct 15 2026. Caveat: every claim about the bank is Treasury’s allegation; no transaction evidence published.
- OFAC recent action (16 individuals and 11 entities; establishment date): OFAC, Oct 15 2026. Caveat: entry fields read from a summary of the listing; Shafaq and UPI count 10 entities.
- General License FF (transactions “ordinarily incident and necessary to the wind down” through 12:01 a.m. EDT, Oct 30, 2026; blocked-account payments; no other ITSR-prohibited transactions authorized): OFAC, Oct 15 2026
- The bank’s denial (“Protecting depositors and customers remains a priority”): Shafaq News, Oct 16 2026; (“we categorically reject the claims made in the statement”): The New Region, Oct 16 2026. Caveat: full bank statement not obtained; translations differ.
- Deposits (2.6 trillion dinars at end-March 2026, per Iraqi Securities Commission data; about 1.5 trillion from citizens and traders, per a source inside the bank): Almodon (Arabic), Oct 16 2026, which also carries the anonymous central bank source; the same 2.6 trillion figure reported by Kurdistan24 via Hathalyoum, Oct 16 2026. Caveat: not audited.
- Exchange rates (official 1,320 to 1,520 dinars per dollar, Oct 7; Baghdad market 166,800 dinars per $100, Oct 8): Shafaq News, Oct 7 2026; Shafaq News, Oct 8 2026. Dollar conversions are our arithmetic.
- Oil about 90 percent of the budget; the DFI account at the New York Fed; “custody”; the auction (“foreign currency window”; daily bidding); the auction’s end “at the start of 2025”; the 2020 threat (“reportedly”): Reuters explainer via Khaleej Times, Sept 30 2026
- Reserves at the New York Fed ($2 billion of $97.6 billion): Rudaw, opinion, Mar 30 2026. Caveat: opinion piece; not reconciled with Reuters.
- 2024 auction sales of $81 billion (Manar Al-Abidi, Iraq Future Foundation): Shafaq News, Jan 15 2025. Caveat: one analyst’s figure.
- Central bank ends its electronic platform for foreign currency transfers: central bank announcement of Sept 4 2024, as reported by Shafaq News, Sept 4 2024.
- Blocked cash shipment of nearly $500 million (citing the Wall Street Journal); central bank “sufficient US currency reserves”: Al Jazeera, Apr 22 2026. Caveat: WSJ original not opened.
- August cash shipment: Al Jazeera Arabic, Aug 6 2026. Caveat: unnamed official via Iraqi News Agency; not shown to be the April cash.
- Iran’s influence in Iraq; sanctions avoided via Iraq’s banking system; “some of the largest banks were spared”; US “effective control” of oil dollars; $4 billion to $5 billion a year for gas; trade above $10 billion in 2025; Keatinge quote: Reuters via Al-Monitor, Aug 26 2026
- Victoria Taylor and Muhanad Seloom quotes: Christian Science Monitor, Aug 25 2026
- Iraq’s population shares (2011 survey): Pew Research Center, Aug 20 2014. Caveat: 2011 data.
- Shia 55 to 60 percent of Muslims: US State Department 2022 International Religious Freedom Report, Iraq, as reproduced by ecoi.net. Caveat: estimates differ; no census.
- November 2025 election (Coordination Framework gains; Sadr boycott; “Tehran’s Influence is Weakening But Still Crucial”): RUSI, Nov 19 2025
- Sistani on religion and state; Najaf and Qom; pro-Sistani PMF units: LSE Middle East Centre blog, Apr 3 2020. Caveat: 2020 analysis; Sistani’s current position not re-verified.
- Sadr as Iraqi nationalist (Harith Hasan): Carnegie Endowment, Jun 14 2018
- Kata’ib Hizballah in the PMF; $2.6 billion a year to the PMF; Shams & Bahr; Bessent’s Sept 10 quote: U.S. Treasury, Sept 10 2026. Caveat: Treasury’s characterizations.
- Said network (oil blending, “billions” collectively, bribery, cash by car and truck): U.S. Treasury, Jul 3 2025. Caveat: Treasury’s allegations.
- Al-Huda Bank (“controlled and operated by the IRGC” since establishment; owner designated; forged documents; at least $6 billion; auction purchases through unaffiliated individuals): U.S. Treasury, Jan 29 2024. Caveat: Treasury’s allegations.
- Iraqi bankers and Muhandis General Company (“tens of millions of dollars”): U.S. Treasury, Oct 9 2025. Caveat: Muhandis description paraphrased from the release.
- al-Bilad Islamic Bank (funds “from Tehran to Hizballah”): U.S. Treasury, May 15 2018
- Energy payments account, “food and medicines,” US Treasury pre-approval: AFP via Arab News Pakistan, Aug 2 2023. Caveat: 2023 reporting; 2026 status not confirmed.
- Electricity waiver ended Mar 8 2025; ministry spokesman Ahmad Moussa’s 30 percent warning: Al Jazeera, Mar 9 2025; waiver “expired on 8 March 2025 and was not renewed”: Enerdata, Mar 12 2025
- Eight banks barred, February 2024: VOA, Feb 4 2024
- Central bank restricted list (28 restricted, four blacklisted including Bank Melli Iran): Iraq Business News, Feb 23 2026. Caveat: the central bank may have updated the list since.
- The National’s report of a 2024 ban; Hiba Abdulwahib: The National, Oct 15 2026. Caveat: the 2024-ban claim is unconfirmed and conflicts with the published lists.
- July 18 “seven banks” statement and the understanding with Treasury (Arabic): Central Bank of Iraq, Jul 18 2026. Translation ours.
- Al Mustaqila’s list of the seven, relayed: Enterprise, Jul 20 2026. Caveat: one newspaper’s list; not confirmed by the central bank.
- Treasury: “no banned banks have regained access”; “years rather than months”; the reintegration stage (“Once a restricted bank satisfies…”): The National, Jul 22 2026
- Governor’s Sept 6 remarks (Arabic): National Iraqi News Agency (NINA), Sept 6 2026; English rendering crediting NINA: Iraq News Gazette, Sept 6 2026. Translation ours.
- Al-Taif depositors’ protest; Fatima Hameed: Shafaq News, Sept 6 2026