OFAC extends wind-down licence for Iraq's International Development Bank

The US Office of Foreign Assets Control has given US persons until 1 December to wind down dealings with Iraq's International Development Bank for Investment and Finance, a month longer than first allowed, OFAC said on 29 October in General License FF-1.

The licence authorises transactions prohibited by the Iranian Transactions and Sanctions Regulations that are "ordinarily incident and necessary to the wind down" of any transaction involving the bank, also known as Iraq Development Bank, or any entity it owns 50 per cent or more of, directly or indirectly. The authorisation runs until 12:01 a.m. eastern standard time on 1 December 2026. Any payment to a blocked person must still be made into a blocked account.

FF-1 replaced General License FF in its entirety from 29 October, paragraph (c) of the new licence says; OFAC's recent actions notice of the same day lists the issuance. The original licence, dated 15 October, ran only until 12:01 a.m. eastern daylight time on 30 October, 15 days after the designation; the extension stretches that window to about six and a half weeks. The new licence keeps the same limit: it does not authorise any other transaction prohibited by the regulations, including dealings with any other blocked person, unless separately authorised.

Treasury designated the bank on 15 October under Executive Order 13902, saying in its press release that the bank provides US dollar access and financial facilitation for Iran; our report on the designation sets out the department's statements and the listing details. OFAC's listing of 15 October gives the bank's addresses on Arasat Avenue in Baghdad's Karrada district, its SWIFT/BIC code IDBQIQBA and its legal entity identifier, which screening teams use to match payment messages. The documents reviewed record no statement from the bank or from Iraqi authorities on the licence.

FF-1 is signed by Bradley T. Smith, OFAC's director. For banks, payment firms and traders with open positions, the change is one of timing only: the licence covers winding down existing business, not new dealings, and payments owed to the bank still go to blocked accounts. OFAC amended 11 of its published answers on blocking, rejecting and reporting transactions on 26 October.