In July 2026, the Central Bank of Iraq and the U.S. Treasury reached
an understanding that created, for the first time, a phased
rehabilitation track for Iraqi banks: completion of the first phase
of the CBI's banking sector reform and relicensing program restores
access to non-dollar correspondent channels, and completion of the
remaining compliance and governance requirements restores
eligibility for U.S. dollar transactions.
The gate at every phase is the same: evidence. Not policies on
paper, but demonstrable, independently verifiable proof — of
screening, of beneficial-ownership transparency, of governance in
operation, of record integrity. Banks that can produce that evidence
move forward. Banks that cannot, wait.