13 August 2025 –
A new civil society report by the Investigator Organization for the Rule of Law (IOL) paints a concerning picture of Iraq’s progress in implementing its anti-corruption obligations under Chapters II (Preventive Measures) and V (Asset Recovery) of the UN Convention against Corruption (UNCAC). Despite enacting anti-corruption laws and strategies, Iraq continues to struggle with deficiencies in enforcement, transparency, institutional independence, and public access to information. The report was produced with technical and financial support from the UNCAC Coalition.
Iraq has adopted national anti-corruption strategies and laws reflecting international standards, including the National Anti-Corruption Strategy 2021–2024 and the Anti-Money Laundering and Financing Terrorism Law of 2015. However, implementation has been undermined by institutionalized political interference, a lack of institutional capacity, and non-transparent governance. Civil society’s role in the design, monitoring, and evaluation of anti-corruption efforts ranges from severely restricted to non-existent, despite constitutional guarantees of participation and transparency. Meanwhile, the country’s oversight bodies face a chronic shortage of resources and are subject to political influence, further weakening their ability to fulfill their mandates.
Regarding asset recovery and money laundering, Iraq has made some legislative progress and has demonstrated a degree of institutional awareness, particularly in countering terrorist financing related to ISIS. In practice, however, the country has not developed the mechanisms or cross-border cooperation needed to meaningfully recover stolen assets. There is still no central registry of beneficial ownership, and Iraq lacks laws or procedures to return confiscated assets to their countries of origin.
The UNCAC review process of Iraq by Niue and Cameroon appears to be in its final stages, after a hybrid joint meeting took place on 6-7 June 2024. Despite Iraq’s commitment to transparency and the inclusion of civil society in the Implementation Review Mechanism at CoSP10, no formal information about the process has been made public. Additionally, it has not included any other stakeholders in its review process so far, and none of the review documents have been published on Iraq’s UNODC Country Review page.
Read the full civil society parallel report in English here, and the Arabic translation here.
Main Findings
Weak implementation of preventive measures of corruption
Iraq has enacted a range of laws and strategies aimed at combating corruption across different sectors. In practice, however, these efforts have had little impact. Institutions responsible for oversight, like the Federal Commission of Integrity and its counterpart in the Kurdistan Region, lack the independence, funding, and authority to carry out their work effectively. Senior positions are often politicized, with key roles left vacant or filled based on party affiliation rather than merit.
Key recommendation:
- Guarantee full independence, sufficient resources, and real transparency for oversight bodies, especially of the Federal and Kurdistan Region Commissions of Integrity, and appoint leadership through transparent and merit-based processes.
Public sector employment
Iraq’s public employment system still struggles with favoritism, limited transparency, and outdated laws. In practice, political favoritism often overrides qualifications. Jobs are frequently awarded through nepotism, vacancies are rarely announced publicly, and competitive exams are largely absent. Senior officials are appointed without transparency, often based on political or sectarian influence, and appeals against hiring decisions are allowed but rarely used or effective.
The public sector is bloated, with limited performance evaluations, weak salary transparency and reports of ghost employees. While asset declarations are legally required for public officials, enforcement is weak and the information is not made public. The inflation and economic strain have not triggered needed reforms.
Some oversight mechanisms exist, like the Commission of Integrity and civil service courts, but political interference and poor enforcement continue to undermine progress.
Key recommendation:
- Enact a new civil service law that ensures transparent, merit-based hiring and promotion, protects whistleblowers, requires public conflict of interest disclosures, introduces real performance reviews, and provides strong oversight and training systems.
Codes of conduct, conflicts of interest and asset declarations
Although Iraq has adopted several Codes of Conduct, in practice there is a lack of systematically-applied sanctions or disciplinary measures for non-compliance.
Senior officials are required to declare their assets, but these declarations are kept secret and are not subject to independent oversight. There is also no central system to manage conflicts of interest, and the few rules that exist are spread across different laws and are rarely enforced. The entities responsible for implementing the laws lack the necessary independence, sufficient resources, and expertise to ensure compliance.
Key recommendation:
- Set up a public, centralized system for asset disclosures and put clear, enforceable rules in place to identify and manage conflicts of interest throughout the government.
Political financing
Iraq faces major challenges in implementing rules and standards of political financing, including the control of major political parties over power and decision-making processes. Weaker political parties and entities have been pursued severely, sometimes beyond the legal framework, to exert pressure on them.
The Electoral Commission lacks independence and is controlled by the political parties. Vote buying and fraud have occurred in public office elections.
Key recommendation:
- Enhance transparency in political financing by regulating this area legally and ensuring sanctions are enforced in the case of non-compliance. Ensure budget reports are published online for the public to scrutinize during election cycles as well as afterwards. Grant the election oversight commission full independence and the necessary resources to effectively conduct its oversight role.
Protection of whistleblowers
Iraq has set up hotlines through both the Federal and Kurdistan Region Commissions of Integrity where people can report corruption, conflicts of interest, or violations of the Code of Conduct. In 2017, the country adopted a whistleblower protection law that offers some safeguards, such as anonymity and relocation, but only in cases involving criminal or terrorism-related offenses. People who report ethical breaches or conflicts of interest are not covered.
Although public employees are required by law to report corruption, they have little real protection if they do. The current legal framework does not address retaliation or harassment, especially within public institutions. A previous order that had provided some protections was repealed, and nothing has replaced it. These gaps discourage people from speaking up and weaken the overall fight against corruption.
Key recommendation:
- Update the whistleblower protection law to clearly prohibit retaliation in all cases, including ethical violations, and make sure there are proper procedures, independent oversight, and enough resources to enforce it.
Public procurement and management of public finances
Iraq has a solid legal framework for public procurement and financial management, including specific laws, regulations, and supervisory bodies tasked with oversight. Despite this, competitive procurement processes are frequently avoided through exemptions, undermining fair competition. Oversight bodies rarely publish evaluations or outcomes, and the lack of a right to information law means critical procurement and budget data remain inaccessible to the public and civil society.
When it comes to the national budget, public participation is virtually non-existent. Budget decisions are shaped behind closed doors, often influenced by political power rather than public priorities. Even when spending reports are released, they are often incomplete or too vague to be useful, making it hard for civil society, journalists, or ordinary citizens to hold the government accountable.
Key recommendation:
- Strengthen Iraq’s public procurement and financial management by improving transparency and public access to data, ensuring clear and enforceable rules against corruption, establishing independent review processes for procurement disputes, and requiring regular publication of budget and procurement reports. These reforms should align with UNCAC principles to foster competitive, transparent, and accountable public sector practices.
Access to information and participation of society
Iraq’s constitution protects freedom of expression and the press, but when it comes to accessing information about how the government works, there are big gaps. Outside of some limited rights for journalists, there are no broad laws or policies that allow ordinary citizens to see how public administration or decision-making happens. There have been many instances of journalists and people who point to corruption or dissent against the government being arbitrarily arrested.
The Kurdistan Region is a positive example, with a law that gives people the right to access information and an independent commission that monitors how well this law is followed. At the federal level, however, there are no formal rules to ensure transparency or public access to information, especially around corruption.
Public participation in lawmaking and budget decisions is minimal, and journalists who try to expose corruption often face threats and legal attacks. Although Iraq joined the Extractive Industries Transparency Initiative, concrete actions to increase transparency remain limited.
Key recommendations:
- Pass and enforce a clear right to access information law that sets out transparent procedures, oversight mechanisms, and proactive publication duties to break down secrecy and build trust between the government and the public.
- Stop restricting civil society organizations, and instead recognize them as a crucial stakeholder and partner of the government in the fight against corruption. Open consultations and enable their participation in legislative drafting processes.
The judiciary and prosecution services
The Iraqi Constitution guarantees the independence of the Judiciary and its separation from the Executive and Legislative powers. Despite facing significant challenges in combating corruption and holding corrupt individuals accountable, the Judiciary has taken important steps forward. These include a Code of Judicial Conduct in 2023, establishing Integrity Investigation Courts at the governorate centres, and forming a Judicial Oversight Authority to monitor judges and impose disciplinary measures against those proven to have committed legal violations. Punishment can include termination or reassignment, as decided by the Supreme Judicial Council.
To improve performance, the Judiciary also trains judges and public prosecutors through the Judicial Development Institute affiliated with the Supreme Judicial Council. However, it needs new measures to establish transparency, especially in publicizing criminal trials and overhauling the investigative system, especially in corruption cases.
Key recommendation:
- Ensure the independence of the Judiciary by enforcing constitutional and legal provisions, strengthening institutional and personal independence, achieving full financial and administrative autonomy, enhancing transparency, and reforming the investigative system, particularly for corruption cases.
Private sector transparency
Transparency in Iraq’s private sector remains extremely limited. There are no legal requirements for companies to publicly disclose who owns or controls them, and there is no accessible system in place to verify or share this information. The data that is collected through financial institutions’ due diligence efforts is kept confidential and shared only with law enforcement, leaving regulators, journalists, and the public in the dark.
While Iraq’s Trade Law and Companies Law include some basic bookkeeping obligations, enforcement is inconsistent. The legal framework does not clearly prohibit off-the-books transactions or fictitious entries, and there are few consequences for falsifying records. Oversight institutions lack the tools and independence to ensure compliance, and relevant data is rarely, if ever, published.
Key recommendation:
- Introduce strong legal requirements for corporate transparency, including mandatory disclosure of beneficial ownership, public access to company information, and proper enforcement of financial reporting standards.
Anti-money laundering
Iraq appears to have made meaningful progress in addressing money laundering and terrorist financing, especially related to ISIS. It has criminalized these offenses, established the Anti-Money Laundering and Financing Terrorism Office (AMLO) within the Central Bank, and joined international initiatives aimed at improving financial integrity.
However, implementation remains weak. The AMLO lacks independence, adequate funding, and effective enforcement powers. Compliance among financial institutions and other regulated entities is inconsistent, and oversight is limited.
Key recommendation:
- Publish statistics and facts on penalties imposed for non-compliance with the Anti-Money Laundering and Terrorism Financing Law and related instructions and regulations. Effectively enforce due diligence controls on politically exposed persons (PEPs) and high-risk individuals within financial institutions and designated non-financial businesses and professions, ensuring serious implementation and preventing the abuse of influence to obstruct them.
Asset recovery and international cooperation
While Iraq’s legal framework allows for confiscation of assets related to money laundering, its asset recovery regime suffers from serious practical and legal limitations. Non-conviction-based confiscation is only allowed in narrow circumstances, and there are no effective procedures for returning assets of foreign origin to their countries of origin. In many cases, recovered assets remain in Iraq’s control even when they are clearly linked to crimes committed abroad.
Additional barriers include bureaucratic delays, weak judicial cooperation, and the lack of mechanisms that allow foreign states to initiate or participate in asset recovery proceedings in Iraqi courts. Existing international agreements are rarely used in practice, and there are no clear rules for victim compensation or asset repatriation.
Key recommendation:
- Strengthen Iraq’s asset recovery systems by improving AMLO’s independence and resources, establishing a public beneficial ownership registry, enabling non-conviction-based confiscation, and creating clear legal pathways for cross-border cooperation, asset return, and victim compensation.