Kindly note that the Iraqi bank, Islamic Bank of Regional Cooperation for Development and Investment, with an email address of Taawenbank, reportedly is majority Iranian-owned. The bank, which has a branch in Iran, appear to have a close relationship with the Central Bank of Iraq. Its Iranian ownership not only represents an unacceptable risk for EU and North American banks, but it could be facilitating sanctions evasion through Iraq.
Add to this the fact that these Iranian banks were granted licenses to operate branches in Iraq:
(1) Parsian Bank
(2) Karafarin Bank
(3) Post Bank of Iran
(4) Keshavarzi Bank a/k/a Agribank
and the risk level for dealing with any Iraqi bank has now gone off the scale. Should you red-line all transactions with private Iraqi banks ? It appears that the answer must now be yes, especially after the focus on HSBCs transgressions with Iran in the Senate Report. You do not want any Iran sanctions violations found by regulators; therefore, it would be prudent to close your correspondent relationships with Iraqi financial institutions at this time.