Are there any license requirements specific to transfers of items within Iraq?
Yes. As noted above, a license is required to transfer, within Iraq, items controlled for export or reexport to Iraq. In addition, transfers of items subject to the EAR within Iraq to designated terrorists or terrorist organizations, as set forth in sections 744.12, 744.13, or 744.14 of the EAR, and transfers to any persons referenced in section 744.18 of the EAR, require a license. Finally, the EPCI requirements also apply to the transfer within Iraq of any item subject to the EAR, if, at the time of the transfer, you know, have reason to know, or are informed by BIS that the item will be used in the design, development, production or use of weapons of mass destruction or their means of delivery.