Contents

List of Abbreviations ......................................................................................................................6

Executive Summary........................................................................................................................8
1. EITI in Iraq .............................................................................................................................. 14
1.1. About the Extractive Industries Transparency Initiative (EITI) ................................... 14
1.2. EITI Implementation in Iraq .................................................................................................. 14
1.3. EITI Governance and leadership in Iraq (Requirement 1.1 – 1.3) ................................ 16
1.4. MSG Governance (Requirement 1.4) .................................................................................. 17
1.5. MSG Workplan (Requirement 1.5)....................................................................................... 18
2. Legal Framework and Fiscal Regime for the Extractive Industries (Requirement 2.1) . 20
2.1. National Governance Structures ......................................................................................... 20
2.2. Overview of the regulations applicable to extractive industries ................................. 21
2.2.1. Extractive sector regulations in federal Iraq ........................................................................ 21
2.2.2. Overview of the corporate income tax and withholding tax regimes applicable to
the oil and gas sector in federal Iraq .............................................................................................. 27
2.2.3. Extractive sector regulations in the Kurdistan Region ............................................................ 29
2.3. State participation in the extractive industries (Requirement 2.6)............................ 30
2.3.1. MSG definition of State-Owned Enterprises (SOEs) ................................................... 30
2.3.2. The prevailing rules and practices in relation to the financial relationship
between the Government and its owned companies .................................................................. 42
2.4. Fiscal Framework .................................................................................................................... 43
2.5. Reforming of the Regulatory and Fiscal Regime in 2016.............................................. 45
2.6. Procedures for granting licenses (Requirement 2.2) .................................................................. 47
2.7. Registry of Licenses (Requirement 2.3)............................................................................ 55
2.8. Contracts in the extractive industries (Requirement 2.4) ............................................ 60
2.9. Beneficial ownership of material extractive companies (Requirement 2.5) ............. 66
3. Extractive Industries Exploration, Production and Export Activities (Requirement 3) 67
3.1. Oil and Gas Sector in Federal Iraq....................................................................................... 67
3.1.1. Oil and gas fields in Iraq .................................................................................................... 67
3.1.2. Oil and Gas reserves in Iraq .............................................................................................. 70
3.1.3. Drilling and well workovers carried out by the Iraqi Drilling Company ................... 72

2
 3.1.4. Significant exploration work carried out by the Oil Exploration Company
(Requirement 3.1) .............................................................................................................................. 73
3.1.5. Crude oil production for year 2016 ................................................................................ 74
3.1.6. Flow of crude oil for national oil companies during the year 2016 ......................... 76
3.1.7. Gas production during 2016 ............................................................................................. 79
3.1.8. Production and supply of petroleum products during 2016 ..................................... 81
3.1.8.1. LPG, Condensate and Dry Gas production by Basra Gas Company during 2016
81
3.1.8.2. Petroleum products supplied by refineries during 2016 ....................................... 81
3.2. Mining and Minerals Sector in fedral Iraq .......................................................................... 85
3.2.1. Mining deposits in Iraq ....................................................................................................... 85
3.2.2. Exploration activities in 2016 .......................................................................................... 88
3.2.3. Minerals Production during the year 2016 ................................................................... 88
3.2.4. Targeted production capacities ....................................................................................... 89
3.3. KRG Oil, Gas and Mineral Production ................................................................................. 90
3.3.1. KRG crude oil production for year 2016 ....................................................................... 90
3.3.2. KRG natural gas production for year 2016................................................................... 92
3.3.3. KRG Mineral production for year 2016 .......................................................................... 92
3.4. Extractive Industries Export data (Requirement 3.3) .................................................... 93
3.4.1. Crude oil exports process ................................................................................................. 93
3.4.2. Extracted quantities of crude oil for export by SOMO ............................................... 96
3.4.3. Crude oil exports during 2016 ......................................................................................... 99
3.4.4. Exported crude oil quantities per region ..................................................................... 101
3.4.5. Exported petroleum products - Naptha ....................................................................... 102
3.4.6. Exported petroleum products - LPG and Condensate .............................................. 103
3.4.7. Mining and Minerals Sector in federal Iraq .......................................................................... 104
3.5. KRG Exports ........................................................................................................................... 105
4. Revenue Collection ............................................................................................................. 106
4.1. Materiality (Requirement 4.1) ........................................................................................... 106
4.2. Revenue streams .................................................................................................................. 106
4.3. Materiality of revenue streams ......................................................................................... 108
4.4. Reporting Companies ........................................................................................................... 110
4.4.1. International Oil Companies ........................................................................................... 110
4.4.2. Government entities ......................................................................................................... 111
3
 4.4.3. State-owned entities ........................................................................................................ 111
4.5. Detailed Reconciliations ...................................................................................................... 112
4.5.1. Crude oil export revenue for year 2016 ...................................................................... 113
4.5.1.1. Cost recovery reconciliation ...................................................................................... 121
4.5.1.2. Remuneration fees reconciliation ............................................................................. 123
4.5.2. Corporate Income Tax (CIT) ........................................................................................... 125
4.5.3. Treasury share of SOE net profits ................................................................................ 127
4.5.4. State partner shares in field remuneration fees ....................................................... 129
4.5.5. Internal Service payments (Requirement 4.5) ........................................................... 130
4.6. Subnational direct payments (Requirement 4.6) .......................................................... 131
4.6.1. KRG Revenue ..................................................................................................................... 131
4.7. In-Kind Revenues, barter agreements, and transportation revenues (Requirements
4.2 -4.4) .............................................................................................................................................. 133
4.8. Data Quality and Assurance (Requirement 4.9) ............................................................ 134
4.8.1. Audit and assurance procedures in state-owned entities working in the
extractive sector: ............................................................................................................................. 134
4.8.2. Audit and assurance procedures in International Oil Companies (IOCs).............. 135
4.8.3. Data quality assurance measures ................................................................................. 135
4.8.4. Data quality of reporting companies ............................................................................ 137
4.8.5. Reconciliation process ..................................................................................................... 139
5. Management and distribution of revenues ....................................................................... 140
5.1. Budget Process (Requirement 5.1) ........................................................................................... 140
5.2. Insight in to the Federal Budget of 2016 .................................................................................. 145
5.3. Subnational transfers (Requirement 5.2) ....................................................................... 147
5.3.1. Petrodollar allocations and transfers ........................................................................... 147
5.3.2. Governorates’ Development Program Allocations and transfers .......................... 149
5.4. Recent and Ongoing Financial Reforms ........................................................................... 151
6. Social and economic spending ........................................................................................... 152
6.1. Mandatory social expenditures (Requirement 6.1)....................................................... 152
6.2. Voluntary social expenditures ........................................................................................... 158
6.3. Quasi Fiscal expenditures (Requirement 6.2) ................................................................ 160
6.4. Economic Contribution of the Extractive Industries on the Iraq Economy
(Requirement 6.3) ............................................................................................................................ 161
7. Outcomes and impact ......................................................................................................... 171

4
7.1. Data accessibility and public debate (Requirements 7.1 and 7.2) ............................ 171
7.2. Observations and Recommendations ............................................................................... 171
7.3. Follow up on recommendations ......................................................................................... 173
Annex 1 – List of bidders during the first licensing round .................................................................... 181
Annex 2 – List of bidders during the second licensing round ............................................................... 182
Annex 3 – List of bidders during the third licensing round ................................................................... 183
Annex 4 – List of bidders during the fourth licensing round ................................................................ 184
Annex 5 – List of bidders during the fifth licensing round .................................................................... 185
Annex 6 – Map of Iraqi oil and gas fields (Licensing rounds in federal Iraq) ........................................ 186
Annex 7 – Coordinates of Iraqi oil and gas fields (Licensing rounds in Federal Iraq) ........................... 187
Annex 8 – Map of Iraqi oil and gas fields (KRG) .................................................................................... 192
Annex 9 – Coordinates of Iraqi oil and gas fields (KRG) ........................................................................ 193
Annex 10 – Map of Mineral locations in Iraq........................................................................................ 200
Annex 11 – Reporting Companies: International Oil Buyers ................................................................ 201
Annex 12 – Reporting Companies: International Oil Companies (working in Iraq under licensing round
service contracts) .................................................................................................................................. 202
Annex 13 - DFI 2016 Statement of Proceeds of Oil Export Sales .......................................................... 203
Annex 14 – Breakdown of training expenditures ................................................................................. 204
Annex 15 – National oil and gas companies mechanisms for calculating production quantities and
production costs ................................................................................................................................... 206

5
List of Abbreviations

The American Petroleum Institute gravity measure which indicates the

API
specific gravity of oil at 60 degree Fahrenheit
A quantity consisting of forty two (42) United States Gallons under a pressure
Barrel of 14.7 pound per square inch and a temperature of sixty (60) degrees
Fahrenheit
BCM Billion Cubic Meter
FBSA Federal Board of Supreme Audit

Calendar Month / In respect of any month in a calendar year, a period commencing on the first
Month day of that month and ending on the last day of the same month

A period of twelve (12) consecutive months commencing with the first day of
Calendar Year /
January and ending with the last day of December, according to the
Year
Gregorian Calendar

All hydrocarbons regardless of gravity which are produced and saved from
the Contract Area in the liquid state at an absolute pressure of fourteen
decimal seven (14.7) pounds per square inch and a temperature of sixty (60)
Crude Oil
degrees Fahrenheit, including asphalt, tar and the liquid hydrocarbons known
as distillates or condensates obtained from natural gas at facilities within the
field other than a gas plant

CBI Central Bank of Iraq

CTI Corporate Income Tax
Destination The place to which oil is shipped or directed
DFI Development Fund for Iraq
Dinar or Iraqi Dinar
The currency of the Republic of Iraq
or IQ
Dollar or USD Dollar of the United States of America
Due date The date on which an obligation must be repaid

A standard blend of crude oil of nearest quality to the crude oil stream
Export Oil produced from the field, out of which a contractor may lift at the delivery
point for the value of its due service fees under the contract

The price per barrel of export oil that is free on board (FOB) at the delivery
Export Oil Price
point
FRBNY Federal Reserve Bank of New York
GCT General Commission for Taxes
GDP Gross domestic product

Government or GoI The Government of the Republic of Iraq

IAMB International Advisory Monitoring Board

IEITI Iraqi Extractive Industries Transparency Initiative

6
Internal
Oil used for domestic purposes
consumption
IOCs International oil companies (international field development oil companies)

INOC Iraq National Oil Company

KRG Kurdistan Regional Government

LC Letter of credit
The date of flanges of the relevant offshore loading terminal(s) in Iraqi and
Loading Date
Turkish seaports where a contractor may lift export oil
LPG Liquid petroleum gas
MoIM Ministry of Industry and Minerals of the Republic of Iraq
MdOC Midland Oil Company of the Republic of Iraq
MdR Midland Refineries Company
MNR Ministry of Natural Resources (KRG)
MOC Missan Oil Company of the Republic of Iraq
MoF Ministry of Finance of the Republic of Iraq
MoO Ministry of Oil of the Republic of Iraq
NA Not Available
N/A Not Applicable
NOC North Oil Company of the Republic of Iraq
NR North Refineries Company
OPRA Oil Proceeds Receipt Account
PCLD Petroleum Contracts and Licensing Directorate of MoO
Production
The point within the field as agreed by the parties, where the volume and
Measurement Point
quality of crude oil produced and saved from the field is measured
/ PMP
RFB Remuneration fees per barrel
The payment of a fee by an IOC to a host government, upon signing a
Signature Bonus concession license agreement (or technical service contract) with a national
oil company or local oil company
SOC South Oil Company of the Republic of Iraq
BOC Basra Oil Company of the Republic of Iraq
SR South Refineries Company
TQOC Thi Qar Oil Company of the Republic of Iraq
Iraq Oil Marketing Company. An Iraqi entity established under and governed
SOMO
by the laws of Iraq, and having monopoly on oil exports
The period of twelve (12) consecutive months according to the Gregorian
Tax Year Calendar for which tax returns or reports are required according to any
applicable tax laws and regulations in Iraq
TPAO Turkiye Petrolleri Anonim Ortakligi
BP British Petroleum
MMSCFD Million Metric Standards Cubic Feet a Day
IA Independent Administrator

7
Executive Summary

The Extractive Industries Transparency Initiative (EITI) is a global organization established in 2002 with
a goal of increasing industry transparency and accountability. EY was engaged on the instructions of the
Iraq Extractive Industries Transparency Initiative (EITI) Secretariat to prepare Iraq’s 2016 Report. This
report was prepared in accordance with the guidelines of the EITI Standard and the reporting process
has been overseen by a Multi-Stakeholder Group (MSG).

The MSG is made up of 20 members; the MSG Chair, the National Coordinator, and six representatives
for each of the government, industry (extractive sector companies), and civil society. The current chair
of the MSG is the Secretary General of the Council of Ministers. In an attempt to enhance Government’s
participation in the IEITI process, the MSG has recently obtained a preliminary approval for this post to
be assumed by the Deputy Prime Minister of Energy Committee/ Minister of Oil.

To establish the scope of the 2016 IEITI report, the MSG conducted a scoping study, under which the
MSG assessed which provisions of the EITI Standard are applicable to Iraq, which elements needs to be
included in the report, and most importantly identified the relevant revenue and payment streams.

The revenue streams identified to be related to the extractive sector in Federal Iraq, according to the
scoping study, are the following:

- Crude oil exports revenue

- Corporate income tax
- State partner share in field remuneration fees
- Treasury share of State Owned Entities (SOEs) reported profits
- Signature bonus

According to the same study, the largest source of government revenue from the extractive industries
is crude oil export revenue, which is realized through export sales made through the State Oil Marketing
Organization (SOMO). As it relates to the mining sector, the only source of revenue to the government,
is through SOE payments to the state treasury equivalent to 45% of its distributable net profits.

The revenue streams identified to be related to the extractive sector in the KRG are the following:

- Crude oil exports revenue

- Royalties
- Bonuses (signature, capacity, and production)
- Capacity Building Payments

In accordance with Requirement 4.1 of the EITI Standard, the MSG determined a quantitative materiality
threshold for selecting revenue streams to be included in the scope of reconciliations. To be broadly
consistent with materiality thresholds used for other EITI-compliant countries, a quantitative materiality
threshold of 2% was determined by the MSG, under which revenue and payment streams that contribute
2% or more to the total revenue received by the government (federal and regional) from/to the mining
and oil and gas sectors, have been reconciled. Lowering the materiality threshold would not have
significantly increased coverage of the report.

8
In accordance with the set materiality threshold, the sole revenue stream that was reconciled was the
crude oil export revenue earned by the Federal Government of Iraq. While the crude oil export revenue
generated by the KRG exceeded the 2% materiality threshold, this revenue stream was not reconciled in
the report as no information was received from the KRG, and the companies operating in the Kurdistan
Region, despite exhaustive efforts made by the MSG and the Independent Administrator to attain the
KRG’s participation in the IEITI reporting process.

Accordingly, the Iraqi EITI submitted an adaptive implementation request to the EITI, as under the
current circumstances no reporting was made from the KRG. Therefore, revenue information included in
this report in relation to the KRG were obtained from publicly available sources.

In addition to the crude oil export revenue (of Federal Iraq), the scope of reconciliations includes
government payment streams that were considered by the MSG to be of importance and of interest to
the public; which are the following:
- Cost recovery
- Remuneration fees
- Internal Service Payments

Material reporting entities, for the purpose of this report, include oil and gas companies, which
contributed to the material revenue streams (excluding KRG) during the reporting period, together with
state-owned enterprises (SOEs) and government entities that received or recorded payments from them.
Material reporting entities also include the SOEs that receive internal service payments from the
government through SOMO. A listing of reporting entities is listed in the report.
For all revenue and payment streams that do not meet the materiality threshold, contextual information
was provided throughout the report. For example, although, subnational transfers were excluded from
the scope of reconciliation in accordance with MSG decisions, the report includes information addressing
the two types of subnational transfers that were identified in the report; petrodollar allocations and
Governorate Development Program allocations. The value of subnational transfer allocations and the
value of actual transfers to governorates with a display of the differences between allocated and
transferred amounts were addressed.

Progress in implementation of the EITI

Notable milestones were achieved for the 2016 report:

- In its scoping study for the year 2016, the MSG has determined, for the first time since becoming
an EITI compliant country, a quantitative materiality threshold to ensure that all revenues and
payments whose "omission or misstatement could significantly affect the comprehensiveness of
the EITI Report” are included in the scope of reconciliation
- The MSG worked with the Government in defining state-owned entities in Iraq, and accordingly
defined SOEs in accordance with Law No. 22 of 1997, as entities that are wholly owned by the
government. In accordance with the set definition, the MSG identified all SOEs operating in the
mining, oil and gas sectors
- The MSG has engaged in discussions with governmental entities for identifying the state’s policy
in relation to contract disclosures, as explained in more details in the body of the report
- The report provides a description of the process applied by the PCLD in awarding licenses to

9
 international oil companies, and provides a description of the technical and financial criteria used
in the pre-qualification phase of the license rounds
- The MSG clarified that all government revenue is recorded in the federal budget, with the
exception of revenues generated by the KRG. While the Federal Budget Act includes a fixed
contribution from KRG’s crude oil export revenue, the federal government, in practice, does not
receive such amounts

Reported production and export data for 2016

Crude oil production in federal Iraq is of two types;

- Licensing round production, which represents production by the IOCs under the licensing round
service contracts
- National efforts production, which refers to the production of crude oil from the oilfields
operated by the national oil companies (NOCs) independently

Crude Oil Production

1,400,000,000
1,200,000,000
1,000,000,000
Barrels

800,000,000
600,000,000
400,000,000
200,000,000
0
National Efforts Licensing Rounds
Production Production
(barrels) (barrels)

2015 2016

No licensing rounds were held during 2016, and therefore no new licenses were awarded during that
year.

The following table illustrates the major reported data during 2016 in comparison with 2015:

Description 20151 2016 Incremental rate

Total extracted crude oil

1,278,991,546 1,434,037,313 12.12%
(barrels)
Total export of crude oil
1,096,778,861 1,208,443,229 10.18%
(barrels)

1
2015 comparative figures were obtained from the IEITI report for year 2015, which is published on the IEITI
website: http://ieiti.org.iq/en/listing/reports-and-publications/annual-report
10
 Crude Oil Export Value of oil lifted by IOCs
800,000,000 16,000,000
700,000,000
14,000,000
600,000,000
500,000,000 12,000,000

Thousand USD
Barrels

400,000,000 10,000,000
300,000,000 8,000,000
200,000,000 6,000,000
100,000,000
4,000,000
0
USA Europe Far East 2,000,000
0
Destination
2010 2012 2014 2016 2018
2015 2016 Year

The average selling price of exported crude oil during 2016 was USD 35.5 per barrel, according to
average monthly prices reported by SOMO. This represents a significant decrease from the average
crude oil export price reported in the 2015 IEITI report of USD 46.44 per barrel.

The extractive industries make up the majority of Iraq’s exports, and have the largest contribution
towards the country’s Gross Domestic Product (GDP), and government revenues.

 Export: Crude oil and oil product exports for the year 2016 make up 99.79% of total exports in
Iraq (excluding KRG exports).
 GDP: The extractive industries contribution to the country’s total estimate GDP (MoP estimate)
for the calendar year 2016 at current prices was IQD 61,361,951.5 million that translates into
a relative share of 29.83% of total GDP (excluding KRG).
 Government Revenue: The extractive industries contribution to total government revenue is
96.7% of actual government revenue (excluding KRG revenue)

Federal Government Revenue

1% 2016 Crude oil export
1% revenue
3%
1% Corporate Income Tax
(CIT)
State treasury share
of SOE net profits
State partner shares
in field remuneration
fees
Other revenues
94%

11
Results of reconciliation and comprehensiveness of data

A difference of approximately USD 1.343 billion was identified from the reconciliation between the data
as reported by SOMO and as reported by the crude oil buyers. These differences were reviewed during
the course of the reconciliation process and the detailed results are presented in the report, however,
the main reason for these differences is attributed to issues such as delay penalties reporting, cut-off
dates and reporting on cash basis as opposed to accrual basis by the different reporting entities. The
reconciliation exercise also revealed differences in crude oil export revenue that couldn’t be justified
through the course of this exercise until the date of the report. These differences amount to USD
20,637,443 and are related to differences in reporting between SOMO, SOCAR, BP and Petrochina
Rumaila (refer to Section 4.5.1 for further details).

In the case of cost recovery and remuneration fee reconciliations, differences were noted among
reporting entities and were mainly attributed to differences in reporting by the PCLD and the IOCs,
whereby the PCLD reported figures that were approved during the year, and not necessarily what was
paid during the same year. However, although differences related to the reconciliation of the cost
recovery and remuneration fees of Shell Majnoon, Shell West Qurna, Pertamina Iraq, and Occidental are
partially attributed to the aforementioned reason, we were unable to conclude as of the date of this
report on the additional factors that contributed to the existence of a difference of USD 1,659,091,773
in this reconciliation (more details are included in the relevant section of the report).

Reliability of reported data

The report includes a section dedicated to the reporting on the reliability of the reported data by the
different participating entities. This was based on adherence of the reporting entities to the requirements
set for that purpose by the MSG. It was noted that only one out of six (16.7%) SOEs had their financial
statements audited by the Federal Board of Supreme Audit (FBSA) and was able to submit these financial
statements as requested, 43.5% of international oil buyers presented their audited financial statements
and 74% of international oil companies submitted their audited field financial statements. Other criteria
used for reporting on data reliability include the presentation of properly signed and stamped reporting
templates, presentation of invoices and financial reporting approved by internal audit departments and
board of directors of governmental institutions. It is clear from our analysis that reporting companies
favored the approach of sending signed and stamped reporting templates. Although this is acceptable
according to the approach approved by the MSG, reported data would be of higher credibility if the
reporting packages included copies of audited financial statements (more details in Section 4.8.3).

Actions and recommendations

Recommendations have been included in the report (Section 7.2) reflecting the steps that are
recommended for future actions by the concerned parties. These recommendations were based on the
observations made during the course of data collection and reporting for 2016 report.
Recommendations have primarily focused on increasing the transparency of reporting by certain
governmental entities, in addition to increasing their awareness towards the importance of the initiative
and its roles in increasing industry transparency and accountability. Recommendations also stressed on

12
the need of building open communication channels with all international companies involved with the oil
and gas sector in Iraq being buyers or operators with the aim of enhancing their reporting efficiency of
IEITI required data.

The following is an overview of the main challenges identified and recommendations covered in this
report:

- Non-cooperation or partial compliance of non-governmental reporting companies with the

reporting requirement has resulted in challenges during data collection
- Information requested from the MoIM, such as details of contracts signed with private sector
companies during the year 2016, and the methodologies used for contracting with private sector
companies was not reported. It is recommended that more efforts be exerted to increase
awareness of the Mining sector about the EITI Standard and its reporting requirements
- Although the PCLD reported the technical and financial criteria used in assessing companies
during licensing round bids, it did not clarify the respective weightings of such criteria. In
addition, several changes in license ownership were identified during the course of our
reconciliation exercises that were not reported by the PCLD. It is recommended that the PCLD
increase the transparency and comprehensiveness of its reporting to bridge the gap between
current reporting and EITI standard reporting requirements
- It is recommended that the MoF Increase the level of detail in reporting subnational transfers, to
clearly distinguish between annual subnational allocations and balances carried forward from
previous years
- It is recommended that national extractive companies operating in Iraq adopt a unified
mechanism in calculating the cost of gas production by national extractive companies

13
 1. EITI in Iraq

1.1. About the Extractive Industries Transparency Initiative

(EITI)

The EITI is an international body, established in 2002, that aims to promote the transparency
of natural resource revenues and accountability of the governments of resource rich countries.
The EITI Standard drafted by EITI requires the disclosure of information along the extractive
industry value chain from the point of extraction, to the flow of revenues through the
government, and how they benefit the public. EITI participating countries are required to publish
annual reports that disclose the revenues from the extraction of the country's extractive
resources, as well as information about the country’s extractive sector (such as license and
contract information as well as the laws and regulations governing the sector). Furthermore,
EITI reports include recommendations for improving sector governance2.

The EITI is considered a tool to identify and address weaknesses in the management of
implementing countries’ natural resources, whereby the international EITI Board monitors
and assesses the progress of countries in meeting the requirements of the Standard. Every
country that joins the EITI as a member is assessed against the EITI Standard in a process called
Validation.
Encouraging greater transparency in resource-rich countries improves foreign investment
opportunities by helping to create a level playing field for companies and investors, and
improves the overall economic and political stability of the implementing countries. As of
February 2018, there are 51 participating countries, and an estimated 2.3 trillion dollars’ worth
of revenue disclosed.

1.2. EITI Implementation in Iraq

Iraq has significant reserves of oil and natural gas; whereby it holds the fourth-largest proved
crude oil reserves in the world, after Venezuela, Saudi Arabia, and Iran 3. In addition, Iraq is
OPEC’s second-largest crude oil producer4. Iraq also has substantial gas reserves, usually found
in conjunction with oil. Much of the gas is associated with oil fields as a byproduct of oil
production, and consequently Iraqi gas development is largely tied to oil production5. However,
due to years of war and international sanctions, Iraq is a largely undeveloped source of
hydrocarbon resource; whereby significant oil and gas reserves remain untapped.

Nonetheless, Iraq’s economy is heavily dependent on oil revenues, which account for most of
the country’s foreign exchange earnings, and Gross Domestic Product (GDP). Iraq’s oil sector
is, therefore, central to Iraq’s fiscal position and critical to the vitality of the economy and the

2
https://eiti.org/who-we-are
3
https://www.opec.org/opec_web/static_files_project/media/downloads/publications/ASB2017_13062017.pdf
4
https://www.opec.org/opec_web/static_files_project/media/downloads/publications/AR%202017.pdf
5
https://www.atlanticcouncil.org/images/Shaping_Iraqs_Oil_and_Gas_Future_web_0108.pdf

14
 ongoing reconstruction efforts of the country, particularly with regard to oil, gas, and power
infrastructure and development.

The Ministry of Oil (MoO) is responsible for the federal government’s oil and gas industry
including overseeing sector investments, operation of infrastructure, planning, and
recommending and overseeing policies. The Ministry of Oil has incorporated several national oil
and gas companies to which it has delegated some of its discretion in the upstream,
downstream, and transportation, distribution and marketing sectors.

Iraq has been conducting a series of oil and gas licensing rounds since 2009, to award service
contracts to International Oil Companies (IOCs), to explore and develop new oil and gas fields
and increase production from its existing oil and gas fields.

Apart from crude oil and gas, Iraq’s other natural resources include minerals such as phosphates
and sulphur. The minerals sector is governed by the Ministry of Industry and Minerals, which
also operates through fully owned subsidiaries.

In January 2010, Iraq’s Prime Minister Nouri Al Maliki declared Iraq's commitment to EITI in an
event launched by Iraqi Extractive Industries Transparency Initiative (IEITI), and in February
2010, the EITI International Board announced that Iraq became an EITI candidate country6. The
implementation of the EITI is an effort to ensure that the country’s oil and gas wealth is managed
for the benefit of its citizens and sustained peace.

The current type of the centralized structure, where the Government through the Ministry of Oil
and Ministry of Industry and Minerals owns, produces, transports, sells and accounts for all the
oil, gas and minerals produced and exported or used domestically, is a comparatively unique
framework amongst the current EITI countries. The centralized structure poses certain
implications of how EITI is designed and implemented in Iraq, as will be discussed throughout
this report.

6
https://eiti.org/news/iraq-recognised-as-eiti-candidate

15
1.3. EITI Governance and leadership in Iraq (Requirement 1.1 –
1.3)

The EITI Standard requires each implementing country to form a multi-stakeholder group (MSG),
which is comprised of representatives from the government, companies (industry) and civil
society. The MSG is the key decision-making and oversight body for EITI implementation.

The IEITI’s MSG is currently comprised of the following members:

o Chair of the MSG – Mr. Mahdi Mohsen Al-Allaq (Secretary General of the Council
of Ministers)
o IEITI National Coordinator – Mr. Ala’a Rasoul Mohei El-Deen
o Six Government representatives:
 Ministry of Finance representative – Mr. Khaled Salah El-Deen Murad
 Two Ministry of Oil representatives – Mr. Ala’a Khader Al-Yaseri and Dr.
Sabah Al-Saedi
 Ministry of Industry and Minerals representative – Dr. Safa’a Al-Deen
Fakhry
 Ministry of Planning representative – Dr. Ala’a El Deen Ja’afar Mohamed
 Federal Board of Supreme Audit representative (FBSA) – Dr. Nedal Abed
Al-Zahra Merdao
o Six Industry representatives (extractive sector companies):
a) State-Owned Entities (SOEs) representatives:
 North Oil Company representative – Mr. Farid Jader Al-Jader
 Midland Oil Company representative – Mr. Jalal Ahmed Mahmoud
 Basra Oil Company representative - Mr. Ihsan Abdul-Jabbar Ismail
b) International Oil Company representatives
 LUKOIL Company representative – Mr. Gati Al-Jebouri
 BP Company representative – Mr. Zaid Al-Yaseri
 Petronas Company representative – A. Malik Jaffar
o Six Civil Society representatives:
 Iraq Association of Certified Accountants representative – Dr. Abed Al-
Saheb Najem Abed
 Private sector representative – Mr. Ali Sabeeh Al-Saedi
 Al-Khair Humanitarian Organization (NGO) representative – Mr. Saed
Jabbar Nehmeh
 Al-Inbithaq Association for Economic Development representative – Mr.
Maher Mahmoud Nasir
 Al-Nahrain Foundation for Transparency and Integrity representative –
Mr. Mohamed Raheem Zagheer
 Kurdistan Region civil society representative - currently vacant as of
September 2018 (previously filled by Mr. Khaled Naqshbandi)

16
1.4. MSG Governance (Requirement 1.4)

The MSG issued an Internal Governance policy in April 2018 (which was approved by the MSG
in its meeting No. 54 dated 6 April 2018). According to Section 2 (10) of the manual, the
invitation to participate in the MSG is open to the public, whereby it should be published on the
IEITI website and in a local newspaper (in Arabic) that is distributed in Baghdad and all other
provinces. The following is a description of instructions related to the selection of MSG
members, documented in the Internal Governance policy:
 Membership in the MSG is for a period of four years, subject to renewal
 The Chair of the MSG is selected based on an executive order, and should preferably be
a minister
 The IEITI National Coordinator is selected based on an executive order, and should
preferably be, at least, in a General Manager position
 The MSG is required to reach out to the different ministries and non-ministry entities
involved in the work of the EITI, in order to nominate six members to represent the
Government, with a condition that the nominated individuals hold a General Manager
position, or a higher positionp0
 The MSG is required to reach out to the state-owned entities involved in the work of the
EITI, in order to nominate three members to represent SOEs, with a condition that the
nominated individuals hold a General Manager position, or a higher position
 The MSG is required to reach out to the international extractive companies working in
Iraq or international companies buying Iraqi oil, to nominate three members to
represent them in them in the MSG, with a condition that the nominated individuals hold
a General Manager position in the Iraqi branch of their company
 The MSG is required to organize a committee of five individuals tasked with overseeing
civil society elections (with the committee president, vice-president and a third member
being employees in the legal field nominated by the Union of Iraq Jurists). The following
are the conditions imposed on civil society organizations wishing to participate in the
MSG membership:
o The entity should be registered and duly authorized by law to carry out its
activities in Iraq;
o The entity should present evidence of its knowledge and involvement in either
of the following areas; Extractive Industries Transparency Initiative and its
related activities, the extractive sector, integrity, transparency, and
governance. This could be displayed through the entity’s internal governance
manuals, publications, and/or pictures of related activities and events held by
the entity;
o The entity’s nominees should hold an “Executive Director” positon as per the
entities’ official docuemnts with the relevant bodies governing the work of the
civil societies. The nominee should have participated in courses and workshops
related to the extractive industries, integrity, transparency, and good
governance, and should have notable media activity in relation to these
activities

17
 The MSG meeting minutes are currently published on the IEITI website. The minutes include the
signatures of the MSG’s members who have attended the meetings and approved the meeting
decisions.

In its meeting No. 35 dated 12 October 2015, the MSG commissioned the IEITI National
Secretariat to pay an amount of IQD 500,000, to the members of the civil society
representatives for each official meeting held by the MSG, with the condition of making this
payment only once a month if there are multiple MSG meetings held in one month.

In its meeting No. 44 dated 17 May 2017, the MSG approved the following decisions in relation
to its language policy:

 The MSG approved a decision to issue the IEITI annual progress report in Arabic
 The MSG approved a decision to issue the IEITI reports in Arabic first and then have the
reports translated into English and Kurdish languages

1.5. MSG Workplan (Requirement 1.5)

According to the EIITI standard, the MSG is required to maintain a current work plan, fully costed
and aligned with the reporting and validation deadlines established by the EITI Board. The
purpose of the IEITI Work Plan is “to implement the EITI in an effective and efficient manner
through building up the organization, structure, knowledge, skills and capacity of participants,
as well as attain EITI compliant status”7.

The workplan is updated periodically to meet EITI standards, and the latest work plan for the
period from May 2018 to April 2019, is published on the IEITI website8.

In its 52nd subscript meeting on 7 March 2018, the MSG decided to rewrite the work plan in line
with the priorities of MoO and MOIM including9:
 National Oil Company formation
 Launching of mining licensing rounds
 Maximizing oil and gas revenues
 Social benefits challenges in licenses rounds
 Expanding oil exploration

As displayed in the IEITI work plan, the financing of the IEITI implementation is supported by the
World Bank. The following excerpt was obtained from an “IRAQ EITI Implementation Support”
report, published on the World Bank website:
"Following an official request from the Government of Iraq, the project has been successfully
restructured, moving the project closing date from 29th December, 2017 to 28th June, 2019,

7
http://documents.worldbank.org/curated/en/182971468261282309/Iraq-IEITI-Work-Plan
8 http://ieiti.org.iq/ar/details/545/%D8%AE%D8%B7%D8%A9-%D8%A7%D9%84%D8%B9%D9%85%D9%84-%D8%A7%D9%8A%D8%A7%D8%B1-
2018-%D9%86%D9%8A%D8%B3%D8%A7%D9%86-2019
9
http://ieiti.org.iq/en/details/414/decisions-of-the-52nd-msg-meeting-1520763278

18
 along with an additional financing top-up of USD 450,000. The total grant amount is now USD
800,000. The restructured project:
(i) supports the production, publication and dissemination of the 8th and 9th
Annual EITI Reports (covering data for the calendar years 2016 and 2017
respectively);
(ii) provides capacity support to the IEITI National Secretariat and IEITI Multi-
Stakeholder Group;
(iii) provides support to operating costs of IEITI National Secretariat;
(iv) supported the establishment of an improved IEITI website; and
(v) supports ‘mainstreaming’ of IEITI into government and company systems
through creation of a ‘feasibility study’ and ‘workplan’”.10

10
http://documents.worldbank.org/curated/pt/433601537551993564/pdf/Disclosable-Version-of-the-ISR-IRAQ-EITI-Implementation-Support-
P160274-Sequence-No-02.pdf

19
 2. Legal Framework and Fiscal Regime for the Extractive
Industries (Requirement 2.1)

2.1. National Governance Structures

Iraq has two levels of government; federal government and a regional government for the
Kurdistan Region.

The federal government of Iraq is defined under the current constitution as a single,
independent federal state with full sovereignty. Its system of government is republican,
representative, parliamentary, and democratic11. The federal government is composed of the
executive, legislative, and judicial branches, as well as numerous independent commissions 12.
In accordance with Article 48 of the constitution, the legislative branch is composed of the
Council of Representatives and the Federation Council. In accordance with Article 66 of the
constitution, the federal executive power is composed of the President and the Council of
Ministers.

The Kurdistan Region is located in northern Iraq, and is made up of the three northern provinces
of Dohuk, Erbil (Hawler), and Sulaimani. The Kurdistan Region forms part of the Federal Republic
of Iraq, and is governed by a regional administration, the Kurdistan Regional Government (KRG).
The KRG exercises executive power according to the Kurdistan Region’s laws as enacted by the
elected Kurdistan Parliament13.

11
http://ar.parliament.iq/%D8%A7%D9%84%D8%AF%D8%B3%D8%AA%D9%88%D8%B1-
%D8%A7%D9%84%D8%B9%D8%B1%D8%A7%D9%82%D9%8A/
12
http://www.irfad.org/iraq-government/
13
http://www.gov.krd/p/page.aspx?l=12&s=050000&r=300&p=210

20
 2.2. Overview of the regulations applicable to extractive
industries

The legal framework for the oil and gas sector in the Republic of Iraq is set forth in the
Constitution of Iraq, which was approved for by the Iraqi people in referendum on 15 October
2005. The relevant provisions of the constitution provide as follows:

Article 111:

Oil and gas are owned by all the people of Iraq in all regions and governorates.

Article 112:

First: The federal government, with the regional governments and producing governorates,
shall undertake the management of oil and gas extracted from present fields, provided that it
distributes its revenues in a fair manner in proportion to the population distribution in all parts
of the country, specifying an allotment for a specified period for the damaged regions which
were unjustly deprived of them by the former regime, and the regions that were damaged
afterwards in a way that ensures balanced development in different areas of the country, and
this shall be regulated by a law.

Second: The federal government, with the producing regional and governorate governments,
shall together formulate the necessary strategic policies to develop the oil and gas wealth in a
way that achieves the highest benefit to the Iraqi people using the most advanced techniques of
the market principles and encouraging investment.

2.2.1. Extractive sector regulations in federal Iraq

In federal Iraq, there is no single law that governs the oil and gas sector. There have been several
drafts for a Federal Oil and Gas Law; however, none has thus far have been implemented14.
Instead, the sector is governed by multiple oil and gas legislations, which will be discussed in the
following sections of this report.

As per the Organization of the Ministry of Oil Law No. 101 of 1976, the MoO of the Federal
Government of Iraq has central control and oversight over oil and gas exploration, production
and development in Iraq. The MoO operates the sector through its different directorates and
national oil and gas companies, as follows:

a) Fully owned subsidiaries of the MoO, are divided into three categories based on the
sectors they operate; upstream, midstream, and downstream sectors:
i. Sate companies in the extractive, drilling and production sector (upstream
sector) are:

14
http://www.iraq-businessnews.com/2018/10/21/petroleum-policy-proposal-for-the-new-govt/

21
 o North Oil Company
o Missan Oil Company
o Midland Oil Company
o Basra Oil Company15
o Thi Qar Oil Company
o Iraqi Drilling Company
o Oil Exploration Company
o North Gas Company
o South Gas Company
ii. Transportation, distribution and marketing sector (midstream sector) SOEs are:
o Gas Filling Company
o State Oil Marketing Company (SOMO)
o Oil Pipelines Company
o Oil Products Distribution Company
o Oil Tankers Company
iii. Downstream sector SOEs are:
o North Refineries Company
o Midland Refineries Company
o South Refineries Company

A description of the MoO state-owned entities is provided in Section 2.3.1.

b) Relevant Ministry of Oil Directorates:

i. Petroleum Contracts and Licensing Directorate (PCLD): The PCLD is a

directorate within the MoO that is tasked with organizing and carrying out
licensing rounds, negotiating with international oil companies in the oil and gas
sector, setting model contracts, and all other related activities in the
development of oil and gas fields in Iraq. The PCLD represents the MoO when
dealing with IOCs and coordinating between sate oil companies (upstream and
downstream) and with Ministry’s directorates16.
ii. Technical Directorate: The MoO’s Technical Directorate is responsible for
following up on the technical specifications of crude oil and oil products locally
produced and imported. It is assigned with the oversight of the import and
export activities in the Oil and Gas sector. The directorate has responsibility for
reconciling quantities of crude oil and oil products between all oil companies 17.

As for the mining and minerals sector in Federal Iraq, the MOIM is the sole governing body
responsible for the extraction and marketing of minerals in Iraq, and is legally authorized to
make decisions in that regard. The MOIM operates the sector through nine state-owned entities,
as follows:

15
Basra Oil Company was previously known as South Oil Company during 2016
16
http://www.moo.oil.gov.iq/PCLD-EN/PCLD/
17
http://www.moo.oil.gov.iq/Technical/Technical/

22
 o The State Company for Mining Industries
o The State Company of Fertilizers – Southern Region
o The State Company of Fertilizers– Northern Region
o Sate Company for Petrochemical Industries
o Phosphate Company
o Mishraq Sulphur Company
o Sate Company for Iron & Steel
o Iraq Sate Cement Company
o Iraqi Geological Survey and Mining Company (Geosurv-Iraq)

A description of the MOIM state-owned entities is provided in Section 2.3.1. Further information
on the MOIM can be found on the Ministry’s website 18.

The Energy Committee of the Council of Ministers: Since the powers of the different ministries
are limited, with the Council of Ministers having the higher authority, the Council of Ministers
formulated an Energy Committee to undertake appropriate decisions on its behalf. The
Committee is also tasked with the responsibility of supervising, and coordinating between the
Ministry of Oil, Ministry of Industry and Minerals, Ministry of Electricity, and other related parties
to facilitate their work towards meeting their respective objectives.

An overview of the different legislations governing the mining, oil and gas sectors is presented
below:

i. Organization of Ministry of Oil Law No. 101 of 1976 (as amended):

As described in Article 5 of Law No. 101 of 1976 (as amended), the Ministry of Oil is
responsible for the management of the oil sector, which involves:

a. Exploration, drilling and extraction of oil and gas

b. Refining activities and the production of gas
c. Transportation and marketing of crude oil and gas and their products

The Ministry of Oil is also responsible for drafting the initial plans for the various aspects
of oil and gas investment activity, and supervising their implementation after approval.
It is also responsible for supervising the implementation of the sector law, and
overseeing the implementation of the “Preservation of Hydrocarbon Resources” Law.

ii. Public Companies Law No. 22 of 1997 (as amended):

State-owned entities (SOEs) in federal Iraq (including those operating in the mining, oil
and gas sectors) are subject to the provisions of the Public Companies Law No. 22 of
1997 (as amended). Article 1 of the law defines a public/state entity as “a self-funded

18
http://www.industry.gov.iq/index.php?name=Pages&op=page&pid=108
23
 economic unit which is fully owned by the state, has a legal personality, is financially and
economically independent, and operates according to economic bases”.

A reference and description of relevant articles of the law is described in Section 2.3.2
below.

iii. Investment Law No. 13 of 2006

Investment Law No. 13 of 2006 aims to encourage Iraqi and foreign private sector
investment in Iraq in order to contribute to the economic and social development of the
country, and to expand and diversify its production and service base, all while creating
work opportunities for Iraqi citizens.

Article 12 of the Iraqi Investment Law No. 13 of 2006 provides that priority in
recruitment and employment shall be given to Iraqi workers, and goes on to state that
investors have the right to employ and use non-Iraqi workers only when it is not possible
to employ an Iraqi with the required qualifications and capabilities.

iv. Crude Oil Refining Investment Law No. 64 of 2007, and its second amendment No.
35 of 2016:

The purpose of this law is to encourage the private sector to participate in the process
of economic development in Iraq and contribute towards the development of Iraq’s
industrial base by participating in crude oil refining activities.

To encourage private sector investment in the refining sector, the Refining Law offers
the following incentives:
o The Ministry of Oil is obligated to supply crude oil to the refining company at
a price equal to the international FOB export price for Iraqi crude less a
discount of 5 per cent; provided that the discount will not be less than USD
4 per barrel or more than USD 8 per barrel.
o The investing company is entitled to determine the prices of its oil products
and sell them inside Iraq or export them to foreign markets according to the
applicable regulations in the free zones
o The investing company may utilize public facilities (such as terminals, export
ports and pipelines) in accordance with a contract to be signed between it
and the Ministry of Oil and the relevant ministries

v. Income Tax Law No. 113 of 1982 (as amended)

A description of the tax laws applicable to the oil and gas sector is provided in Section
2.2.2 below.

24
 vi. The Law of Income Taxation on Foreign Oil Companies Working in Iraq No. 19 of
2010 and its accompanying instructions; Taxation Instructions No. 5 of 2011 as
amended by Instructions 2 of 201319;

A description of the tax laws applicable to the oil and gas sector is provided in Section
2.2.2.

vii. Law No. 27 of 2009 on the Protection and Improvement of the Environment;

Matters relating to the environment within mining, and oil and gas exploration activities
are governed by Law No. 27 of 2009 on the Protection and Improvement of the
Environment. Article 21 of the Law addresses the activities of the entities involved in
the exploration and extraction of oil and natural gas, whereby it requires such entities
to:
o take necessary measures to limit the dangers and risks resulting from
petroleum operations
o take necessary measures to protect earth, air, water and underground
reservoirs from pollution and destruction
o take necessary precautions to dispose of produced salt water through safe
environmental methods
o prevent spills of oil and refrain from injecting oil into subsurface areas that
are used for human and agricultural purposes
o provide the Ministry of Environment with information about the causes of
any fires, explosions, breakdowns, accidents and leakage of crude oil and gas
from wells and pipelines

viii. Iraqi Ministry of Industry and Minerals Law No. 38 of 2011

The Iraqi Ministry of Industry and Minerals Law No. 38 of 2011 defines the ministry’s
objectives, scope, and structure and explains its role in promoting the country’s mineral
industry sector. Article 3 of the law states that the MOIM is responsible for increasing
the non-oil minerals sector’s share of the GDP, organizing and developing industrial and
mineral activities, and setting industrial policies and strategies in accordance with the
Government’s policies.

ix. Mineral Investment Law No. 91 of 1988

The Mineral Investment Law No. 91 of 1988 provides that the Iraqi Geological Survey
and Mining Company (“the establishment”) is responsible for supervising the
enforcement of the Law, and that it is responsible for monitoring the investment in
quarries and mines across the country, compiling and classifying the information
pertaining to those activities for the purposes of promoting, guiding and directing

19
http://www.moo.oil.gov.iq/Legal-Dir-websitee/Legal-Dir-website/PDF/LAW_NO_19_2010_EN.pdf
25
 investments to guarantee the maintenance of mineral wealth and protecting the
environment.

According to Article 4 of the Law, the Minister of Industry and Minerals, or his nominee
may allocate certain areas of land to private and mixed sector companies for investment
in quarries to execute their own projects, either with or without compensation, for a
limited period and according to specific conditions including the handling of by-
products20.

Other relevant regulations identified by the MSG are:

x. Government Contracts Law No. 87 of year 2004, and its Instructions No. 2 of 2014
(as amended) and its annexes
xi. Oil Production Fees Law No. 9 of 1939 (as amended)
xii. Allocation of Investment Areas for the Iraqi National Oil Company Law No. 97 of
the year 1967
xiii. Oil Products Anti-Smuggling Law No. 41 of 2008;
xiv. Law No. 84 of 1985 for preservation and protection of Hydrocarbon Endowment
xv. Law No. 37 of 2016 on Documents Preservation;
xvi. Oil Products Import and Sale Law No. 9 of 2006;

The IEITI has published on its website21 a study of the legal framework governing the
extractive sector in Iraq, in which the relevant governing laws and regulations are listed
as well as the relative articles of such laws.

20
http://www.iraq-lg-law.org/ar/content/%D9%82%D8%A7%D9%86%D9%88%D9%86-%D8%AA%D9%86%D8%B8%D9%8A%D9%85-
%D8%A7%D9%84%D8%A7%D8%B3%D8%AA%D8%AB%D9%85%D8%A7%D8%B1-%D8%A7%D9%84%D9%85%D8%B9%D8%AF%D9%86%D9%8A-
%D8%B1%D9%82%D9%85-91-%D9%84%D8%B3%D9%86%D8%A9-1988-%D8%A7%D9%84%D9%85%D8%B9%D8%AF%D9%84
21 http://ieiti.org.iq/mediafiles/articles/doc-561-2018_11_25_11_15_43.pdf

26
 2.2.2. Overview of the corporate income tax and withholding tax
regimes applicable to the oil and gas sector in federal Iraq

i. Application under the Income Tax Law

Iraq’s current income tax law is set out in Law No. 113 of 1982 (as amended) (the “Income Tax
Law”). Per the Income Tax Law, Article 13, Paragraph 3, the general CIT rate applicable to all
activities (except oil and gas activities) is a unified flat rate of 15% of taxable income. Under Law
No. 19 of 2010 (the “O&G Tax Law”), a higher rate of 35% was introduced for foreign oil
companies operating in the production of oil and gas in Iraq.

All companies with a formally registered business presence in Iraq must submit an annual CIT
filing with the GCT, consisting of the taxpayer’s audited Iraqi Unified Accounting System
(“IUAS”) financial statements and tax return.

Iraq’s Income Tax Law and O&G Law do not provide for a specific different treatment for the tax
filing and reporting requirements of a foreign oil contracting company working under a service
contract. Therefore, the taxation of foreign oil contracting companies should follow Iraq’s tax
regime of general applicability set out in the current Income Tax Law and O&G Law (and relevant
instructions).

As per the Income Tax Law, the CIT liability within the tax return should be computed by applying
the applicable CIT rate (35% for a company operating in the oil and gas sector) to a taxpayer’s
taxable income, whereby the latter is based on the net profit as reported in the audited IUAS
financial statements, adjusted for any non-deductible expenses and tax-exempt income. In
addition, taxable losses should be available to offset against future taxable income up to 50% of
the year’s taxable income for five consecutive years.

ii. Application under the Ministry of Oil’s service contracts

The Ministry of Oil’s standard service contract includes tax provisions that are inconsistent with
the Income Tax Law in Iraq. According to Article 23 (Taxes) of a typical service contract:

“23.3 For the avoidance of doubt, it is the understanding of the Parties that the sole tax liability
of Contractor under this Contract shall be corporate income tax at a rate not to exceed 35%
levied on the Remuneration Fee calculated in accordance with Article 19.5. SOC shall secure
that the provisions of the relevant Law are consistent with this understanding and afford
Contractor such treatment under the Contract and the Law.

23.4 In the event Contractor is subject to any demand to pay other taxes (other than corporate
income tax in accordance with Article 23.3) SOC shall bear and pay on behalf of Contractor all
such other taxes and shall indemnify and hold Contractor harmless against any and all liabilities
relating to the payment of such other taxes.”
Therefore, as per the service contract, taxable income to which the 35% CIT rate would apply is
equal to the remuneration fees.
27
In respect of payments made under an oil service contract, the practice of the PCLD in respect
of all tax filings up to financial year 2016 was to retain an amount of 35% from the remuneration
fee payment approved in the first quarter after the end of the financial year. The PCLD should
transfer the withheld amounts to the GCT. The GCT, in turn, is to provide the PCLD with proof
of transfer of the retentions that have been deposited in the name of the contractor in order for
the contractor to use the proof of transfer as support when settling with the GCT its CIT liability
for that financial year.

iii. Application to payments made to subcontractors

Per Article 4 (Second) of Instructions No. 5 of 2011 (as amended), the retention rates
applicable to foreign oil companies contracted to work in Iraq (or their branches), and
subcontractors in the fields of production and extraction of oil and gas and related industries,
including service contracts, are as follows:

 7%, if the contract relates to the following activities listed in Article 1 (First) of
Instructions No. 5 of 2011:

a. Oil and gas fields and exploration areas' upstream development contracts
b. Seismic surveys
c. Well drilling
d. Well reclamation
e. Technical operations related to wells and including the laying down linings, cementing,
wells recovery, electrical boring and wells completion
f. Surface installations for the operations of producing and extracting oil, gas and the
industries related to them
g. Water injection facilities
h. Flow pipes
i. Gas treatment coefficient
j. Cathode protection
k. Engineering examination and quality control related to oil industries
l. Water wells drilling
m. Activities related to extraction up to the limit at which oil or gas is ready for pumping
to exportation outlets

 3.3%, if the contract relates to other activities

28
 2.2.3. Extractive sector regulations in the Kurdistan Region

Unlike the Federal Government, the Regional Government of Kurdistan passed an Oil and Gas
Law - Oil and Gas Law of the Kurdistan Region – Iraq Law No. 22 of 200722, which entered into
force on 9 August 2007.

According to Article 5 of the Oil and Gas Law No. 22 of 2007, the Regional Council is responsible
for formulating the general principles of petroleum policy, prospect planning and field
development, and any modifications to those principles, in the Region. The Law provides that
the Regional Council shall be established as follows:

First: The Prime Minister - President

Second: The Deputy Prime Minister - Deputy President
Third: The Minister of Natural Resources - Member
Fourth: The Minister of Finance and Economy - Member
Fifth: The Planning Minister – Member

As stated on the MNR’s website: “The Ministry of Natural Resources is the sole authorized
signatory of production-sharing agreements with companies willing to invest in the exploration
of hydrocarbons and mineral resources in the region. The ministry is also the authority awarding
licenses for transportation and storage infrastructure, hydrocarbons and minerals production
operations as well as refining, petrochemicals and retail operations 23".

A description of relevant articles from the Oil and Gas Law is provided in Sections 2.3.1 and
2.8.2.2 of this report.

22
http://mnr.krg.org/images/pdfs/Kurdistan_Oil_and_Gas_Law_English_2007.pdf
23
http://mnr.krg.org/index.php/en/the-ministry

29
 2.3. State participation in the extractive industries (Requirement
2.6)

2.3.1. MSG definition of State-Owned Enterprises (SOEs)

In accordance with Requirement 2.6 of the EITI Standard, the MSG has defined state-owned
enterprises in accordance with the amended Public Companies’ Law no. 22 of 1997, which
defines a public company as:

“a self-funded economic unit which is fully owned by the state, has a legal personality,
financially and economically independent, and operates according to economic bases”.

The state-owned entities are therefore subject to the provisions of Law No 22 of 1997. Entities
that are majority owned by the state are not included in the MSG’s definition of state-owned
entities, since such entities are considered mixed sector companies, and are governed by a
different law – Law No. 21 of 1997.

i. Federal Government of Iraq

a) SOEs operating in the oil and gas sector in federal Iraq are fully owned subsidiaries of the
Ministry of Oil:

Upstream sector:

In federal Iraq, there are nine sate-owned companies in the extractive, drilling and production
sector (upstream sector).

1- Basra Oil Company/ South Oil Company

Basra Oil Company (BOC) is a state-owned company within the Iraqi Ministry of Oil, responsible
for the oil in the South of Iraq, and is based in Basrah, Iraq. BOC was previously known as South
Oil Company (SOC), and as of April 2017, SOC’s name was changed to Basra Oil Company after
it was restructured following the establishment and independence of Thi Qar Oil Company. BOC
is one of the major fundamental formations of the Iraq National Oil Company (INOC). The
company has operatorship of Iraq’s southern fields, including its biggest producing field
the Rumaila field24.

24
http://iraqministryofoil.com/south-oil-company-tenders-iraq/

30
 2- North Oil Company

North Oil Company (NOC) is a state-owned company within the Iraqi Ministry of Oil. The company
operates in the Northern fields in Iraq, and its operation area spans the following governorates:
Kirkuk, Nineveh, and Salah al-Din. NOC supplies crude oil to Iraqi refineries and associated gas
to North Gas Company units and to electricity generation stations as well as for export through
a network of pipeline system toward north and west of the country for export from terminals in
Turkey. The company’s main activities include 25:
- Production of oil and natural gas from the oil and gas fields within the company’s
geographical area
- Treatment of oil in process units and transportation by pipelines to refineries and
export terminals
- Separation and compression of associated gas and production of dome gas to be
transported to North Gas Company’s gas processing complex to produce LPG for
domestic consumption and dry gas as a fuel for industrial use.
- Sponsoring oil well drilling, workover and completion operations by Iraqi Drilling
Company (IDC) and other foreign drilling contractors, in addition to geological
control of those wells.
- Carrying out geological studies, reservoir engineering and field measurements
- Carrying out research and quality control of crude oil, gas, water and other oil
products

3- Missan Oil Company

Missan Oil Company (MOC) is a state-owned oil and gas company located in Maysan
Governorate, Iraq. It was created in 2008, as a spin-off from South Oil Company, to expand oil
related activities in Maysan province and to set up joint ventures with international companies
to develop the province's oil fields. This company has a very long pipeline and a number of
stations on this line, which ended in Haditha 26.

4- Midland Oil Company

Midland Oil Company (MdOC) is the fourth state-owned company that is responsible for
overseeing development in auctioned fields in the center of the country. There are more than
30 oil and gas fields that are located within the area of operations of the company, in addition
to about 160 geological blocks that have not been explored yet27.

25
http://www.noc.oil.gov.iq/english_ver/homepage_en.htm
26
http://www.gulfoilandgas.com/webpro1/prod1/suppliercat.asp?sid=10547
27
http://mdoc.oil.gov.iq/index.php?name=Pages&op=page&pid=96
31
 5- Thi Qar Oil Company

The Council of Ministers, voted in October 2016 on the establishment of the Thi Qar Oil
Company (TQOC), to develop the province of Thi Qar, a promising province in the oil and gas
industry with a large reserve of national wealth28. The first deputy governor of Thi Qar, Adel al-
Dakhili, announced the opening of the Thi Qar Oil Company officially in the presence of the Iraqi
Oil Minister, His Excellency, Mr. Jabar Ali al-Luaibi and a number of government figures in the
province in March 201729. The Iraqi Oil Minister, His Excellency, Mr. Jabar Ali al-Luaibi ordered
the state-run Thi Qar Oil Company (DQOC) and Iraq Drilling Company (IDC) to develop the
Nasiriyah oil field in Thi Qar province, which is expected to produce 300,000 barrels per day 30.

6- Oil Exploration Company

Prior to 1987, the Oil Exploration Company (OEC) was a state establishment under the umbrella
of the then Iraq National Oil Company. In 1987, the issuance of Decree No. 267 resulted in the
dissolution of the Iraq National Oil Company and its associated establishments, and the Oil
Exploration Company was established as an administratively and financially independent public
entity under the formations of the Iraqi Ministry of Oil. The main task of the company is to
discover and evaluate, the new hydrocarbon structures in the fields of geology, seismic
acquisition, interpretation, processing and laboratory researches and analyses, supported by
engineers, legal, administrative and finance staff 31.

7- Iraq Drilling Company

Iraq Drilling Company (IDC) is a state-owned entity established in 1990 with a purpose of limiting
the drilling and workover operations into one national company working across all geographical
areas32. The main activities of the company include:

- Drilling of oil and gas wells

- Reclamation and completion of oil and gas wells
- Drilling of water and waste wells
- Operation of drilling camps and support operations
- Maintenance of drilling equipment
- Dismantling, transporting and installing equipment at drilling sites

8- North Gas Company

North Gas Company was established in 1998, in accordance with the Organization of Ministry
of Oil Law No. 101 of 1976, and Public Companies Law No. 22 of 1977. The company is based
in Kirkuk, and its main objective is to utilize associated gas available in Iraqi fields to produce
the following products:

28
https://oil.gov.iq/index.php?name=News&file=article&sid=1475
29
http://en.economiciraq.com/2017/03/30/the-opening-of-the-dhi-qar-oil-company-officially-in-the-presence-of-
iraqi-oil-minister/
30
http://www.iraq-businessnews.com/2018/08/01/iraq-invests-to-boost-nasiriyah-oil-field/
31
http://oec.oil.gov.iq/ar/page/about-us
32
http://www.idc.gov.iq/about-en.php

32
 - Dry gas: for use in electricity generation stations as well as other industrial factories
as fuel gas, in addition to its use as a raw material in petrochemical industries and
fertilizers
- LPG: for domestic use and export
- Natural Gasoline: used as fuel or injected with raw oil to improve specifications
- Sulphur: used as a raw material in local industries and for export 33

9- South Gas Company

South Gas Company (SGC) was established in June 1998, as a public entity in accordance with
Law No. 22 of 1997, and is based in Basrah.

The company aims to support the national economy in the field of oil through the production of
liquid and dry gas for internal consumption and exportation in a way that achieves the objectives
of the development plans and the plans approved by the Ministry of Oil.

SGC activities include:

- Receiving and processing gas from the southern fields

- Manufacturing and pressing of dry gas to be delivered to consumption sites and
exportation outlets using the regional pipeline network
- Manufacturing, storing, mixing and pressing of liquid gas to be delivered to the filling
plants or exportation outlets through the regional pipeline network or by other
means
- Producing and distributing Gasoline (Natural Petrol)
- Developing and expanding oil plants, production lines and establishing new and
completing projects and lines
- Managing and executing all technical and service operations that supports its
activities

Transportation, distribution and marketing sector:

1- State Oil Marketing Organization

State Oil Marketing Organization (SOMO) is the only official company legally authorized to
negotiate and conclude Iraqi laws regarding crude oil sale contracts as well as oil product
contracts in accordance with international standards. SOMO is specialized in the marketing of
crude oil as well as working on the export of fuel oil products. More information about SOMO
and its working mechanisms are described in Section 3.5.1.

2- Oil Pipelines Company

Oil Pipeline Company (OPC) is a state owned company founded in 1930 for the purpose of
transporting crude oil using pipelines. OPC’s main objectives can be summarized as follows:

33
http://ngc.oil.gov.iq/en_index.htm

33
 - Operating and maintaining pipelines for the transportation of black and white
petroleum oil products, from production to consumption sites
- Operating and maintaining pipelines for the transportation of liquid and natural gas
from production sites to main consumers across the region
- Operating and maintaining crude oil pipelines for the transport of crude oil to oil
refineries, and pipelines for the transport of crude oil to power generation stations
for use as fuel
- Managing centers to control the movement of oil and gas using the pipelines
mentioned above
- Operating and maintaining pumping stations and warehouses
- Organizing, following up and participating with the MoO in making plans for the
production and consumption of oil products and industrial fuel
- Overseeing, controlling and limiting the proliferation of oil spills from oil
products.34

3- Gas Filling Company

Gas Filling Company (GFC) replaced the gas filling general facility on 1 June 1998, the
company is considered one of the supporting pillars to the oil sector as it contributes with
the following:
- Operating gas factories and filling liquid gas
- Manufacturing gas containers and its related maintenance
- Establishing liquid gas systems for cars
- Establishing liquid gas systems for industrial, service, and household usage

4- Oil Products Distribution Company

Oil Products Distribution Company (OPDC) is a governmental owned company established

in 1967 as the oil products distribution authority and it was later merged with the Oil
Products Transportation Company and General Pipeline Facility in 1991. OPDC is
considered a strategic link in the oil industry operations as it is responsible for providing
citizens with oil products and power to electric stations.17

5- Iraqi Oil Tankers Company

Iraqi Oil Tankers Company (IOTC) is a company specializing in the ocean transport of crude
oil and refined products, established in 1972. IOTC uses a fleet of oil tankers, also known as
petroleum tankers; which are merchant ships designed for the bulk transport of oil. There
are two basic types of oil tankers: the crude tanker and the product tanker. Crude tankers
move large quantities of unrefined crude oil from point of extraction to refineries. Product

34
http://opc.oil.gov.iq/

34
 tankers, generally much smaller, are designed to move refined products from refineries to
points near consuming markets35.

Downstream Sector

1- North Refineries Company

North Refineries Company (NR) was established in 1976 and is the largest Iraqi oil refining
company. NR produces various products including unleaded gasoline, illuminating kerosene,
ATK, diesel, lube oil product, spindle oil, transformer oil, asphalt, sulfur, LPG and RT36.

The company runs the following refineries and facilities:

- North Refinery
- Salahudin I
- Salahudin II
- Lube plant

2- South Refineries Company

South Refineries Company (SR) was founded in 1969, but began production in 1974 by
establishing Refining Unit No. 1, which is one of the major manufacturing units in the
country. The company’s activities include refining crude oil and producing the following
derivatives: gasoline, kerosene, diesel, fuel oil, LPG, light Naptha and jet fuel 37.

3- Midland Refineries Company

Midland Refineries Company (MdR) is one of the three major refining organizations
operating in Iraq, all governed by the Iraqi Ministry of Oil. Midland Refineries Company is
made up of Al-Daura Refinery and other exterior refineries. The Daura refinery was built in
1953 and began operations in 1955. It is located 20 kilometers southwest of Baghdad and
is the second largest in Iraq38.

The following is a list of MdR exterior refineries:

- Al-Samawah Refinery
- Al-Najaf Refinery
- Al-Diwaniya Refiner
- Karbala Refinery

35
http://iotc.oil.gov.iq/en/index.php?page=about-us

36
http://www.nrc.oil.gov.iq/english/home.htm

37
http://www.src.gov.iq/en/about_us
38
http://iraqministryofoil.com/midland-refineries-company-tenders-iraq/

35
 b) Sate-owned enterprises operating in the minerals and mining sector in federal Iraq are fully
owned subsidiaries of the Ministry of Industry and Minerals (MOIM):

1- The State Company for Mining Industries

The State Company for Mining Industries is one of the major formations of the Ministry of
Industry and Minerals, and has two industrial identities39:
- Chemical production: The company is involved in the production of various types
of products such as construction products, asphalt polymer, asphalt cement, and
waterproofing products used in for heat insulation in tanks and pipelines
- Mining: The company is involved in quarrying, extraction, and marketing of
minerals, mostly sand in all forms such as silica sand, filter sand, feldspathic sand,
flint and kaolin.

The mineral extraction unit is a division within the company that is specialized in the
extraction and marketing of mineral raw materials and semi-finished products.

The company has several sites in Iraq, as follows:

- Baghdad - company HQ, Mineral Extraction Division
Basra - Al-Thaghar Factory
- Muthanna - Samawah
- Najaf - Al-Najaf Mine
- Nineveh - Al-Remah Factory
- Al-Anbar - Western desert mines and Bentonite activation project.

2- The State Company of Fertilizers – Southern Region and The State Company of
Fertilizers– Northern Region

In 1969, the State Company of Fertilizers was established in Abo al-Khassib, Basra province
with a capital of IQD 12 million. The company’s factory became operational in 1971,
producing the following products:
- Urea (final product)
- Ammonia

Due to the inability of one fertilizers plant to meet the demands of the agricultural industry
at the time, it was decided to expand the capacity of the first plant by establishing a second
plant for the production of urea fertilizers in the same location (Abo Al-Khassib) with a
capital of IQD 32 million with the following planned daily capacities:
- Urea fertilizer (1,300 tons /day)
- Ammonia (800 tons/day)

39
http://en.altadinea.industry.gov.iq/pages?id=1

36
 During September 1973, a contract was signed with Mitsubishi Heavy industries to
construct the second plant.

In addition, to the increasing demand for urea for use in agricultural and industrial activities,
a decision was taken to construct two large factories for urea production at a cost of QD
192 Million in Khor Al Zubair.

In 1988, the two companies {Abo al-Khassib & Khor Al-Zubair} were incorporated within the
State Company of Fertilizers; however, in 1994 the two entities were split into two separate
entities:
- The State Company of Fertilizers/ Northern Region and;
- The State Company of Fertilizer / Southern Region

3- State Company for Petrochemical Industries

The State Company for Petrochemical Industries was established in Basra –Khor Al-Zubair
in 1977. The objective of the company is to produce raw materials used in the
manufacturing of plastic materials (polyethylene, polyvinyl chloride (PVC)) and any other
petrochemical products, using natural gas and other petroleum products 40.

The company also produces the following chemical products:

- Hydrochloric Acid (HCI)
- Sodium Hypochlorite (NaOCI)
- Caustic Soda

4- The State Company for Phosphates

The Sate Company for Phosphates is one of the major formations of the Ministry of Industry
and Minerals that specializes in the mining of phosphates. The main objective of the
company is to carry out exploration and mining of phosphate deposits as well as production
and transfer of phosphate ores for the production of phosphate fertilizers, compound
fertilizers and various byproducts.

Akashat phosphate mine is located in the province of Anbar in the western desert at Akashat
region sites between Al Qaim district and Rutba district about 150 km southwest. The main
task of the mine is limited by the extraction of the phosphate rocks, crushing, loading and
conveying the raw materials by rail wagons to the chemical Complex in Al Qaim. Akashat
phosphate mine project is an integrated production unit owns their workshops, vehicles and
warehouses as well as other requirements necessary for production operations 41.

40
http://pchemiq.com/xabout.htm
41
http://www.sulphuric-acid.com/sulphuric-acid-on-the-web/acid%20plants/State%20Company%20for%20Phosphates.htm

37
 5- Mishraq Sulphur State Company

Mishraq Sulphur State Company is one of the MoIM establishments, which was founded in
1969. The production of Sulphur began towards the end of year 1971, which is extracted
from underground deposits of 120-200 meters in depth, using the Frasch process. In the
Frasch process, superheated water is pumped into the sulphur deposit; the sulfur melts and
is extracted with the assistance of compressed air42.

The company produces the following products:

- Pure Sulphur
- A LUM (Hydrated Aluminum sulfate)
- Agriculture Sulphur
- Sulphuric Acid

6- The State Company for Iron & Steel

The State Company for Iron & Steel is an establishment of the MoIM, involved in
transformational activities, and is specialized in:
- Production of wielded steel pipes
- Outer coating of steel pipes with polyethylene, adhesives, and epoxy, as well as
inner coating of steel pipes with nutritional epoxy.

7- Iraq State Cement Company

Iraq State Cement Company was established as a public entity in 1964 as the Iraqi State
Cement Company after the passing of the Public Companies Law No. 22 of 1997. Prior to
that, ISC consisted of three companies, Iraqi Cement Co. Ltd that was establish in 1936, Al-
Furat Cement Co. established in 1957 and United Cement Co. established in 1958.

The company’s functions are set as follows:

- production of all types of Cement according to set specifications
- marketing the produced Cement internally and exporting it externally according to
specified plans and programs
- anufacturing Cement filling bags 43

8- The Iraqi Geological Survey and Mining Company

The Iraqi Geological Survey and Mining Company (Geosurv-Iraq) is an establishment of the
Ministry, which is responsible for carrying out geological surveys and mineral explorations,
promoting mining projects in the private and public sectors, and conducting environmental
impact studies. Geosurv-Iraq is also responsible for implementing the Mineral Investment
Law No. 91 of 1988 (as amended), whereby it offers a number of investment opportunities
including investments in phosphate, free sulfur, sulphate, silica sand, red clay, brick clay
and others44.

42
www.mishraq.industry.gov.iq/
43
http://cementiraq.com/en/producers/1
44
http://geosurviraq.iq/Pages?id=1138

38
 Mixed Sector companies:

Basra Gas Company (BGC) is a 25-year Iraqi joint venture established to overcome the challenge
of flared natural gas in Basrah Province. The Company’s shares are distributed between the
South Gas Company (51%), Shell (44%), and Mitsubishi (5%). Basrah Gas Company is organized
as a mixed limited liability company under the Iraqi Companies Law No. 21 of 1997, and is the
only mixed limited liability company that has been formed in the extractive sector.

The company’s main objective is to capture and treat associated natural gas that is currently
being flared in West Qurna Phase 1, Zubair, and Rumaila fields. Its’ operations officially
commenced in May 2013, and in December 2014, BGC achieved a new processing record of
500 mmscf/d of gas and a new LPG production record of 2650 tons per day45.

The following is a brief description of BGC’s gas gathering systems, which was obtained from
the company’s website46.

Pipelines

BGC operates a network of around 1,800 kilometers of natural gas, hydrocarbon liquids and
industrial water pipelines. Natural gas and liquids are transported through these pipelines from
where it is produced to BGC’s processing plants. BGC is in process of inspecting and
rehabilitating these pipelines, and is building 300 kilometers of new pipelines to expand its
capacity.

Compressor stations

BGC has nine compressor stations, which are distributed at intervals along its pipeline network.
Their purpose is to compress the natural gas, thereby providing an increase in pressure for the
natural gas to continue flowing towards the BGC processing plants. BGC is building nine new
compressor stations, and in the meantime, has installed three temporary compressors to
increase gas flow to meet the needs of South Iraq for power.

Gas processing plants

BGC operates two gas processing plants, at which the company removes contaminants from the
natural gas and separates it into dry gas for supply to power generators and valuable natural
gas liquids. At the Khor Al Zubair gas processing plant, BGC further processes natural gas liquids
to make LPG (which is a very high API oil in gas form that has condensed when rising to the
surface) and condensate.

45
https://www.shell.iq/en_iq/about-us/projects-and-sites/basrahgascompany.html
46
http://www.basrahgas.com/infrastructure-overview

39
 Storage and Marine Terminal

On the coast at Umm Qasr, BGC operates a storage and marine terminal. LPG and condensate
are stored at this facility before they are delivered to South Gas Company for distribution in the
domestic market.

In early 2016, and after domestic demand of LPG was met, LPG and condensate exports began,
through BGC47. While the exports are facilitated via SOMO, given that SOMO is the only entity
with the legal authority to export crude oil and oil products outside the country, the sale
proceeds go to BGC. Based on information provided by SOMO, SOMO only receives a commission
for its services, from BGC. Since South Gas Company is a shareholder of BGC, it receives its
share (according to its ownership stake) of the company’s net profits (after making all legal
deductions, and payment towards compulsory reserve), in accordance with Law No. 21 of 1997
(as amended)48. The government indirectly receives its share of the BGC’s profits upon receiving
SGC’s treasury share (45% of distributable net profits); the legal basis of such payment is
discussed in the following section (2.3.2).

ii. Kurdistan Regional Government

According to the Kurdistan Oil and Gas Law No. 22 of 2007, the KRG’s MNR exerts control and
oversight over the Kurdish region through the following public entities:

Kurdistan Exploration and Production Company (KEPCO):

As per Article 10 of the Oil and Gas Law No. 22 of 2007, KEPCO may, subject to the approval
of the Regional Council:
 “compete with other companies to obtain Authorizations regarding Future Fields;
 enter into joint ventures and similar contractual arrangements, whether in the Region,
in other parts of Iraq or abroad; and
 create operating subsidiaries for particular Petroleum Operations in respect of Future
Fields.”

Kurdistan National Oil Company (KNOC):

As per Article 11 of the Oil and Gas Law No. 22 of 2007, KNOC may, with the approval of the
Regional Council:
 “compete with other companies to obtain Authorisations regarding the management of
Current Fields;
 enter into joint ventures with reputable and experienced international petroleum
companies for Petroleum Operations to enhance production from Current Fields, to
maximize early returns; and
 on a case by case basis, compete to obtain Authorisations regarding Future Fields.”

47
http://www.basrahgas.com/node/200
48
http://www.iraq-lg-law.org/ar/content/%D9%82%D8%A7%D9%86%D9%88%D9%86-
%D8%A7%D9%84%D8%B4%D8%B1%D9%83%D8%A7%D8%AA-%D8%B1%D9%82%D9%85-21-%D9%84%D8%B3%D9%86%D8%A9-1997-
%D8%A7%D9%84%D9%85%D8%B9%D8%AF%D9%84-%D9%84%D8%B3%D9%86%D8%A9-2004

40
Kurdistan Oil Marketing Organization (KOMO):

As stipulated in Article 12 of the KRG Oil and Gas Law No. 22 of 2007, “KOMO may market or
regulate the marketing of the production from Petroleum Operations, and may, with the
agreement of a Contractor to a Production Sharing Contract, market the Contractor’s share of
Petroleum.”

Kurdistan Organization for Downstream Operations (KODO):

According to Article 13 of the Oil and Gas Law No. 22 of 2007, “KODO may:
 manage all Regional Government-owned infrastructure related to Petroleum Operations
referred to in Article 8 Paragraph First of this Law, and shall make available such
infrastructure, including main pipeline networks, to all relevant public and private sector
entities operating in the Region.
 compete with other companies for Authorizations after obtaining the approval of the
Regional Council, in its own right create operating subsidiaries for particular Petroleum
Operations, and enter into joint ventures and similar contractual arrangements,
whether in the Region, or in other regions and governorates;
 participate with international oil companies or with the local private sector for new
downstream Petroleum Operations, with the approval of the Regional Council; and
 license the management of any of its infrastructure to third parties with the approval of
the Regional Council.”

Kurdistan Oil Trust Organization (KOTO):

As per Article 15 of the Oil and Gas Law No.22 of 2007:

“Fourth: KOTO shall, consistent with the entitlement defined in Articles 112 and 115 of the
Federal Constitution, receive Revenues from Petroleum Operations from Current Fields and
Future Fields on behalf of the people of the Region, according to the provisions stated in this
Law.

Fifth: Until such time as the conditions of Article 19 of this Law are implemented, KOTO shall
maintain two accounts: one for Revenues from Petroleum Operations in respect of Current
Fields (the Current Fields Account); and one for Revenues from Petroleum Operations in respect
of Future Fields (the Future Fields Account). Both accounts shall be part of the general revenue
of the Region and shall be subject to monitoring of the Parliament.

Sixth: The Current Fields Account and the Future Fields Account shall be subject to regular
independent audit, which shall be available for public viewing. In all other respects KOTO shall
discharge its responsibilities consistent with the Principles and Criteria of the Extractive
Industries Transparency Initiative (EITI) as set out in the EITI Source Book of March 2005.”

41
 2.3.2. The prevailing rules and practices in relation to the financial
relationship between the Government and its owned companies

According to Law No. 22 of 1997 (as amended), the public company's capital shall be
determined in a decision by the Council of Ministers approving its establishment.

Article 11 of Law No. 22 of 1997 (as amended) requires public companies to allocate the
distributable portion of net profits as follows:

 45% to be remitted to the MoF

 33% to be paid as incentives to company employees, including members of the Board
of Directors and Ministry employees, in accordance with the percentages and
controls set by the Board of Directors and approved by the Minister
 5% to be allocated for social services
 5% to be allocated for research and development
 Remaining amount is to be retained as the company’s capital reserves

The MSG has determined that the distribution of SOEs’ net profits, in practice, are in
accordance with the stipulations of the Law.

Article 15 (3) of Law 22 allows Iraqi SOEs to engage in partnership agreements with Arab and
foreign companies, to carry out work related to the objectives of the company inside Iraq. This
provision allows SOEs to participate in oil and gas licensing round contracts as state partners
in the service contracts.

Article 17 of Law No. 22 of 1997 (as amended) provides that a public company may lend, or
borrow funds to finance its activities from financial institutions and national public companies,
under loan agreements subject to conditions to be agreed upon, given that the loans do not to
exceed 50% of the company’s paid up capital.

Article 18 provides that SOEs require approval from the Council of Ministers when borrowing
from outside of Iraq to finance investment activities.

However, while it is permissible by Law for SOEs to obtain and grant financial loans to and from
third parties, SOEs, in practice, do not directly grant or receive third party loans. If, and when
required, SOEs obtain financing from the MoF.

The four material national oil companies (subject to materiality thresholds determined in
Section 4.1) that were operational during 2016 (BOC, NOC, MdOC, and MOC) declared that
there were no loans received during 2016.

42
2.4. Fiscal Framework

The following diagram illustrates the financial relations between the federal government and
extractive companies, including SOEs in Federal Iraq:

Diagram 1: Fiscal relationships in the extractive sector of Federal Iraq

 All crude oil produced by national efforts and under licensing rounds contracts (excluding
Kurdistan Region) flows to:
o SOMO for export of crude oil to external markets
o Oil refineries for refining crude oil and the production of oil products
o Power plants for electricity generation
 Internal Service Payments are paid on a monthly basis by the Ministry of Finance (through
SOMO) to national oil companies to cover the cost of production that is exported. As of
2016, the MoO extended ISP to the Oil Exploration Company due to its involvement in the
extraction activities, and therefore indirect involvement in the export process.
 The value of crude oil supplied to refineries and power plants is transferred to the national
extractive oil companies.
 All proceeds from the export of crude oil are deposited by the international oil buyers into
the Oil Proceed Receipt Account (OPRA), held at the Federal Reserve Bank of New York
(FRBNY). Ninety five percent (95%) of the proceeds are transferred to the Development
Fund for Iraq (DFI) held at the FRBNY. The remaining five percent (5%) of crude oil export

43
 proceeds are transferred to the UN Compensation Fund for Kuwait. For more details about
the flow of oil revenue into the country, please refer to Section 5.1.
 Revenues generated from the sale of produced minerals are paid to the accounts of the
extractive industrial companies.
 Basrah Gas Company is a mixed sector company, which is 51% owned by South Gas
Company. South Gas Company accordingly receives its share of BGC’s net profits in
accordance with its ownership interest (51%).
 All state-owned entities are required by Law to allocate 45% of the distributable portion of
net profits to the Ministry of Finance as “treasury share” remittances.
 The practice of the Ministry of Oil - PCLD in respect of all tax filings up to financial year
2016 was to retain an amount of 35% from the remuneration fee payment approved in the
first quarter after the end of the financial year.
 The MoO transfers to the MoF amounts in respect of:
o CIT deducted from IOC’s remuneration fees
o Signature bonus amounts paid by the IOCs to the MoO
o State partner share of remuneration fees paid during the year
 The Ministry of Finance distributes funds to the different ministries and governorates, as
per budgetary allocations.

44
 2.5. Reforming of the Regulatory and Fiscal Regime in 2016

The following is an overview of the recent and ongoing legal reforms in federal Iraq:

 Extractive Industries Transparency Committee Law of 2017: The Extractive Industries

Transparency Committee Law was passed during 2017. The Commission’s main
objectives include:
o Enhancing transparency and governance of the extractive industries by
applying global standards
o Promoting and raising levels of transparency and accountability in extractive
industries
o Integrating the Initiative's standards within the operations, processes, and
contracts of the Iraqi extractive industries

 Iraqi National Oil Company Law No. 4 of 2018: Iraq's Parliament passed a law in March
2018 to resurrect the Iraqi National Oil Company (INOC), which was founded in 1964
and disbanded in 1987. The new company is supposed to assume operational authority
of the oil sector49. According the INOC Law No. 4 of 2018, the INOC aims to make the
best use of the oil and gas resources in the field of oil and gas exploration, rehabilitation,
field development, production, marketing and all related activities.

The companies transferred to INOC ownership, as per the Law, are:

o Iraqi Oil Exploration Company
o Iraqi Drilling Company
o Basra Oil Company
o North Oil Company
o Missan Oil Company
o Midland Oil Company
o Thi Qar Oil Company
o State Organization for Marketing of Oil (SOMO)
o Iraqi Oil Tankers Company

The Law was published in the Iraqi Gazette in Issue No. 4486 dated 9 April 2018. 50

 Service contract amendments in fifth licensing rounds: The MoO represented by the
PCLD, amended the licensing round contracts (in the fifth licensing round) by adding a
clause requiring IOCs to adhere to the Extractive Industries Transparency Initiative
standards.

 The Ministry of Oil approved the adoption of the work plan submitted by the government
representatives on the MSG in relation to direct disclosure project.

49
https://www.iraqoilreport.com/news/oil-minister-wants-new-inoc-law-33810/
50
https://www.moj.gov.iq/upload/pdf/4486.pdf

45
 Approval of Council of Ministers of Mineral Investment Law

 On 15 March 2018, the PCLD issued letter no. 901 indicating that no tax retention will
be deducted from the 2017 remuneration fees. Instead, taxpayers are required to
approach the GCT directly in order to settle their 2017 CIT liability. The letter specified:

“- […] the amount of Corporate Income Tax at a percentage of (35%) on the paid
Remuneration Fee that Contractor is required to pay.
- Contractor shall pay the due Corporate Income Tax directly to the General
Commission for Taxes no later than 31st May of each year and provide relevant Iraqi
company (First Party of the Contract) with the receipt of payment and a copy of the
same to PCLD in June of each year […]”

46
 2.6. Procedures for granting licenses (Requirement 2.2)

2.6.1. Licensing process in Federal Government of Iraq

Iraq conducted five oil and gas licensing rounds, which were held in June 2009, December 2009,
October 2010, May 2012, and most recently in April 2018. Under these licensing rounds, the
Iraqi Ministry of Oil, through its wholly owned subsidiaries, signed service contracts (technical
service contracts (TCSs), development and production service contracts (DPSCs), and
exploration, development and production contracts (EDPCs)) with international oil companies
(IOCs).

Under these service contracts, the winning consortium or company becomes a “Contractor” for
the national oil company, which varies by field/exploration block. The national oil company is
referred to as a Regional Oil Company (ROC) in the service contracts and is contractually defined
as an Iraqi state oil and gas company, exclusively entrusted with and authorized for exploration,
appraisal, development and production of the contract area, in accordance with the Law51. The
geographical areas (fields/blocks) were originally allocated to the national oil companies in
accordance with the Organization of the Ministry of Oil Law No. 101 of 1976 (as amended).

In addition, the Iraqi Government has the right to acquire a share of the consortium’s/company’s
total participating interest in the oil and gas license, through a state-owed entity referred to as
the sate partner. While licenses awarded in the first three licensing rounds included state
partner participation in field licenses, contracts signed under the fourth and fifth licensing
rounds did not include state partner participation. A description of the contracts under licensing
rounds, including contract types and terms is included in Section 2.8 below.

The PCLD of the MoO confirmed that there were no licenses awarded through a competitive
bidding process in 2016, and that there are no licenses awarded to international oil companies
outside of licensing rounds. Hence, no new licenses were awarded during the year 2016.
Consequently, there were no non-trivial deviations from the regulatory regime of awarding
licenses, which is described below:

1) Qualifying International Oil Companies (IOCs):

In order to participate in the license round bidding, the candidate IOCs have to be pre-
qualified by the PCLD. The qualification phase involves a review of the documents submitted
by the IOCs and an assessment on the basis of five criteria; legal, technical, financial,
training and environmental safety. A description of the five qualification criteria as
presented in the PCLD’s licenses register is as follows:

51
https://oil.gov.iq/upload/upfile/ar/659.pdf

47
o Legal standards:

The following documents/declarations are required from each applicant company:

 Full company name, type and headquarters’ address

 Articles of Incorporation
 A confirmation from the company’s registrar that the company is still
operational and has not been liquidated, dissolved or bankrupt
 Consortium contract, where applicable, and the ownership interest of each
partner in the consortium
 Tax clearance certificate from the countries in which the company is
operational
 Register of previous projects including ceased projects (completed and
incomplete) with a description of such projects
 A list of all lawsuits the company was a part of (both as a defendant or as a
plaintiff) and all arbitrations, and the outcomes of such lawsuits and
arbitrations
 Authenticated original company documents from the respective authorities

o Technical and training standards:

 Number of exploration and developmental projects managed by the

company (as an operator or non-operator)
 Whether the company is involved in one or more exploration or
development projects in onshore blocks, as an operator or non-operator
 Aggregate production managed by the company
 Estimates of oil inventory/reserves awarded to the company
 Qualitative assessment of the company’s experience in technical challenges
management
 Level of investment in applied research related to extraction activities
 Number of awards or patents in the company’s field of operation
 Trainings conducted by the firm to its employees and trainings organized by
the company in the host country, in accordance with the exploration and
development contracts
 Whether the company has an institute or a training facility

o Financial standards:

 Annual financial statements, audited by an independent certified public

accountant, for three consecutive years
 Financial position determined by expertise houses, and according to the
expertise houses’ worldwide ranking of long-term debt
 Amounts invested in petroleum exploration and development operations
 Total company assets
 Company net profit and current ratio
 Company earnings per share (EPS)

48
 o Environmental safety standards:

 Company policies on environmental and occupational health & safety

management
 Documents related to the applied international standards (ISO 14001 –
18001)
 Documents clarifying the company’s approved contingency plans and
application mechanisms
 Waste management company policy
 Documents related to the occupational health and safety procedures
applied by the company and application mechanisms
 Number of fatal workplace accidents
 Number of environment pollution accidents which impact and pollute air,
soil and water

Companies failing to meet the qualification criteria, due to inadequate technical and
financial competencies as compared with the size and nature of the offered fields, are
disqualified and are therefore not allowed to participate in the licensing round bidding.

According to the PCLD, the different weightings used in the assessment of the above
mentioned criteria is not published, as it is considered confidential information.

2) Announcing licensing rounds:

Licensing rounds are announced through a press conference in which a description of the
oil fields or exploration blocks offered in the licensing round is provided; including location,
reserves, oil or gas deposits, any previous work, and required work.
3) Preparing the initial draft of the contract and the initial tender protocol:
This phase involves preparing the initial contract draft and tender protocol to include the
general principles and requisites of the current licensing round.
4) Preparing the technical data packages:
The technical data packages are prepared in coordination with Ministry’s related
departments and entities, and include a preliminary draft of the service contract, technical
information specific to the disclosed fields, in addition to the preliminary tender protocol
document.
5) Selling data packages:
Data packages are sold to the qualified IOCs and the proceeds from the sale of data packages
are recorded as revenue to the Ministry of Oil.
6) Promotional conference (Roadshow):
A promotional conference is held, and all related government officials and the qualified IOCs
(who purchased data packages) are invited. The purpose of the promotional conference is
to explain the basic features and technical aspects of the contract, as well as answer
questions asked by the participating companies. In addition, one-to-one meeting are
arranged (upon request from the IOCs) to explain any other technical queries.

49
 7) Inquiries:
This phase involves receiving and addressing IOC’s questions and suggestions about the
initial contract draft and preliminary tender protocol.
8) Workshops:
A workshop, or multiple workshops are set up with the attendance of all qualified companies
that purchased the data pack in order to discuss all inquiries.
9) Issuing the model contract and final tender protocol:
Subsequent to the workshops, the contract draft is adjusted accordingly and the final
service contract along with the final tender protocol document are released to the IOCs who
purchased the data pack.
10) Receiving and opening bids:
IOCs submit their bids in a transparent and competitive manner and the firm with the most
competitive bid is selected.
11) Contract award:
The winning bidder (company or consortium of companies) is announced in front of the
media and the attendees. The winning company or consortium is later invited to sign the
contract, in the presence of all governmental and private related parties.
12) Signing the contract after obtaining governmental approval:
The contract is signed by each of the contract parties. The Ministry of Oil then obtains the
approval from the Council of Ministers for the final contract approval.

The bidding parameters and evaluation criteria for each of the bidding rounds, as presented by
the PCLD, are presented below:

First Licensing Round:

The first petroleum-licensing round was announced on 30 June 2008, under which the Ministry
of Oil announced the opportunity for IOCs to bid to develop six oil fields (Rumaila, Zubair, West
Qurna (first stage), Missan fields, Kirkuk, and Bai Hassan) and two gas fields (Akkas and
Mansuriya). Eighty five out of 120 participating companies were eliminated in the pre-
qualification phase. The licensing round lasted for one year, and on 30 June 2009, four oil fields
were awarded. The following two parameters were used for calculating the bid score of the
bidding companies/consortium in the first licensing round:

1) Plateau Production Target (PPT): “means (a) in the case of an Oil Field, the Net Oil
Production Rate, or (b) in the case of a Gas Field, the Net Dry Gas Production Rate
to be achieved and sustained for the Plateau Production Period in the relevant
approved Development Plan.”52 The higher the guaranteed production the better.
2) Remuneration Fee Bid (RFB): the RFB is the remuneration fee the consortium
accepts per produced barrel once it reached the plateau production target. The
lower the fee, the higher the company would score.

52
https://oil.gov.iq/upload/upfile/ar/660.pdf

50
The formula used for selecting the winning bidder, which was disclosed by the PCLD, is the
following:
Bid score = (PPT-IPR) * (50-RFB)

The Initial Production Rate (IPR) is the baseline production capacity of the field before awarding
the field to the company or consortium, which is defined by the MoO and shared with the
participants. The MoO sets a pre-defined maximum remuneration fee (MRF), and the consortium
achieving the highest bid score is invited to match the ministry’s maximum remuneration fee
(MRF). If declines, the consortium with the second highest score is then invited to do the same.
If it is also declines, the contract for the field remains un-awarded.

Second Licensing Round:

The second licensing round offered by the Government of Iraq occurred during the period 11-
12 December 2009. Ten major oil fields were included in the second licensing round, which
resulted in deals for seven fields (Halfaya, Majnoon, Qaiyarah, Badra, Garraf, Najmah and West
Qurna 2). The three fields that were not awarded were East Baghdad, the Eastern Fields and
Middle Furat. Thirty one out of 40 companies who applied for qualification were eliminated in
the pre-qualification phase of the second bidding round.

The formula used for selecting the winning bidders in the second licensing round, which was
disclosed by the PCLD for the purpose of the EITI reporting, is the following:
Bid score = RFB bid score + PPT bid score

RFB bid score = 80* (Lowest RFB/Bidder RFB)

PPT bid score = 20* (Bidder PPT/Highest PPT bid)

Third Licensing Round:

In the third licensing round, three gas fields were offered and awarded; Akkas, Siba, and
Mansuriya. According to PCLD license register, 33 out of 54 participating companies were
eliminated in the qualification phase of the third bidding round.

The formula used for selecting the winning bidders in the third licensing round is the following:
Bid score = RFB bid score + PPT bid score

RFB bid score = 90* (Lowest RFB/Bidder RFB)

PPT bid score = 10* (Bidder PPT/Highest PPT bid)

51
 Fourth Licensing Round:

Iraq’s fourth round of bidding was held in May 2012 and offered twelve blocks for development.
Unlike the previous rounds, which focused largely on expanding existing production, the blocks
offered in the fourth round were unexplored and had undetermined levels of hydrocarbons.
Hence, the only criteria for scoring bidding companies was RFB per BOE (barrels of oil
equivalent), whereby the lower the RFB per BOE offered by a company/consortium, the higher
the score it achieved.

Fifth Licensing Round:

The fifth licensing round was announced during mid- 2017, and is therefore out of the scope of
this EITI report. Under the fifth licensing round, 11 fields and exploration border blocks were
offered. Five of eight new companies were qualified and a total of 26 companies participated in
the bidding round. The fifth licensing round was concluded on 26 April 2018, and six of the 11
projects were awarded, as follows:
1. Gilabat-Qamar contract area was awarded to Crescent Company
2. Khashim Ahmer-Injana contract area was awarded to Crescent Company
3. Naft Khana contract area was awarded to Geo – Jade Company
4. Huwaiza contract area was awarded to Geo – Jade Company
5. Sindbad contract area was awarded to UEG Company
6. Khader Al Mai contract area was awarded to Crescent Company

The two criteria used for scoring the bidding companies are as follows:
1- Maximum Remuneration Percentage Bid (MRPB): The maximum remuneration percentage
that can be granted to a company, which was determined by the MoO
2- Remuneration Percentage Bid (RPB): the remuneration percentage offered by the
company where, the bidding companies’ RPB should be equal to or lower than the MRPB.

The list of all bidding companies for each of the five licensing round fields, and the winning
consortiums for the awarded fields (including the accepted remuneration fee) is included in
Annexes 1 -5.

Mining and Minerals Sector

There were no licensing rounds announced or conducted in the Iraqi mining sector to date (as
per MoIM declaration). According to the MoIM, Investment Law No. 13 of 2006 (as amended)
and the Law of Mineral Investment No. 91 of 1988 govern the mineral sector investment in Iraq.
The Iraqi Geological Survey and Mining Company (Geosurv-Iraq) is an establishment of the
ministry, which is responsible for carrying out geological surveys and mineral explorations,
promoting mining projects in the private and public sectors, and conducting environmental
impact studies. Geosurv-Iraq is also responsible for implementing the Mineral Investment Law
No. 91 of 1988 (as amended), whereby it offers a number of investment opportunities including
investments in phosphate, free sulfur, sulphate, silica sand, red clay, brick clay and others53.

53
http://geosurviraq.iq/Pages?id=1138

52
In accordance with the Mineral Investment Law No. 91 of 1988, the MoIM contracts with private
and public sector companies, by allocating specific mineral quantities to the companies through
the assignment of quarries for specified periods of time.

53
 2.6.2. Licensing process in Kurdistan Region of Iraq (KRI)

According to a Q&A report published on the KRG’s website54, the roles of the Ministry of Natural
Resources (MNR) and the Regional Council for Oil and Gas Affairs (RCOGA) are stipulated by
law. The RCOGA is in charge of formulating the sector’s policies and approving contracts. The
MNR is responsible for the development of natural resources in the region as per Articles 6 to 9
of Chapter 4 of Kurdistan’s Oil & Gas Law (Law No. 22 of 2007).

The process for signing PSCs with IOCs is briefly described on the KRG’s website, as follows:

“The procurement process at the Ministry of Natural Resources involves joint input from both
the oil companies and the ministry, to ensure that a competitive, fair and transparent bidding
process is conducted. In line with our procurement policy, the ministry ensures that all
registered bidders are invited to tender where applicable, all the while ensuring an open door
policy so that bidders, as we refer to them, or subcontractors are able to voice concerns.

The procurement process is conducted by the international oil company (IOC), however it allows
for the joint management committee to monitor the process at various steps. The management
committee chairman (a member of the ministry) along with his fellow members and advisers are
required to approve the bid strategy, to ensure that a fair procurement procedure has been
designed that involves all registered participants and does not handicap any of the tenderers
without firm justification.

During the process, technical and commercial recommendations are evaluated by both the IOC
and the ministry, with the management committee chairman from the ministry providing final
approval. The involvement and advice of both the ministry and the IOC in the procurement
process has helped to develop trust and transparency in the system, allowing for open technical
and commercial discussions that ultimately promote the service sector in the region in support
of oilfield operations.” 55

54
http://cabinet.gov.krd/uploads/documents/2018/KRG_Oil_and_Gas_Sector_Frequently_Asked_Questions_ENG-AR.PDF
55
http://mnr.krg.org/index.php/en/the-ministry/transparency/transparency-in-procurement

54
 2.7. Registry of Licenses (Requirement 2.3)

2.7.1. Federal Iraq

A register of licenses is maintained at the Iraqi Ministry of Oil (specifically at the PCLD), and has
been published by the IEITI on its website56. The tables below display the active licenses in
federal Iraq during the year 2016, which were awarded under the four licensing rounds,
conducted between 2009 and 2012, as reported by the PCLD and respective NOC (license
holder). The license information presented below represents the status of licenses during 2018.

No licensing round (oil and gas field)

First
State Contract Contract Initial Initial
License Contract Commercial
Field Consortium % Partner Operator Signature Effective Production Production
Holder Period Production
% Date Date Rate (IPR) Target (10%)
(barrels)

Al-Waha Al-Waha
SOMO
Ahdeb57 Petroleum 75 MdOC Petroleum 1-Sep-08 10-Nov-08 20 years N/A N/A 25,000
(25)
Co. Ltd Co.

1st round (oil fields)

First
State Contract Contract Initial Initial
License Contract Commercial
Field Consortium % Partner Operator Signature Effective Production Production
Holder Period Production
% Date Date Rate (IPR) Target (10%)
(barrels)58

British
Petroleum 47.63 British
(BP) SOMO
Rumaila BOC Petroleum 3-Nov-09 17-Dec-09 25 years 1,066,000 1,172,600 1,172,600
(6)
(BP)
Petrochina 46.37

ENI 41.56

MOC
Zubair BOC* 29.69 BOC ENI B.V. 22-Jan-10 18-Feb-10 25 years 182,775 201,053 201,053
(5)

KOGAS 23.75

ExxonMobil 32.69

SHELL59 19.61 20 years

West Qurna OEC (extended
BOC ExxonMobil 25-Jan-10 1-Mar-10 244,000 268,400 268,400
(Phase 1) (5) to 30
Petrochina 32.69 years)

Pertamina 10

Missan
Fields (Abu CNOOC Iraq 63.75
IDC CNOOC 20 -Dec -
Gharib, MOC 17-May-10 20 years 88,000 96,800 96,800
(25) Iraq 10
Buzurgan, TPAO 11.25
Fauqi)

56
http://ieiti.org.iq/ar/listing/reports-and-publications/contracts-licences
57
According to MdOC, peak production for Ahdeb field is 115,000 barrels/pay. Average daily production for Ahdeb field during 2016 was
133,100.5 barrels/day
58
The figures for the first commercial production for the four fields awarded in the first licensing round were obtained from the previous IEITI
report for year 2015: http://ieiti.org.iq/en/listing/reports-and-publications/annual-report
59
According to the General Manager of Basra Oil Company, Shell sold its shares in West Qurna (Phase 1) to Itochu Company towards the end of
2017. However, this was not reflected in the license register received from the PCLD.

55
 2nd round (non-producing oil fields)

Initial First
State Contract Contract Initial
License Contract Production Commercial
Field Consortium % Partner Operator Signature Effective Production
Holder Period Target Production
% Date Date Rate (IPR)
(10%) (barrels)

West
LUKOIL Mid- LUKOIL Mid-
Qurna 75 NOC (25) BOC 31-Jan-10 10-Feb-10 25 years - - 120,000
East Ltd East Ltd
(Phase 2)
60
Shell 45
Majnoon MOC (25) BOC Shell 17-Jan-10 1-Mar-10 20 years - 175,000
45,900
Petronas 30

Petrochina 45

Halfaya PETRONAS 22.5 BOC (10) MOC Petrochina 18-Jan-10 1-Mar-10 30 years - 7,000
3,100

Total 22.5

PETRONAS 45
Garraf NOC (25) TQOC61 PETRONAS 26-Jan-10 10-Feb-10 20 years - - 35,000
JAPEX 30

JSC
Gazprom 30
Neft
Korea Gas
Corporation 22.5
(KOGAS) Gazprom
Badra62 OEC (25) MdOC Neft Badra 17-Jan-10 18-Feb-10 20 years - - 15,000
PETRONAS
15 B.V
Carigali
Türkiye
Petrolleri
Anonim 7.5
Ortaklığı
(TAPO)

Qaiyarah63 Sonangol 75 BOC (25) NOC Sonangol 26-Jan-10 18-Feb-10 20 years - - 30,000

Najmah63 Sonangol 75 IDC (25) NOC Sonangol 26-Jan-10 18-Feb-10 20 years - - 20,000

3rd round (gas fields)

Initial First
State Contract Contract Initial
License Contract Production Commercial
Field Consortium % Partner Operator Signature Effective Production
Holder Period Target Production
% Date Date Rate (IPR)
(10%) (barrels)

Korea Gas
KOGAS 100
Akkas64 Corporation 75 NOC (25) MdOC 13-Oct-11 15-Nov-11 20 years - -
Akkas MMscfd
(KOGAS)

TPAO 37.5
Türkiye
Kuwait Petrolleri
22.5
Mansuriya64 Energy Co. OEC (25) MdOC Anonim 5-Jun-11 18-Jul-11 20 years - - 80 MMscfd
Ortaklığı
Korea Gas (TPAO)
Corporation 15
(KOGAS)

Kuwait
0.45
Energy Co. Kuwait
Siba MOC (25) BOC 5-Jun-11 1-Jul-11 20 years - - 25 MMscfd
Energy Co.
TPAO 0.3

60
According to BOC, Shell sold its shares in Majnoon filed to BOC, effective 1 July 2018. However, this is not reflected in the license register
presented by the PCLD.
61
License holder for Garraf field was South Oil Company during 2016 (SOC is known as Basra Oil Company since 2017). The license register
received from the PCLD shows current license information, and therefore does not necessarily reflect the actual ownership status during 2016.
The License was transferred to ThiQar Oil Company during 2017, after South Oil Company was restructured and Thi Qar Oil Company was
established.
62
According to MdOC, peak production for Badra field is 170,000 barrels/pay. Average daily production for Badra field during 2016 was
52,114.2 barrels/day
63
According to NOC, both fields were not operational during years 2016 and 2017, and resumed operations in February 2018
64
According to MdOC, these fields were not operational during 2016, due to security reasons in Iraq

56
 4th round (exploration blocks)

Initial
State Contract Contract Initial First Commercial
License Contract Production
Field Consortium % Partner Operator Signature Effective Production Production
Holder Period Target
% Date Date Rate (IPR) (barrels)
(10%)

Pakistan Pakistan
Exploration
Petroleum 100 N/A MdOC Petroleum 5-Nov-12 5-Dec-12 40 years
Block 8*
Ltd (PPL) Ltd (PPL)

Kuwait
60
Energy Co.
Exploration Kuwait
Dragon Oil 30 N/A BOC 27-Jan-13 3-Feb-13 30 years
Block 9 Energy Co.

EGPC 10
N/A (Exploration blocks)

LUKOIL
Overseas Iraq LUKOIL
60 Overseas
Exploration Exploration
(LOIE) N/A TQOC65 Iraq 7-Nov-12 5-Dec-12 30 years
Block 10
Exploration
(LOIE)
Inpex 40

Exploration
Bashneft 100 N/A BOC Bashneft 8-Nov-12 1-Jan-13 30 years
Block 12

* According to MdOC, this block is still in exploration phase.

As displayed in the tables above, the commodities produced by each field (where applicable)
are listed below:
Ahdeb: oil and gas field
First license round fields: oil fields
Second license round fields: oil fields
Third license round fields: gas fields
Fourth license round: Not applicable (exploration blocks)

The PCLD was requested to provide details about any amendments made to existing service
contracts during the year 2016, however, no response was received from the PCLD in that
regard.

Transfer of license ownership during the year 2016:

The following is a description of the transfers in license ownership that took place during
the year 2016, as follows:

1) As expressed in the general notes of the Zubair Field Operating Division Special Purpose
Statements of Petroleum Costs and Supplementary Costs and Operating Account for the
year 2016 (audited by the oil field’s external auditor), Occidental issued a notice of
withdrawal from the TSC contract on 6 September 2015, and South Oil Company (currently
named Basra Oil Company), expressed its intention to acquire Occidental’s participating
interest. From January 2016, the continuing parties (KOGAS and ENI Iraq BV) were
financing the pro-rata project activities. In September 2016, Occidental completed its
withdrawal and BOC acquired their interest in the TSC.

65
License holder for Exploration Block 10 was South Oil Company during 2016 (SOC is known as Basra Oil Company since 2017). The license
register received from the PCLD shows current license information, and therefore does not necessarily reflect the actual ownership status
during 2016. The License was transferred to Thi Qar Oil Company during 2017, after South Oil Company was restructured and Thi Qar Oil
Company was established.

57
 2) The PCLD reported that during 2016, Premier Oil transferred its 30% share in Exploration
Block 12 to Bashneft. However, the MSG identified that, while the contract to transfer the
ownership shares in the filed license was signed during 2016, the Ministry of Oil approved
the transfer of ownership on 28 May 2017, and hence the effective date of transfer is 28
May 2017.

In addition to the changes in license ownership during the year 2016, the BOC reported that
during July 2015, approval was granted to transfer 10% of Kuwait Energy’s share in Block 9 to
Egyptian General Petroleum Corporation (EGPC).

The table below summarizes the changes in service contract ownership explained above:
Percentage ownership before Percentages of ownership after Date of license
Field
transfer transfer transfer
ENI Iraq B.V 41.56% ENI Iraq B.V 41.56%
Occidental 29.69% BOC 29.69%
Zubair September 2016
KOGAS 23.75% KOGAS 23.75%
MOC 5% MOC 5%
Bashneft 70% 2016 (effective
Block 12 Bashneft 100%
Premier Oil 30% date: 28 May 2017)
Kuwait Energy 60%
Kuwait Energy 70%
Block 9 Dragon Oil 30% 2015
Dragon Oil 30%
EGPC 10%

Changes in license ownership beyond the calendar year 2016 are the following:
- The following statement was published on Shell’s website: “On 14 September 2017,
Shell Iraq Petroleum Development B.V. announced that the Ministry of Oil of Iraq has
endorsed its proposal to pursue an amicable and mutually acceptable handover of the
Shell interest in Majnoon, with timings to be agreed in due course”66.
- According to the BOC, Shell sold its shares in West Qurna (Phase 1) field during end of
2017, to the Japanese Company – Itochu.

According to the PCLD, the process of transferring shares in service contracts is done through
full or partial assignment of rights and obligations, in accordance with Article 28 of the service
contracts, which provides the following:

“28.1 No Company may assign its rights or obligations under this Contract, in whole or in part,
without the prior written consent of ROC67.”

“28.2 In the event that any Company wishes to assign any of its Participating Interest, shares,
rights, privileges, duties or obligations under this Contract to a wholly-owned and controlled
Affiliate, the Company shall submit to ROC a request to this effect together with documentary
evidence that the said Affiliate has been qualified by the Ministry of Oil and such qualification
remains in effect as of the date of the proposed assignment. ROC shall not withhold consent to
assignment to a wholly-owned and controlled Affiliate if said Affiliate has been qualified by the
Ministry of Oil and such qualification remains in effect as of the date of the proposed
assignment. Notwithstanding the foregoing, unless expressly agreed by ROC in the written
consent, such assignment shall not release the Company from its obligations under this Contract

66
https://www.shell.com/media/news-and-media-releases/2018/shell-to-sell-its-stake.html
67
ROC refers to Regional Oil Company; the national oil company that holds the field or block license

58
 and it shall remain jointly responsible together with the assignee Affiliate for the proper and
timely execution of this Contract.”

“28.3 In the event that any Company wishes to assign, in whole or in part, any of its Participating
Interest, shares, rights, privileges, duties or obligations under this Contract to a third party or
an Affiliate that is not wholly-owned, the Company shall submit to ROC a request to this effect
giving detailed evidence of the technical and financial competence of the recommended
assignee (i.e. the recommended assignee must be qualified by the Iraqi Ministry of Oil). ROC
shall consider the said request and notify the Company of its consent or otherwise within three
(3) months of receipt thereof. Before such assignment becomes effective, the assignee shall
first provide ROC with a guarantee acceptable to ROC in the form set out in Annex F after which
ROC shall, to the extent of the assigned Participating Interest, release assignor from its
obligations under this Contract and any guarantee provided to it by assignor.”

Further details on the process of assigning license shares under service contracts is included in
Article 28 of the model DPSC68.

The PCLD further clarified the process applied in practice to transfer ownership shares in a
license as follows:

 A request is made by the contractor, to the national oil company (license holder), to
notify the national oil company of its decision to sell its shares in the field license
 In accordance with a pre-emptive rights clause, the shares of the contractor are offered
to the remaining consortium companies and the national oil company, for a three-month
period
 After that period, the shares are offered to external parties
 Once a decision is made, a deed of assignment is signed between the selling entity and
purchasing entity (former contractor and current contractor)
 An amended contract is then signed between all concerned parties; national oil
company, consortium companies (reflecting the new shares), and the state partner
 If the purchasing company is a subsidiary of another company, the parent company is
required to provide the PCLD with a letter of guarantee, in relation to the obligations of
the contractor under the field license

As it related to the transfer of Garraf license from BOC to ThiQar Oil Company, the PCLD clarified
the transfer rationale and process as follows:

Due to the increase in production of Garraf field, and in accordance with the law that allows for
the establishment of a new public company once a field’s production exceeds 100,000 barrels
per day, Thi Qar Oil Company was established. To make the license transfer, a novation
agreement was signed between all contract parties; BOC, TQOC, consortium companies and the
field state partner.

Although this clarification was provided by the PCLD and it also confirmed through meetings
that the process of transferring shares in the service contracts mentioned above was done in
accordance with Article 28 of service contracts and its internal procedures, it did not present

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59
 documentation in that regard. Hence, we were unable to identify any deviations in this process
(if any).

2.7.2. Kurdistan Region

The Ministry of Natural Resources of the Kurdistan Regional Government publishes production
sharing contracts (PSCs) signed with international oil companies on the KRG website69. This list
of PSCs published on the KRG website is included in Section 2.8 below. Based on a review of the
PSC and amendments published on the KRG websites, we could not identify any amendments, or
Assignment and Novation agreements signed during the year 2016, and thus we were unable to
identify whether there were any transfer of ownership rights during the year under review.

2.8. Contracts in the extractive industries (Requirement 2.4)

2.8.1. Policy on contract disclosure

There MSG understands that there is no written policy of the Government of Iraq on the subject
of contract disclosures in Federal Iraq. However, the MSG acknowledges that, although there is
no written policy on the publication of oil and gas contracts, the current practice of the PCLD is
to only publish contract templates, and not the signed contracts.

The PCLD declared that it has published all contract templates on the website of MoO, and thus
the templates are available to the public with no restrictions on access. The PCLD also stated
that the templates do not differ from the signed contracts, with the exception of some
information, which is disclosed separately.
The links provided by the PCLD, in relation to the contract templates are the following:

 Development and Production Service Contracts (DPSC)

(https://oil.gov.iq/upload/upfile/en/98.pdf)
 Exploration, Development and Production Service Contracts (EDPSC)
(https://oil.gov.iq/upload/upfile/en/97.pdf)

In an announcement made by the PCLD and published on the MoO website, the PCLD stated that
their practice is governed by business practices that are in line with international professional
standards applied in all oil rich countries.

The PCLD also stated that the data packages prepared for each licensing round, which include
technical information specific to the fields and exploration blocks offered in addition to a
preliminary contract draft and tender protocol, are sold to pre-qualified companies wishing to
participate in the bidding round for set fees, after signing confidentiality agreements. Among the
reasons specified by MoO for signing the confidentiality agreements is to maintain confidentiality
of information, since its public circulation would be detrimental to the public interest, and to the

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60
 value of information. According to the MoO, it is common practice for resource rich countries to
safeguard information related to their petroleum wealth70.

Kurdistan Region

The Ministry of Natural Resources of the Kurdistan Regional Government (KRG) publishes the
production sharing contracts (PSCs) signed with international oil companies on the KRG
website71. The following table lists out the 42 fields for which the related PSCs and amendments
were published on the KRG website:

Oil Fields
Barda
Ain Sifni Akri Bijeel Arbat Atrush Baranan Bazian
Rash

Chia Surkh Mala Omar Duhok Erbil Garmain Harir Hawler

Pramagrun Pulkhana Qala Dze Qara Dagh Taza Rovi Safen

Sindi
Sangaw North Qush Tapa Sarta Sheikh Adi Shakal Shorish
Amedi
Central
Sangaw South Topkhana Miran Shakrok Tawke Bina Bawi
Duhok

Ber Bahr Kurdamir Sarsang Sulevani Dinarta Shaikan Taq Taq

However, the uploaded PSCs do not seem to be comprehensive. According to publicly available
information, Dana Gas Company, a UAE based company listed on Abu Dhabi Securities Exchange
(ADX), has been active in the KRG since April 2007. According to information published on Dana
Gas Company website, Dana Gas and Crescent Petroleum entered into agreement with the KRG
in 2007, for exclusive rights to develop, process and transport natural gas from the Khor Mor
gas field, and to also appraise the potential of the Chemchemal gas field72. Production from a
newly built plant began in October 2008, and in 2009, Pearl Petroleum was formed as a
consortium with Dana Gas and Crescent Petroleum as shareholders, and with OMV, MOL, and
RWE joining the consortium subsequently with a 10% share each73.

In addition, the KRG entered into PSCs with Rosneft, a Russian integrated energy company, in
October 201774 for five production blocks; Batil, Zawita, Qasrok, Harir-Bejil and Darato.

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https://oil.gov.iq/index.php?name=News&file=article&sid=1966
71
http://mnr.krg.org/index.php/en/the-ministry/contracts/pscs-signed
72
http://www.danagas.com/en-us/operations/iraq
73
http://www.danagas.com/en-us/media-center/press-releases/press-release-details?ID=298
74
http://www.rudaw.net/english/analysis/31072018

61
 2.8.2. Contracts in the extractive industries

2.8.2.1. Contracts in Federal Iraq

In Federal Iraq, service contracts are used, under which the contractor receives a fixed fee per
barrel (remuneration fee), above reimbursement of the costs it incurs (recoverable costs).

The following service contracts have been used in the petroleum-licensing rounds managed by
the Federal Government of Iraq:

 Technical Service Contracts (TSCs)

 elopment and Production Service Contracts (DPSCs)
 ontracts (GDPSC)
 Exploration Development and Production Service Contracts (EDPSC)

Contract terms:

i. Cost recovery and remuneration fees:

Recoverable Costs:

Under the Ministry of Oil’s service contracts (TSCs, DPSCs, etc.), expenses incurred in conducting
petroleum operations include petroleum costs and supplementary costs, which are generally
recoverable.

- Petroleum costs: include recoverable costs and expenditures incurred and payments
made by the companies in connection with or in relation to the conduct of petroleum
operations.
- Supplementary costs: include recoverable costs and expenditures other than
petroleum costs. These costs specifically include de-mining costs, financing and building
of transportation facilities beyond the transfer point of petroleum production from the
contract area, specific works or building of facilities (at the request of the regional oil
company) and remediation costs.

Remuneration fees:

In respect of the compensation under the service contracts, the contractor (the international oil
company operating in the production of oil and gas in Iraq) is paid a fixed fee per barrel known
as the remuneration fee.

Cost recovery and remuneration fees are calculated in accordance with article no. 19 of the
service contracts. The following are excerpts from the model DPSC published on the MoO
website75.

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62
Article 19.3: “Contractor shall start charging Petroleum Costs to the Operating Account as from
the Effective Date, in accordance with this Contract and the Accounting Procedures, but the
same shall be due and payable in accordance with Article 19.5 and the Accounting
Procedures (Annex C).”

Article 19.4: “Contractor shall become entitled to Remuneration and shall start charging the
same to the Operating Account only from the Eligibility Date. For the Quarter in which
Remuneration first becomes payable, the Remuneration shall be an amount equal to the product
of the Remuneration Percentage Bid and Remaining Net Deemed Revenue from the Eligibility
Date to the end of that Quarter.
(a) For any subsequent Quarter, the Remuneration shall be an amount equal to the
product of the Remuneration Percentage Bid and Remaining Net Deemed Revenue.
(b) For any Quarter in respect of which Remuneration is due and payable, the
Remuneration Percentage Bid shall be adjusted by multiplying it by the Performance
Factor. However, any adjustment of this Remuneration Percentage Bid shall cease for so
long as the following cases shall apply: (i) Government imposed production curtailment
under Article 12.5(d); or (ii) where normal production is curtailed or suspended through
failure of the Transporter(s) to receive the same at the Transfer Point(s) at no fault of
the Operator or Contractor under Article 12.5 (e).”

The mechanism for calculating cost recovery and remuneration fees applied by the PCLD is
summarized as follows:

 A detailed statement of account, listing all petroleum costs and production data is prepared
by the contractors (IOCs) and sent to the respective national extractive companies (NOCs)
for audit and review
 A meeting is then conducted at the national oil company sites, which is attended by the
representatives of various committees and departments (including Finance Committee,
Operational Committees, License Affairs Department, Internal Control and Contract Audit
Department), along with the contractors’ representatives to discuss the petroleum costs,
supplementary costs and remuneration fees listed in the statements of account
 The related meeting observations are documented and are sent in an official letter to a
ministerial committee to review the contractors’ statements of account. Subsequently, a
meeting is held by the committee at the MoO site, in the presence of all representatives of
the different committees and IOCs mentioned above, to discuss the observations
 The calculation of contractors’ receivables (cost recovery and remuneration fees) are
prepared by the PCLD (Commercial Department), in accordance with the terms of the
respective service contracts. The process involves setting percentages for petroleum costs
in accordance with a maximum recovery limit after calculating the estimate revenues based
on the preliminary oil-selling price announced by SOMO. In addition, remuneration fees are
calculated in accordance with the contract terms for each field
 The minutes of meeting are documented and after the obtaining the Minister’s approval on
the minutes, the minutes are sent in an official letter to SOMO. SOMO accordingly settles
the quarterly financial obligations (cost recovery and remuneration fees) to the IOCs

63
 (contractors) in the form of crude oil (liftings), in shipments determined by SOMO (which
could take up to several months)

Source: PCLD- MoO

ii. Training, technology and scholarship fund: Article 26 of the service contracts (TSCs/DPSCs
etc.) in Federal Iraq requires contractors to pay certain amounts into training, technology
and scholarship funds (TTS fund), which are non-recoverable costs for the contractor.

Payments made by IOCs during 2016, in respect of TTS fund are detailed in Section 6.4.

2.8.2.2. Contracts in Kurdistan Region

In Kurdistan Region, the Oil and Gas Law No. 22 of 2007, allows the use of production sharing
contracts (PSCs), under which the Contractor receives a percentage of the profit oil. Article 37
of the Oil and Gas Law specifies the standard terms of a production sharing contract, which
include (but are not limited to) the following:

 “An initial exploration term of a maximum of five years, divided into two sub-periods, of
three years and two years, extendable on a yearly basis for up to a maximum total of seven
(7) years
 Relinquishment of twenty-five percent after the initial exploration term, with a further
twenty-five percent of the remaining area at the end of each renewal period. If these
percentages of relinquishments can only be achieved by including part of the area of a
discovery, these percentages shall be reduced to exclude the discovery area. Voluntary
relinquishment at the end of each Contract year is permitted
 An exploration commitment, which shall be negotiable, involving the purchase and
interpretation of all existing data, including seismic data, where available, and seismic
acquisition in the first sub-period, with exploration drilling in the second sub-period and a
Well in each of the annual extensions
 A development period, following discovery, to be twenty (20) years, with a right of the
Contractor to a five (5) year extension, on the same terms and conditions, with possible
further extensions to be negotiated
 Royalty, at a rate of ten percent (10%), and paid in accordance with Article 41 of this Law
 Cost recovery from a portion of production after deduction of the Royalty, to a maximum
not exceeding forty-five percent (45%) for Crude Oil; and not exceeding sixty percent (60%)
for Natural Gas
 Production sharing from remaining production after Royalty and allowable cost recovery
according to a formula, which takes into account cumulative revenues and cumulative
petroleum costs and provides the Contractor with reasonable returns.”

64
Payments made by IOCs in Kurdistan Region in accordance with PSCs signed with the KRG:

Bonuses: Bonuses include signature, capacity building bonus and production bonus, which are
determined in the production sharing contracts with the IOCs
Capacity Building Payments: Under PSCs, international oil companies make capacity-building
payments once they generate profit oil, which are used in funding large social programmes
including infrastructure development
License fees: These are fees and other sums paid as consideration for acquiring a license for
gaining access to an area where extractives are performed
Royalties: The contractor's production is subject to a 10% royalty rate payable to in cash or in
kind as the KRG
Taxes: According to Article 41 of the Oil and Gas Law of 2007, a petroleum contract may
exempt a contractor from tax by law

65
2.9. Beneficial ownership of material extractive companies
(Requirement 2.5)

The MSG has published a roadmap for disclosing beneficial ownership information in Iraq, on the
website of the IEITI. In the roadmap, a beneficial owner is defined as a person who directly or
indirectly exercises substantial control over a legal entity or has a substantial economic interest
in, or receives substantial economic benefit from such legal entity.

Beneficial ownership disclosures required for companies operating in the extractive mineral, oil
and gas sector, as per the roadmap, are:

 The name of the beneficial owner(s), in addition to any alternate names they may use.
 The names and roles of any politically exposed persons who own or practice control over
a company, irrespective of the size of their ownership interest
 The related details of the owner(s), including date of birth, ID number, place of
residence, and the names of first degree relatives (specifically for the politically exposed
persons)
 Attachment of supporting documents for the beneficial ownership information
 Other information such as the company manager’s name

The roadmap action plan requires the National Secretariat to prepare a complete database with
the required beneficial ownership information for companies operating in the upstream and
downstream sectors of extractive industries, and link it electronically with the companies’
registrar office, Ministry of Trade, the PCLD/Mo, and the IEITI. Such database has not yet been
implemented in Iraq.

For the purpose of the Iraq EITI 2016 report, national oil and gas companies were required to
disclose all secondary contracts worth over USD 100 million, clarifying the name of the
company, value of the contract, and the date of signing the contract. Accordingly, the IEITI
would request from the Ministry of Trade (Companies registrar) the beneficial ownership
information of individuals/entities with ownership stake of 10% or more in the contracting
company. However, all national oil and gas companies reported that there were no secondary
contracts over USD 100m signed during the calendar year 2016.

66
3. Extractive Industries Exploration, Production and Export
Activities (Requirement 3)

3.1. Oil and Gas Sector in Federal Iraq

3.1.1. Oil and gas fields in Iraq

As discussed previously in this report, there are five national oil companies operating in the
upstream sector of Iraq’s oil and gas sector; South Oil Company (currently known as Basra Oil
Company), North Oil Company, Midland Oil Company, Missan Oil Company, and Thi Qar Oil
Company (not operational during 2016, and was officially opened in 2017). These national oil
companies have responsibility for the development of oil and gas fields in the provinces in which
they operate. Of the fields within each company’s territory, some are operated by the national
oil companies independently, while others are operated by international oil companies under
licensing rounds service contract. While the allocation of fields to national oil companies for the
purpose of licensing round production was made in accordance with Law No. 101 of 1976, the
allocation of fields to national oil companies for the purpose of national production is made in
accordance with each company’s activities as per their certificates of incorporation, and in
accordance MoO plans. Hence these fields are not allocated to national oil companies through
license round biddings.

67
The following tables present the producing and non-producing oil and gas fields operated by
national oil companies and by IOCs under licensing round contracts, as of 1 January 2017. The
data was presented by the Ministry of Oil’s Reservoir and Field Development Directorate in a
report related to the proven oil and gas reserves in Iraq (excluding KRG). The following data
does not take into consideration events after 1 January 2017, and therefore no data is
presented in relation to Thi Qar Oil Company. The methodology documented in the MoO’s report
explains that the approved reserves studies are based on the final development plans (FDPs and
ERPs) for the fields offered in the first, second and third licensing rounds, in addition to detailed
reservoir and geological studies for the fields of national efforts, and non-producing field
reserves.

Producing fields Non-producing fields

Fields operated Fields operated Fields operated by Fields operated
Company name
by NOCs by IOCs NOCs by IOCs
Gas Fields
None None None 1- Siba
Oil Fields
1- Bin Omar 1- West Qurna 1- Rachi 1- Arido
2- Artawi 2- Zubair 2- Jeraishan
Basra Oil
3- Al-Nasriyah 3- Majnoon 3- Semawa
Company
4- Tuba 4- Rumaila 4- Abu-Khaima
5- Subba 5- Garraf 5- Sindbad
6- Luhais 6- Block 9 (Al-
Faihaa)
Source: Ministry of Oil - Reservoir and Field Development Directorate

Producing Oil Fields Non-producing fields

Fields operated Fields operated by Fields operated Fields operated
Company name
by NOCs IOCs by NOCs by IOCs
Gas Fields
None None 1- Khanuqah None
2- Khashab
Oil Fields
1- Kirkuk* Al-Qaiyarah 1- Jawan Najmah
2- Bai Hassan** 2- Ismail
3- Jambur 3- Qasab
North Oil 4- Sufaiya** 4- Makhmur
Company 5- Khabaz 5- Judaida
6- Ajil 6- Alan
7- Tikrit 7- Sasan
8- Balad 8- Qara Chauq
9- Ain Zalah + 9- Pulkhana
Butmah 10- Ibrahim
10- Himrin
Source: Ministry of Oil - Reservoir and Field Development Directorate

68
The following information was documented in the scoping study prepared by the IEITI for the
year 2016:

 As it relates to Kirkuk, Avana Dome is under the control of KRG since 11 July 2014 and
Khurmala Dome is under the control of KRG since 2009

** These fields are under control of KRG since 11 July 2014

Producing fields Non-producing fields

Fields
Fields operated by Fields operated by Fields operated
Company name operated by
IOCs NOCs by IOCs
NOCs
Gas Fields
None None None None
Oil Fields
1- Amara 1- Helfaya 1- Abu-Amood None
Missan Oil 2- Noor 2- Missan fields: 2- Kumait
Company  Buzurgan 3- Dujaila
 Fauqi 4- Rifaee
 Abu 5- Huwaiza
Ghirab 6- Dima
Source: Ministry of Oil - Reservoir and Field Development Directorate

Producing fields Non-producing fields

Fields
Company Fields operated Fields operated by
operated by Fields operated by NOCs
name by NOCs IOCs
IOCs
Gas Fields
None None Jaria Pika 1- Akkas
2- Mansuriya
Oil Fields
1- East 1- Ahdeb 1- Nahrawan None
Baghdad 2- Badra 2- Khashim Al-Ahmar
2- Naft Khana 3- Injana
Midland Oil 4- Gilabat
Company 5- Tel Ghazal
6- Nau Doman
7- Qumar
8- Dhufriya
9- Merjan
10- Kifl
11- West Kifl
Source: Ministry of Oil - Reservoir and Field Development Directorate

69
 3.1.2. Oil and Gas reserves in Iraq

The following tables present the reserves of oil and gas in federal Iraq as of 1 January 2017, as
reported by the Ministry of Oil – Reservoir and Field Development Directorate, in the report
discussed in the Section 3.1.1. The proven reserves include quantities that can be produced
using the below listed methods which are technologically feasible within the current limitations:

1- Production by natural propulsion without water injection

2- Production by natural propulsion with water injection
3- Use of industrial lifting methods

The following table displays the proven oil reserves in federal Iraq as of 1 January 2017,
presented by national oil company.

Oil Reserves
Original Oil-In-Place Original Oil
No. of Remaining Oil Reserves
Company (OOIP) Reserves
fields Billion Bbls
Billion Bbls Billion Bbls
BOC 19 339.7 124.8 102.2

MOC 12 39.7 11.1 10.1

NOC 24 114.2 41.9 24.4

MdOC 18 52.2 12.2 11.7

Total 73 545.8 190 148.4

Source: Ministry of Oil - Reservoir and Field Development Directorate

The following table display the proven gas reserves in federal Iraq as of 1 January 2017,
presented by national oil company.

Gas Reserves
Total
Associated gas Free gas Remaining
(Trillion SCF) (Trillion SCF) (associated &
No. of free gas)
Company
fields Initial Initial Initial Initial
Remaining Remaining
associated associated free free Remaining
associated associated+
gas in gas gas in gas free gas
gas free gas
place reserve place reserve

BOC 19 268.6 94.56 80.06 3.86 2.74 2.74 82.8

MOC 12 22.1 5.71 5.2 - - - 5.2

NOC 24 39.4 14.6 7.6 22.1 17.6 16.6 24.2

MdOC 18 32.8 9.7 8.8 17.4 13.9 13.9 22.7

Total 73 362.9 124.57 101.66 43.36 34.24 33.24 134.9

Source: Ministry of Oil - Reservoir and Field Development Directorate

70
The following table display the proven condensate reserves in federal Iraq as of 1 January 2017,
presented by national oil company. The condensate reserve data presented in the MoO report
was generated by estimating the amount of condensate expected to be produced from gas
deposits over their useful (productive) lives, and adding the estimate to the initial reserve.

Condensate Reserves
Condensate
No. of (Million barrels)
Company
fields Initial condensate
Remaining condensate reserve
reserve
BOC 1 210 210
MOC - - -
NOC - - -
MdOC 2 110 110
Total 3 320 320
Source: Ministry of Oil - Reservoir and Field Development Directorate

71
 3.1.3. Drilling and well workovers carried out by the Iraqi Drilling
Company

Iraqi Drilling Company (IDC) is a SOE under the MoO specialized in drilling, and oil and gas well
workovers. The following section provides an overview of the work carried out by the IDC during
the calendar year 2016 in relation to fields operated by national oil companies and fields
operated by IOCs under service contracts.

The following table displays the drilling and rehabilitation work performed by the IDC during
2016 for fields operated by national oil companies independently “national efforts”:

Number of wells Number of wells

Beneficiary Location Field
drilled rehabilitated
South Oil
Company Al-Basrah and Al-Basrah and Dhi
22.71 11.7
(Basra Oil Dhi Qar Qar fields
Company)
Missan Oil
Maysan Amara field 2.15 2
Company
Midland Oil
Baghdad East Baghdad field - 1.2
Company
North Oil
Kirkuk Kirkuk field 1.46 6.04
Company
Total activities performed for nationally operated
26.32 20.94
fields
Source: Data presented was reported by Iraqi Drilling Company

The following table displays the drilling and rehabilitation work performed by the IDC Company
during 2016 for fields operated by IOCs under licensing round contracts:

Number of Number of wells

Beneficiary Location Field
wells drilled rehabilitated
ExxonMobil West Qurna (Phase 1) - 28

ENI Zubair 5.03 52.75

Al-Basrah
BP Rumaila - 10
LUKOIL Mid-
West Qurna (Phase 2) 6 1
East Ltd
Petronas Thi Qar Garraf - -

Total activities performed for IOC operated fields 11.03 91.75

Source: Data presented was reported by Iraqi Drilling Company

72
 3.1.4. Significant exploration work carried out by the Oil Exploration
Company (Requirement 3.1)

1- Seismic surveys: Seismic data obtained is required for updating of the fields’ geological model,
both for the discovered formations and prospective horizons. The following is a description of
seismic surveys carried out during the calendar year 2016:

a. National seismic teams within the OEC conducted seismic surveys of the following areas
during the year 2016, for the benefit of national oil companies and international oil
companies operating under licensing rounds as follows:

Program Survey type Beneficiary

West Qurna (Phase 2) 3D LUKOIL Mid-East Ltd

Block 9 3D Kuwait Energy

Block 8 3D Pakistan Petroleum Ltd (PPL)

Al-Okhaider 3D

Laksh 3D

Najaf – Karbala 3D National extractive companies

Block 11 2D
Remaining areas of
2D
Muthanna and Hadeer
Source: Oil Exploration Company

The teams carried out 3D seismic surveys covering 2,590 square kilometers, in addition to 2D
seismic surveys covering 1,834 linear kilometers.

b. Vertical surveys of the following wells were performed during the year 2016 as follows:
 West Qurna (Phase 1) well by Halliburton Company
 Vertical survey of Sindbad (3) well at three recordings (long offset, zero offset,
check offset)

2- Exploratory drilling and evaluation

OEC carried out geological appraisals and explorations for the following exploration and
excavated wells during the year 2016:
Well Beneficiary
Exploration well (Arido -1 ) of Block 10 LUKOIL Overseas Iraq Exploration (LOIE)
Excavated well (Faihaa -2) of Block 9 Kuwait Energy
Excavated well (Faihaa -3) of Block 9 Kuwait Energy
Excavated well (Sindbad -3) Basra Oil Company
Source: Oil Exploration Company

73
 3.1.5. Crude oil production for year 2016

As briefly presented in Section 3.1 above, there are two types of production in Federal Iraq. The
first type of production is the production undertaken by the IOCs under the licensing round
service contracts, referred to as “licensing rounds production”. The second type of production
is referred to as “national efforts production” and is the production of crude oil from the oilfields
that the NOCs operate independently. The following section presents crude oil quantities
produced during 2016, reported by national oil companies, in respect of both national efforts
production and licensing round production.

The following table presents crude oil production quantities reported by Basra Oil Company for
year 2016:

National Efforts Production Licensing Rounds Production Total Production

(barrels) (barrels) (barrels)

64,426,11476 1,106,408,010 1,170,834,124

Source: Data presented was reported by BOC

The following table presents crude oil production quantities reported by Midland Oil Company
for year 2016:

National Efforts Production Licensing Rounds Production Total Production

(barrels) (barrels) (barrels)

4,035,130 67,603,391 71,638,521

Source: Data presented was reported by MdOC

The following table presents crude oil production quantities reported by Missan Oil Company for
year 2016:

National Efforts Production Licensing Rounds Production Total Production

(barrels) (barrels) (barrels)

7,821,571 125,510,245 133,331,816

Source: Data presented was reported by MOC

The following table presents crude oil production quantities reported by North Oil Company for
year 2016:

National Efforts Production Licensing Rounds Production Total Production

(barrels) (barrels) (barrels)

58,232,852 - 58,232,852
Source: Data presented was reported by NOC

76
Quantities produced from Al-Nasriyah oil field was reported by BOC under licensing round production quantities. However, BOC’s Annual
Statistics Report for the year 2016, displays production quantities by field, and therefore depicts the actual distribution of national vs licensing
round production, including the production generated from Al-Nasiriya oil field.

74
National effort production figures reported by the national oil companies in the tables above
(for year 2016) reflects production from the following fields:

National Oil Company Producing fields

Al-Luhais
Artawi
BOC Bin Omar
Tuba
Al-Nasiriya
Kirkuk
Jambur
NOC Bai Hassan
Khabaz
Sifaya
East Baghdad fields
MdOC
Naft Khana
Noor
MOC
Amara

The largest producing fields in federal Iraq are the Southern fields, whereby production
generated by fields operated by Basra Oil Company (both independently and through IOCs)
represented 81.65% of total production in federal Iraq during 2016.

The following is a breakdown of production by field reported by Basra Oil Company in its Annual
Statistics Report for the year 2016:

Total Production
Field
(barrels)
Rumaila 516,340,603
Zubair 134,711,571
Bin Omar 12,407,883
Al-Luhais 32,631,608
West Qurna 1 162,835,918
West Qurna 2 148,807,189
Majnoon 78,469,336
Tuba 13,262,897
Artawi 6,123,726
Al-Nasiriyah 26,023,131
Garraf 36,914,425
Faihaa (Block 9) 2,305,837
Total 1,170,834,124

75
 3.1.6. Flow of crude oil for national oil companies during the year 2016

The following table presents the flow of crude oil quantities related to South Oil/Basra Oil
Company for year 2016. As displayed in the table below, BOC receives crude oil produced by
Midland Oil Company and Missan Oil Company. The transfer of crude oil between the national oil
companies is made due to the following reasons:
- Crude oil is transferred to the national oil companies that have control over export ports such
as Basra port situated in Al-Basrah
- The production of some national extractive companies is not sufficient for internal
consumption in their respective provinces, therefore, they receive crude oil from other
companies to cover such shortages

BOC
(barrels)
Beginning Balance 49,014,777
Crude Oil Produced 1,170,834,124
Quantities received from
51,254,378
MdOC
Quantities received from
127,617,594
MOC
Mixed residue 17,264,885
Crude Oil Exported (1,201,145,804)

Refineries (134,014,552)

Power plants (32,529,137)

Others (107,825)

Ending Balance 48,188,440

Source: Data presented was reported by BOC

76
The following table presents the flow of crude oil quantities related to Midland Oil Company for
year 2016:

MdOC
(barrels)
Beginning Balance 605,382

Crude Oil Produced 71,638,521

Quantities received from
2,222,884
the strategic line
Quantities received from
6,260,990
NOC
Crude Oil Exported (32,226,211)

Refineries (510,020)

Power plants (28,308,272)

Supplied quantities from
(19,028,166)
Badra oil field to BOC
Loss (8,850)

Others (63,839)

Ending Balance 582,419

Source: Data presented was reported by MdOC

The following table presents the flow of crude oil quantities related to Missan Oil Company for
year 2016:

MOC
(barrels)
Beginning Balance 433,219

Crude Oil Produced 133,331,816

Mixed residue 3,352,107

Crude Oil Exported (123,528,620)

Refineries (8,945,510)

Power plants (4,088,974)

Others (67,156)

Ending Balance 486,882

Source: Data presented was reported by MOC

The following table presents the flow of crude oil quantities related to North Oil Company for the
year 2016:
77
 NOC
(barrels)
Beginning Balance 3,660,558
Crude Oil Produced -
58,232,852
National efforts
Crude Oil Produced-
Supplied from Avana and -
Bai Hassan fields
Khor Mor condenser -
Mixed residue and
-
Gasoline
Crude Oil Exported (7,297,425)

Refineries (10,347,656)

Power plants (6,285,446)

Loss -
Crude Oil Exported
through KRG pipelines (20,351,220)
system From IT1
Injected crude oil (21,069,000)

Supplied to Ceyhan port -

Others (288,363)

Ending Balance 3,551,725

Source: Data presented was reported by NOC

78
 3.1.7. Gas production during 2016

Associated gas is gas associated with oil fields, typically as a byproduct of oil production, while
non-associated gas is extracted from gas fields. Three gas fields have been awarded under
license rounds in Federal Iraq; Akkas (in Anbar province); Mansuriya (near the Iranian border in
Diyala province), and Siba (in Basra)77. As stated in Section 2.7, these three gas fields were
awarded under the third licensing round. However, there has been limited activity in these fields
since they have been awarded. Both Akkas and Mansuriya gas fields were not operational during
2016, due to the challenging security reasons inflicted by the insurgency of ISIS in Iraq since
2014.

The following table presents gas production quantities, as well as the flow of gas produced for
internal consumption, reported by North Oil Company for the calendar year 2016:

Gas Produced Internal Consumption

(mmscf) (mmscf)

Mullah
Jambur Dibis Used for
Associated North Gas Kirkuk Abdallah KRG
Dome Power company Others
gas Company Refinery Power stations
gas station purposes
station

50,234 103,041 74,134 478.0 404.0 6,365.0 27,096.0 6,122.0 38,676

Source: Data presented was reported by NOC

The following table presents the quantities of associated gas produced, invested and burnt,
reported by Basra Oil Company for the calendar year 2016:

Gas Produced Invested Gas Burnt Gas

(million cubic meter) (Million Cubic Meter) (million cubic meter)

Supplied to gas Direct supply to Non-

Associated Gas Condensates Investable
companies network investable

739,697.90 207,904 39,114 321 36,192 456,166.9

Source: Data presented was reported by BOC

77
https://www.atlanticcouncil.org/images/Shaping_Iraqs_Oil_and_Gas_Future_web_0108.pdf

79
The following table presents the quantities of associated gas produced, invested and burnt,
reported by Midland Oil Company for the calendar year 2016:

Gas Produced Invested Gas

(mmscf) (mmscf)
Burnt Gas
Dry gas supplied to Al- Converted to (mmscf)
Associated Gas Used
Zebadiah LPG

61,425.69 4,119.61 17,859.50 1,192.51 38,254.07

Source: Data presented was reported by MdOC

The following table presents the quantities of associated gas produced, invested and burnt
reported by Missan Oil Company for the calendar year 2016:

Gas Produced Invested Gas

(cubic meter) (Cubic Meter)
Burnt Gas
(cubic meter)
Associated Gas Supplied to refineries Used internally

2,291,933,545.67 635,200,526.449 71,483,095.25 1,585,249,925.071

Source: Data presented was reported by MOC

80
 3.1.8. Production and supply of petroleum products during 2016

3.1.8.1. LPG, Condensate and Dry Gas production by Basra Gas

Company during 2016

The following table presents LPG and condensate produced by BGC during the year 2016:

2016
LPG Condensate Dry Gas Dry Gas
Month
(Ton) (Cubic Meter) (Cubic Meter)
January 101,625 23,269 344,803,311
February 98,400 29,345 336,243,066
March 91,575 32,545 331,906,625
April 100,525 43,158 363,472,531
May 102,231 51,466 373,018,331
June 89,697 46,852 329,569,453
July 93,563 51,522 372,342,522
August 101,800 62,366 396,474,530
September 93,893 58,610 400,585,701
October 79,767 52,355 402,049,953
November 88,700 42,070 348,379,466
December 99,188 43,688 358,319,488
Total 1,140,964 537,246 435,716,498
Source: This information was reported by BGC

3.1.8.2. Petroleum products supplied by refineries during 2016

The following table presents the quantities and values of RT fuel supplied by refineries to the
OPDC:

RT Fuel
Quantity Amount
Company
(Cubic Meter) (IQD)
NR - -
SR 39,824 6,969,200
MdR 51,649 9,096,289,409
Total 91,473 9,103,258,609
Source: This information was reported by the respective refineries

81
The following table presents the quantities and values of RT fuel supplied by the Midland
Refineries Company to the OPC:

RT Fuel
Quantity Amount
Company
(Cubic Meter) (IQD)
MdR 173,196 30,309,350,925
Total 173,196 30,309,350,925
Source: This information was reported by the MdR

The following table presents the quantities and values of Kerosene supplied by the Refineries to
the OPDC:

Kerosene

Quantity Amount
Company
(Cubic Meter) (IQD)
NR 224,795 13,485,900,000
SR 446,133 60,227,955
MdR 363,711 45,463,823,125
Total 1,034,639 59,009,951,080
Source: This information was reported by the respective refineries

The following table presents the quantities and values of Kerosene supplied by the Midland
Refineries Company to the OPC:

Kerosene

Quantity Amount
Company
(Cubic Meter) (IQD)
MdR 195,984 24,497,947,125
Total 195,984 24,497,947,125
Source: This information was reported by the MdR

The following table presents the quantities and values of super gasoline supplied by the
Refineries to the OPDC:

Super Gasoline

Quantity Amount
Company
(Cubic Meter) (IQD)
NR - -
SR 1,705,584 272,893,440
MdR 505,846 96,110,713,210
Total 2,211,430 96,383,606,650
Source: This information was reported by the respective refineries

82
The following table presents the quantities and values of super gasoline supplied by the Midland
Refineries Company to the OPC:

Super Gasoline
Quantity Amount
Company
(Cubic Meter) (IQD)
MdR 559,568 106,317,830,320
Total 559,568 106,317,830,320
Source: This information was reported by the MdR

The following table presents the quantities and values of High-octane Kerosene supplied by the
South Refineries Company to the OPDC:

High-Octane Kerosene

Quantity Amount
Company
(Cubic Meter) (IQD)
SR 1,231,029 196,964,640
Total 1,231,029 196,964,640
Source: This information was reported by the SR

The following table presents the quantities and values of gas oil supplied by the Refineries to
the OPDC:

Gas Oil

Quantity Amount
Company
(Cubic Meter) (IQD)
NR 228,798 132,727,820,000
SR 1,828,597 246,860,595
MdR 992,237 124,029,595,500
Total 3,049,632 257,004,276,095
Source: This information was reported by the respective refineries

The following table presents the quantities and values of gas oil supplied by the Midland
Refineries Company to the OPC:

Gas Oil

Quantity Amount
Company
(Cubic Meter) (IQD)
MdR 481,272 60,158,995,250
Total 481,272 60,158,995,250
Source: This information was reported by the MdR

83
The following table presents the quantities and values of diesel oil supplied by the Midland
Refineries Company to the OPDC:

Diesel Oil

Quantity Amount
Company
(Cubic Meter) (IQD)
MdR 150,955 8,000,629,734
Total 150,955 8,000,629,734
Source: This information was reported by the MdR

The following table presents the quantities and values of fuel oil supplied by the Refineries to
the OPDC:

Fuel Oil
Quantity Amount
Company
(Cubic Meter) (IQD)
NR - -
SR 1,498,512 89,910,720

MdR 3,907,095 234,425,721,420

Total 5,405,607 234,515,632,140
Source: This information was reported by the respective refineries

The following table presents the quantities and values of fuel oil supplied by the Midland
Refineries Company to the OPC:

Fuel Oil
Quantity Amount
Company
(Cubic Meter) (IQD)
MdR 551,508 43,590,014,046
Total 551,508 43,590,014,046
Source: This information was reported by the MdR

The following table presents the quantities and values of LPG supplied by the Refineries to the
Gas Filling Company:

LPG
Quantity Amount
Company
(Ton) (IQD)
SR 52,216 -*
MdR 61,842 4,328,910,390
Total 114,058 4,328,910,390
Source: This information was reported by the MdR and SR

 Value of LPG supplied was not reported by South Refineries

84
3.2. Mining and Minerals Sector in fedral Iraq

3.2.1. Mining deposits in Iraq

The following table presents a summary of Iraq’s main minerals, which was prepared in
accordance with a study prepared by Geosurv-Iraq:

Geographical Recorded
Mineral Deposit Formation Uses
Location(s) Reserve
Nineveh and About 600 m.t
Fatha Formation Phosphatic fertilizers
Free Sulfur Salah Al Deen 60% is
(Middle Miocene) and chemical industries
Governorates extractable

Akashat
Formation
Phosphates 21% -
(Paleocene), Anbar More than Phosphatic fertilizers
22% P2O5 (can be
Ratka Formation Governorate 10000 m.t industry
increased to 30%)
(Eocene), and
Digma Formation

Dhiban and Al-

Fatha (Middle
Nineveh and
Sodium chloride Miocene) Nourishments, textile
Muthanna About 50 m.t
(Salt) formations and and textile industries
Governorates
quaternary
deposits
The production of
Sodium Sulfate Alshari Salah Al Deen
22 m.t detergents, paper and
(Glaubente ore) Formation Governorate
other industries

Rataka & Damam

Formations
Nineveh, Anbar, The industry of cement,
(Eocene),
Muthanna, Al- lime, glass, ceramics,
Limestone AL-Furat (Early About 8000 m.t
Najaf and iron, steel &
Miocene), and
Kurdistan Region construction
AL-Fatha (Middle
Miocene)

Al-Mulsa & Zoro

Hauran
(Triassic),
Hussainiat & Production of
Amij (Jurassic), Anbar and magnesia, magnetite
More than 330
Dolomite Um Rudma Muthanna brick, glass industry,
m.t
(Paleocene), Governorates ceramics, iron, steel &
Damam construction
(Eocene), and
Euphrates
(Miocene)

85
 Geographical Recorded
Mineral Deposit Formation Uses
Location(s) Reserve

Nineveh, Kirkuk,
Plaster industry for
Al-Fatha (Middle Salah Al Deen &
Gypsum About 130 m.t decoration & cement
Miocene) Anbar
industry
Governorates
Ga’ara
(Permian),
Hussainiat Anbar Glass and standard
Silica Sand 75 m.t
(Jurassic), Nahr Governorate sand
Umar & Rutba
formations
Nahr Umar &
Anbar Silicon industries & acid
Quartzite Rutba About 16 m.t
Governorate lining of furnaces
formations
Dibdibba Al-Najaf Al-
Feldspar bearing About 2.3 m.t Ceramic industries &
formation Ashraf
sand (Expandable) filters
(Pliocene) Governorate
Hussainiat
Anbar About 30,000
Standard Sand Formation Construction & filters
Governorate tons
(Jurassic)
Ga’ara (Permo- Jewelry manufacture
carboniferous) rutile/ source for
Heavy Minerals Anbar
and Amij - titanium zircon / source
Sand Governorate
(Jurassic) for zirconium monazite
formations / source for thorium
Al-Najaf Al
Dibdibba Ashraf, Karbala,
About 2200
Sand and Gravel (Pliocene) Salah Al Deen, Construction
million m3
formations Kirkuk and Al-
Basra
About 285
Al-Fatha (Middle Governorates million m3 for
Miocene) and located in the brick industry
Brick & Cement
Recent clays Injana (Late Mesopotamian About 450 industries
Miocene) and Anbar million m3 for
formations Governorate cement
industry
Ga’ara
(Permian), Cement, Refractories,
Anbar
Kaolin clays Hussainiat and About 1200 m.t white cement and
Governorate
Amij (Jurassic) historical bricks
formations

Karst deposits Western desert

White cement and
Flint clay north of Al- Anbar About 10 m.t
refractories
Hussainiat Governorate
Digma (late
cretaceous) and
Bentonite / Western desert
Akashat About 22 m.t Drilling muds for oil
Montmorillonite Anbar
(Pliocene) (expandable) wells & concrete pillars
clay Governorate
formations

86
 Geographical Recorded
Mineral Deposit Formation Uses
Location(s) Reserve
Digma (late
cretaceous),
Akashat Western desert Salty drilling muds,
Attapulgite clays (Pliocene) and Anbar 0.5 m.t color bleaching for wax
Injana (Late Governorate & vegetable oils
Miocene)
formations
Injana (Late
Al-Najaf Al-
Celestite Miocene) and
Ashraf and 0.8 m.t )not Raw materials for sugar
(Strontium Dibdibba
Karbala invested) extraction
Sulphate) (Paleocene)
Governorates
formations

Digma (Late
Porcellanite Vegetable oils
Cretaceous) and Western desert
Siliceous rocks of 1.8 m.t purification,
Akashat Anbar
low density less (expandable) nourishments, sulfur &
(Pliocene) Governorate
than 1 gm/cm3 light concrete
formations

Karst deposits
reserved in
carbonate rocks
belongs to Anbar Refractory industry and
Bauxite About 1 m.t
Jurassic period Governorate aluminum production
north of Al
Hussainiat
formations
Ga’ara (Permian)
and Al- Western desert
Sedimentary Iron Hussainiat Anbar - -
(Jurassic) Governorate
formations
Source: Data presented was based on information presented by Geosurv-Iraq

87
 3.2.2. Exploration activities in 2016

In early 2013, the mineral extraction division separated from Geosurv-Iraq, and became part of
the Mining Industries Company. The mineral extraction division is specialized in the extraction
and marketing of mineral raw materials and semi-finished products, which are used as raw
materials in many Iraqi industries in the public and private sectors.

Due to the insurgency of ISIS from mid- 2014, the majority of the company’s extractive sites
were subject to destruction, specifically site infrastructure and production lines. The security
situation in Iraq, therefore, led to a halt in exploration, production and sales.

As a result, the main activities during 2016 were focused on the following:
o Setting plans to assess the current situation, which involved determining the
percentage of damage to production sites
o Conducting economic and technical feasibility studies in relation to all mining
products
o Preparing investment portfolios (through third-party manufacturing contracts
or joint production contracts) for the purpose of resuming operations and
rehabilitating production lines that have been damaged by the war on ISIS.

3.2.3. Minerals Production during the year 2016

As described earlier in this report, there are nine state companies operating in the mining
sector, under the Ministry of Industry and Minerals. The following table provides the operational
status of each company during the year 2016:

Company Status
Operational during 2016. The company is involved in both extractive and
Mining Industries Company
transformational activities.
The State Company of Fertilizers – Operational during 2016. The company is only involved in
Southern Region78 transformational activities (no extraction activities).
Operational during 2016. The company is only involved in
Sate Company for Petrochemical
transformational activities (no extraction activities), as reported by the
Industries
company.
Operational during 2016. The company is only involved in
State Company for Iron & Steel transformational activities (no extraction activities), as reported by the
company.
Operational during 2016. The company is only involved in
Iraq Sate Cement Company78
transformational activities (no extraction activities).
The State Company of Fertilizers–
Not operational during 2016
Northern Region
Phosphate Company Not operational during 2016

Mishraq Sulphur Company Not operational since 2003

78
According to the MoIM, these two companies are not involved in extraction activities. The Iraqi State Cement Company is essentially a
transformational company, but also carries out extractive activities that are important for conducting transformational activities. The ISC also
contracts with private companies, to perform quarrying activities on its behalf.

88
 Company Status

Iraqi Geological Survey and Mining

This SOE does not carry out any production activities.
Company (Geosurv-Iraq)

Production and sales volumes in relation to the state companies operating in the mining sector
were reported through the Ministry of Industry and Minerals, whereby the reporting templates
completed by the state companies were sent to the MoIM. The production and sales figures
presented below are related to the State Company for Mining Industries, which was the only
operational sate-owned entity involved in extractive activities on behalf of the government
during 2016.

Production Sales quantities

Mineral Uses
quantities (Tons) (Tons)
Industrial salt 21,232 8,728.25 Industrial uses (petrochemical -
Ore salt 9,721.10 31,805.64 petroleum - food – chemical)
Silica sand for black
- - Black cement manufacturing
cement
Silica sand (non-
- - Glass and ceramics manufacturing
granulated)
Silica sand for Sand casting for engineering and
- -
foundry mechanical molds
Bentonite product - - Industrial uses (petroleum - civil
Raw bentonite - - and construction work)

Standard sand 8.68 8.135 Cement strength testing

Filter sand 190 190 Drinking water treatment
Total 31,151.78 40,732.03
Source: This information was presented by the MoIM on behalf of the State Company for Mining Industries

3.2.4. Targeted production capacities

The table below presents the State Company for Mining Industries’ planned production
capacities up to year 2019:

Mineral Production Quantity (Ton / Year)

Ore salt 36,000
Industrial salt 30,000
Sedimentary iron 6,000
Red Kaolin clay 60,000
Silica sand for glass and ceramics 1,200
Silica sand for white cement 1,200
Silica sand for black cement 3,000
Silica sand for plumbing 1,800
Standard sand 60
Calcium bentonite 3,600
Bentonite ore 6,000
Total 148,860

89
 3.3. KRG Oil, Gas and Mineral Production

3.3.1. KRG crude oil production for year 2016

Despite the numerous efforts exerted by the IEITI and the IA to secure KRG’s participation in the
IEIT reporting for year 2016, there was no response from the KRG and the international
companies working in the region to the data requests made. Accordingly, all related data
presented in this report in relation to KRG has been obtained from publicly available sources.

The Kurdistan Region Ministry of Natural Resources estimates the reserves at 45 billion barrels
of oil and between 100 - 200 trillion cubic feet of gas79.

The MNR published on its website a production report, showing daily gross field production
figures during the period from January 2015 to September 2016. According to the report, the
producing oil fields during that period are Tawke, Taq Taq, Shaikan, Khurmala Dome80, Bai
Hassan80, Avana Dome80, Sarsang, Sarqala, Hawler, Akri Bijel, and Khalakan. In addition to the
filed production report, the MNR published on its website, monthly export data for the period
from January 2016 to October 2016. These two reports were relied on for the purpose of
reporting KRG production and export figures.

Since the production report presented production data up to September 2016 only, we relied
on the production data included in the monthly export report for the month of October 2016:

Daily Gross Production Month Total

2016
(bpd) (barrels)

January 578,703 17,939,793

February 358,262 10,389,598
March 457,430 14,180,330
April 582,131 17,463,930
May 586,488 18,181,128
June 571,229 17,136,870
July 572,771 17,755,901
August 479,046 14,850,426
September 562,879 16,886,370
October 614,071 19,036,203
Total 5,313,622 163,820,549

79
http://mnr.krg.org/index.php/en/oil/vision
http://cabinet.gov.krd/a/print.aspx?l=12&smap=010000&a=39078

80
These fields are operated by North Oil Company but have been under the control of KRG (Khurmala Dome and Bai Hassan since 2009, Avana
Dome since 11 July 2014)

90
The following table presents a breakdown of the daily gross production by field. However, a
breakdown for the month of October 2016 is not presented, as it was not included in the field
production report published by the MNR (as discussed above):

Daily Gross Field Production

Khurmala/Bai
Tawke Taq Taq Shaikan Sarsang Sarqala Hawler Khalakan
2016 Hassan/Avana
(bpd) (bpd) (bpd) (bpd) (bpd) (bpd) (bpd)
(bpd)

January 121,829 81,244 36,065 336,026 1,987 842 710 -

February 74,134 62,176 22,084 197,895 1,883 - 90 -
March 79,703 75,326 21,703 275,090 2,525 1,234 1,849 -
April 119,038 67,405 40,839 344,596 350 3,693 3,417 2,793
May 117,773 63,697 40,096 347,040 4,777 5,452 3,158 4,495
June 114,319 62,979 38,108 340,674 2,616 5,487 2,856 4,190
July 118,025 61,788 38,763 338,515 3,079 5,003 3,054 4,544
August 96,764 57,668 39,077 267,589 6,420 5,538 2,679 3,311
September 112,720 56,076 27,302 347,821 7,941 5,452 2,902 2,665
Total 954,305 588,359 304,037 2,795,246 31,578 32,701 20,715 21,998

The following monthly production figures were calculated by multiplying the daily gross field
production quantities (listed in the above table) by the number of days corresponding to each
month:

Monthly Production

Khurmala/Bai
Tawke Taq Taq Shaikan Sarsang Sarqala Hawler Khalakan
2016 Hassan/Avana
(barrels) (barrels) (barrels) (barrels) (barrels) (barrels) (barrels)
(barrels)

January 3,776,699 2,518,564 1,118,015 10,416,806 61,597 26,102 22,010 -

February 2,149,886 1,803,104 640,436 5,738,955 54,607 - 2,610 -
March 2,470,793 2,335,106 672,793 8,527,790 78,275 38,254 57,319 -
April 3,571,140 2,022,150 1,225,170 10,337,880 10,500 110,790 102,510 83,790
May 3,650,963 1,974,607 1,242,976 10,758,240 148,087 169,012 97,898 139,345
June 3,429,570 1,889,370 1,143,240 10,220,220 78,480 164,610 85,680 125,700
July 3,658,775 1,915,428 1,201,653 10,493,965 95,449 155,093 94,674 140,864
August 2,999,684 1,787,708 1,211,387 8,295,259 199,020 171,678 83,049 102,641
September 3,381,600 1,682,280 819,060 10,434,630 238,230 163,560 87,060 79,950
Total 29,089,110 17,928,317 9,274,730 85,223,745 964,245 999,099 632,810 672,290

91
 3.3.2. KRG natural gas production for year 2016

The MNR gross field production report for the period from January 2015 to September 2016
does not include any figures for gas production quantities. In addition, the monthly export
reports only contained information of produced gas quantities (supplied to electricity generation
plants) for the months of June, July and August 2016 as presented in the table below:

Net Gas Production

Daily Average Month Total

Month
(mmscfd) (mmscfd)

June 311.9 9,356

July 306.6 9,504
August 311.6 9,661
Total 930.1 28,521

3.3.3. KRG Mineral production for year 2016

We were unable to identify any public information about mineral production in the Kurdistan
Region during the year 2016.

92
3.4. Extractive Industries Export data (Requirement 3.3)

3.4.1. Crude oil exports process

SOMO is the sole and official exporter of Iraqi’s crude oil, established in accordance with Public
Companies Law No. 22 of 1997. It aims to contribute to the support of the national economy
through marketing of crude oil and natural gas outside Iraq in addition to the marketing of crude
oil inside Iraq.

The following section has been prepared in accordance with the information presented by
SOMO, in relation to its adopted set of standards and mechanisms as follows:

1. Criteria for the allocation of the quantity of crude oil available for export to companies:

The main eligibility criterion used by SOMO for contracting with qualified companies to purchase
Iraq’s crude oil is summarized as follows:

 Large international oil companies, vertically-integrated medium sized oil companies

(government owned or independent), and top-rated international petroleum
companies capable of refining and have extensive distribution networks in various
countries
 Companies specialized in the production and distribution of refined petroleum
products
 National oil companies and/or entities, authorized by their respective governments
to enter into contracts for the benefit of their national refineries (e.g. China and
Japan)

2. The basis for determining the allocation of quantities of crude oil available for export to
qualifying companies:

SOMO bases its allocation of the quantity of crude oil, which is designated for sale to a qualifying
company, on a set of similar principles applicable to all buyers defined as follows:

 All quantities of crude oil designated for export (after allocation of crude oil
quantities needed for domestic use by refineries and power plants) are sold in global
markets according to global price formulas in order to achieve maximum return on
Iraq’s resources
 Priority, in terms of allocation, is given to qualified companies that have large
refining capacities, as these companies are able to withstand sudden price
fluctuations and, at the same time, maintain the demand for Iraqi crude oil over the
long-term
 This policy intends to ensure even distribution of Iraqi oil throughout the major global
markets (American, European and Asian markets) under a sound and an adjustable
allocation system. This enables exports to increase in a manner that meets world
demand

93
3. Contracting mechanism

SOMO’s contracts with qualified companies are semi-annual, annual or long-term contracts and
are designed to operate according to the following process:

 SOMO directly invites all oil companies who meet the criteria set out in Section 2
(those who have valid contracts or were recently identified through the selection
process) to submit their projected quantity needs of Iraqi oil
 SOMO only reviews the companies’ projected quantity needs that are provided via
the official communication of the respective company. SOMO does not deal with
requests through brokers, agents, international organizations, or diplomatic
missions operating in Iraq or abroad. Final quantity allocation to qualifying
companies is made in accordance with oil selling criteria described above
 SOMO also receives a number of requests (via e-mail) from companies, brokers,
agents and international organizations (other than those previously identified and
directly invited) indicating their interest in buying Iraqi crude oil. The following
procedures are performed by a technical committee (formed by an administrative
order) comprised of specialists from SOMO:
o Study the activities of the companies or the institutions that have made oil
purchase requests in order to establish whether they comply with the
principles and criteria applicable to the contracts with regard to the purchase
of Iraqi crude oil
o Companies and institutions that are excluded on this basis are notified of the
reason of their exclusion and are placed on the list of companies that are not
eligible. Eligible companies and institutions are listed on the allocation tables
under the new companies caption
o These tables are presented to SOMO’s Board of Directors and to the
Ministerial Committee which reviews and approves the Technical
Committee’s decisions
 After obtaining the Minister of Oil’s approval on the allocated quantities, eligible
companies and institutions are notified of the allocated quantities. Upon approval of
SOMO’s contractual terms, contracts are finalized and qualified companies and
institutions are added to the list of qualified buyers of Iraqi crude oil.

4. Contract implementation:

 The execution of the contract begins when the Shipping & Quantities Division and the
Financial Commercial Division of SOMO are provided with the contract execution
details
 SOMO sets the date on which the shipments should be loaded and requests the
purchasing company to inform the carrier to make all necessary arrangements in
order to load the shipment in a timely manner. The purchasing company officially
informs SOMO of the nominated carrier. In turn, SOMO would need to approve the
carrier depending on the carrier’s technical specifications and the specifications of
the loading port

94
  The purchasing company issues an irrevocable letter of credit through a recognized
bank to the benefit of the Central Bank of Iraq, prior to approving the carrier and not
less than seven days of that date. The letter of credit should be issued for not less
than the estimated amount of the shipment. SOMO then instructs the loading port to
load the vessels, with an emphasis on the fact that the destination of the shipment
may not be amended once the letter of credit is issued
 After completion of loading, the port issues a bill of lading which includes the
quantity loaded, the degree of density (API Gravity), date, and the final destination
of shipment in addition to other related documents
 Afterwards, SOMO calculates the barrel’s final price in accordance with the terms of
the contract and informs the purchasing company in order for the company to settle
the value of the shipment within 30 days from the bill of lading date
 Crude oil is not sold on the basis of a fixed price or a discount or a specific premium.
It is sold using a standard pricing mechanism for each market, globally known as the
official selling price

Source: Oil Marketing Company (SOMO)

5. SOMO Pricing mechanisms:

SOMO uses the Official Selling Price (OSP) for crude oil export sales to enhance the
transparency when dealing with its buyers, and to avoid price negotiations with buyers
through the consolidation of crude oil prices for all buyers in each market.

General crude oil price formula: OSP + (-) D + (-) API + (-) F

OSP: The average reference oil price (according to international price lists, as per
shipment destination)

D: refers to the price differences that are calculated on a monthly basis

API: refers to price difference for density fluctuations (API Gravity) between contract
specifications and the actual shipment

F: represents the Freight rate (according to international daily bulletins)

95
 3.4.2. Extracted quantities of crude oil for export by SOMO

The following table presents the extracted for export crude oil quantities (barrels)
reconciliation between Ministry of Oil, Basra Oil Company and SOMO for year 2016:

Extracted for Extracted for

Extracted for export
export crude oil export crude oil
crude oil quantities Differences*
Month quantities quantities
reported by MoO (Barrel)
reported by reported by BOC
(Barrel)
SOMO (Barrel) (Barrel)
January 101,839,744 88,588,631 101,839,744 (13,251,113)
February 93,536,524 80,920,505 93,536,524 (12,616,019)
March 101,865,415 87,464,565 101,865,415 (14,400,850)
April 100,916,053 87,547,332 100,916,053 (13,368,721)
May 99,205,367 86,068,494 99,205,367 (13,136,873)
June 95,260,683 82,907,739 95,260,683 (12,352,944)
July 99,266,184 86,666,440 99,266,184 (12,599,744)
August 100,130,104 87,690,605 100,130,104 (12,439,499)
September 97,349,969 85,381,878 97,349,969 (11,968,091)
October 102,620,595 89,724,398 102,620,595 (12,896,197)
November 102,199,824 89,022,478 102,199,824 (13,177,346)
December 106,955,342 93,407,908 106,955,342 (13,547,434)
Total 1,201,145,804 1,045,390,973 1,201,145,804 (155,754,831)
Source: data presented in the table was reported by SOMO, MoO and BOC

*No difference were noted between the quantities reported by the MoO and BOC.
Differences were noted between the quantities reported by MoO and SOMO from one part
and the quantities reported by BOC. SOMO reported the quantities related to BOC only while
MoO and BOC reported quantities that included the quantities supplied from MdOC
amounting to 32,226,211 barrels, and quantities supplied from MOC amounting to
123,528,620 barrels.

96
The following table presents the extracted for export crude oil quantities (barrels)
reconciliation between Ministry of Oil, Missan Oil Company and SOMO for year 2016:

Extracted for Extracted for

Extracted for export
export crude oil export crude oil
crude oil quantities Differences
Month quantities quantities
reported by MoO (Barrel)
reported by SOMO reported by MOC
(Barrel)
(Barrel) (Barrel)
January 10,105,935 10,105,935 10,105,935 -
February 9,664,466 9,664,466 9,664,466 -
March 10,745,097 10,745,097 10,745,097 -
April 10,129,508 10,129,508 10,129,508 -
May 10,493,895 10,493,895 10,493,895 -
June 9,840,380 9,840,380 9,840,380 -
July 10,257,744 10,257,744 10,257,744 -
August 10,232,480 10,232,480 10,232,480 -
September 9,854,054 9,854,054 9,854,054 -
October 10,478,982 10,478,982 10,478,982 -
November 10,539,437 10,539,437 10,539,437 -
December 11,186,642 11,186,642 11,186,642 -
Total 123,528,620 123,528,620 123,528,620 -
Source: data presented in the table was reported by SOMO, MoO and MOC

The following table presents the extracted for export crude oil quantities (barrels)
reconciliation between Ministry of Oil, Midland Oil Company and SOMO for year 2016:

Extracted for Extracted for

Extracted for export
export crude oil export crude oil
crude oil quantities Differences
Month quantities reported quantities
reported by MoO (Barrel)
by SOMO reported by
(Barrel)
(Barrel) MdOC (Barrel)
January 3,145,178 3,145,178 3,145,178 -
February 2,951,553 2,951,553 2,951,553 -
March 3,655,753 3,655,753 3,655,753 -
April 3,239,213 3,239,213 3,239,213 -
May 2,642,978 2,642,978 2,642,978 -
June 2,512,564 2,512,564 2,512,564 -
July 2,342,000 2,342,000 2,342,000 -
August 2,207,019 2,207,019 2,207,019 -
September 2,114,037 2,114,037 2,114,037 -
October 2,417,215 2,417,215 2,417,215 -
November 2,637,898 2,637,898 2,637,898 -
December 2,360,803 2,360,803 2,360,803 -
Total 32,226,211 32,226,211 32,226,211 -
Source: data presented in the table was reported by SOMO, MoO and MdOC

97
The following table presents the extracted for export crude oil quantities (barrels)
reconciliation between Ministry of Oil, North Oil Company and SOMO for year 2016:

Extracted for Extracted for Extracted for

export crude oil export crude oil export crude oil
Differences
Month quantities quantities reported quantities
(Barrel)
reported by MoO by SOMO reported by NOC
(Barrel) (Barrel) (Barrel)
January - - - -
February - - - -
March - - - -
April - - - -
May - - - -
June - - - -
July - - - -
August - - - -
September 935,270 935,270 935,270 -
October 2,294,327 2,294,327 2,294,327 -
November 1,915,987 1,915,987 1,915,987 -
December 2,151,841 2,151,841 2,151,841 -
Total 7,297,425 7,297,425 7,297,425 -
Source: data presented in the table was reported by SOMO, MoO and NOC

98
 3.4.3. Crude oil exports during 2016

The following table presents export volumes and values reported by SOMO disaggregated
by buyer, during the calendar year 2016.

Amount Quantities
No. Buyer
(USD) (barrel)
1 Al Waha Petroleum 949,382,831 28,542,846
2 API 255,665,418 6,975,044
3 BHARAT OMAN 197,797,902 5,425,724
4 BHARAT PETROLEUM 24,514,909 698,938
BP & PETROCHINA
5 2,902,043,591 78,305,500
INTERNATIONAL
6 BP OIL 725,572,194 22,042,265
7 CANAL 549,574,243 14,875,317
8 CEPSA 371,754,858 10,316,436
CHENNAI PETROLEUM
9 617,897,175 17,277,492
CORPORATION LTD
10 CHEVRON 978,911,116 28,245,146
11 CHINA INTERNATIONAL 4,096,691,420 109,199,283
12 CHINA NATIONAL 1,494,359,889 43,072,272
13 CHINA OFFSHORE OIL 371,611,409 9,800,688
14 CNOOC IRAQ LIMITED & TP 365,213,165 10,994,398
16 ENI IRAQ B.V. 846,432,255 23,080,447
ENI SOC (Partnership
17 194,429,481 4,996,189
contracts)
18 ENI TRADING 341,003,530 9,558,420
19 ESSAR OIL 38,178,999 1,045,914
20 EXXON MOBIL IRAQ LIMITED 318,330,411 8,823,760
EXXON MOBIL SALES AND
21 SUPPLY CORPORTION 395,799,826 11,223,730
GALLOWS
22 GAZPROM NEFT BADRA B.V. 141,000,083 3,792,869
GS CALTEX (Project of Karbala
23 344,651,360 8,995,274
Refinery)
GS CALTEX SINGAPORE PTE.
24 1,344,523,262 37,126,436
LTD.
25 GUNVOR 146,095,477 4,072,509
26 HELLENIC 36,058,142 1,006,564
HINDUSTAN PETROLEUM
27 758,312,457 20,645,195
CORPORATION LIMITED
28 HPCL-MITTAL 707,817,720 19,258,535
29 INDIAN 3,418,806,784 90,334,372
30 IPLOM 116,170,810 3,127,109
31 JAPEX 283,819,236 8,947,673
32 JX NIPPON OIL 518,383,616 14,058,456
33 KOCH SUPPLY & TRADING 220,119,109 6,181,507
34 KOGAS BADRA B.V. 132,147,008 3,543,010
35 KOGAS ZUBAIR 499,255,063 13,483,424

99
 Amount Quantities
No. Buyer
(USD) (barrel)
36 KUWAIT ENERGY 22,651,516 523,444
37 LITASCO 336,441,675 8,297,972
38 LUKOIL 2,110,921,802 62,866,412
39 MOTOR OIL 713,296,013 19,624,664
40 NORTH PETROLEUM 618,246,995 17,407,231
OCCIDENTAL ENERGY IRAQ
41 145,388,719 4,023,276
LLC
42 PERTAMINA ( PERSERO ) 212,736,520 4,938,759
43 PETRO DIAMOND 317,239,599 9,783,044
44 PETROBRAS 195,037,592 4,657,625
45 PETROCHINA HALFAYA 580,222,138 17,021,652
46 PETROCHINA WEST QURNA 325,299,060 9,716,278
47 PETROGAL 136,347,160 3,091,008
48 PETRONAS 192,468,568 5,925,925
49 PETRONAS BADRA 68,271,232 1,797,607
50 PETRONAS GARRAF 547,822,225 17,011,732
51 PETRONAS HALFAYA 272,689,953 8,017,234
52 PETRONAS MAJNOON 429,788,526 12,104,085
53 PHILLIPS 66 1,172,198,606 34,322,985
54 PT PERTAMINA IRAK 141,612,379 3,963,702
RELIANCE INDUSTRIES
55 1,160,500,072 35,769,787
LIMITED(RIL)
56 REPSOL 552,932,799 15,534,059
57 SARAS SPA - MILANO 427,490,043 11,258,975
58 SHELL 366,391,683 10,055,797
59 SHELL MAJNOON 741,516,631 20,998,679
60 SHELL WEST QURNA 184,652,178 5,001,378
61 SINOCHEM 3,205,534,045 85,896,885
62 SK ENERGY 463,153,473 12,110,776
63 SOCAR 252,355,472 6,819,920
64 TOTSA TOTAL 731,211,184 21,334,258
TOTSA TOTAL HALFAYA
65 271,939,979 8,009,380
CONTRACT
66 TOYOTA 610,789,754 17,959,264
67 TP BADRA LTD. 28,804,419 838,322
68 TP MISSAN 53,520,479 1,353,840
69 TUPRAS 179,522,511 4,153,896
VALERO MARKETING &SUPPLY
70 890,384,979 24,108,657
COMPANY
71 VITOL 88,902,511 3,071,979
Sub total 43,450,607,236 1,208,443,229

100
 3.4.4. Exported crude oil quantities per region

The following table depicts the monthly export quantities and monthly average price of
exported crude oil for the year 2016 with regard to the American, European and Asian
Markets, exported through Basrah Port by SOMO for year 2016:

Basrah Port (Barrel) Monthly Average Price (USD)

Month Far
USA Europe Far East USA Europe
East
January 9,414,295 25,119,806 67,305,643 24.87 21.71 21.81
February 11,805,030 19,279,158 62,452,336 23.25 27.41 22.50
March 17,343,871 18,710,464 65,811,080 24.81 29.77 28.45
April 13,524,946 20,430,593 66,960,514 29.56 36.54 32.77
May 10,723,034 21,864,931 66,617,402 34.99 39.95 37.26
June 15,938,849 26,393,148 52,928,686 39.09 38.23 41.14
July 17,340,936 35,927,480 45,493,144 38.56 35.13 40.32
August 16,890,890 14,207,231 69,031,983 37.00 39.27 39.34
September 15,931,876 12,190,820 69,227,273 38.17 41.35 38.57
October 20,025,784 19,487,712 63,107,099 42.07 39.13 42.69
November 20,901,545 27,201,529 54,407,054 38.32 42.02 40.66
December 23,432,056 27,067,603 56,455,683 43.42 47.30 46.31
Total 193,273,112 267,880,475 739,797,897
Source: data presented in the table was reported by SOMO

The following table depicts the monthly export quantities and monthly average price of
exported crude oil for the year 2016 with regard to the American, European and Asian
Markets, exported through Ceyhan Port by SOMO for year 2016:

Ceyhan Port (Barrel) Monthly Average Price (USD)

Month Far Far
USA Europe East Jordan USA Europe East Jordan
January - - - - - - - -
February - - - - - - - -
March - - - - - - - -
April - - - - - - - -
May - - - - - - - -
June - - - - - - - -
July - 504,624 - - - 36.59 - -
August - - - - - - - -
September - 935,270 - - - 41.51 - -
October - 2,294,327 - - - 42.44 - -
November - 1,605,683 - - - 38.98 - -
December - 2,151,841 - - - 47.51 - -
Total - 7,491,745 - -
Source: data presented in the table was reported by SOMO

101
 3.4.5. Exported petroleum products - Naptha

Naptha is a refined oil product (such as kerosene) produced by the state owned refineries in
Iraq, and exported by SOMO. The OPDC collects the quantities of Naphtha produced by the
refineries and supplies the quantities to SOMO. SOMO then announces the quantities to be
exported and the selling price in US dollars.

The following table depicts the quantities and value of Naptha exported through SOMO
during the calendar year 2016:

Value
Date Port Ton Liter List Price
(USD)
Midland
31/1/2016 14,385.55 20,777,000 202.664 2,915,433.11
Refineries
Midland
29/2/2016 14,677.05 21,246,000 184.452 2,707,211.23
Refineries
Midland
31/3/2016 25,920.90 37,475,500 231.727 6,006,572.39
Refineries
Midland
30/4/2016 25,707.60 37,661,000 261.018 6,710,146.34
Refineries
Midland
31/5/2016 27,859.52 40,727,000 278.703 7,764,532.36
Refineries
Midland
30/6/2016 7,305.58 10,646,000 291.676 2,130,862.35
Refineries
Dora Najaf
31/7/2016 17,853.91 26,024,500 256.876 4,586,240.99
Samaoura
Midland
31/7/2016 11,081.67 16,040,000 256.876 2,846,615.06
Refineries
Dora Najaf
31/8/2016 31,657.37 45,846,000 242.628 7,680,964.37
Samaoura
Dora Najaf
30/9/2016 25,236.56 36,613,000 267.105 6,740,811.36
Samaoura
31/10/2016 Al-Daura 1,490.61 2,139,500 360.289 537,050.39
31/10/2016 Al-Najaf 1,741.68 2,556,000 366.589 638,480.73
31/10/2016 Al-Samawah 2,815.78 4,152,500 371.089 1,044,905.73
31/10/2016 Diwaniya 1,980.00 2,904,000 368.389 729,410.22
30/11/2016 Al-Najaf 1,573.06 2,300,000 355.946 559,924.41
30/11/2016 Al-Samawah 1,676.73 2,444,500 360.446 604,370.62
30/11/2016 Diwaniya 3,876.02 5,876.02 357.746 1,386,630.65
30/12/2016 Al-Daura 1,222.27 1,659,500 393.358 480,789.68
30/12/2016 Al-Najaf 369.94 538,000 399.658 147,849.48
30/12/2016 Al-Samawah 1,620.69 2,356,000 404.158 655,014.83
31/12/2016 Diwaniya 1,361.08 1,963,000 401.458 546,416.45
Midland
30/12/2016 5,087.66 7,213,500 383.658 1,951,921.46
Refineries
Midland
30/12/2016 3,936.01 5,601,000 383.658 1,510,081.72
Refineries
Total 230,437.24 328,889,376.02 60,882,235.93
Source: data presented in the table was reported by SOMO

102
 3.4.6. Exported petroleum products - LPG and Condensate

The following table presents the volumes and values of Condensate produced by BGC, and
exported by SOMO during the year 2016:

Condensate
Quantity Price Value
B/L Date
(Ton) (USD) (USD)
20/03/2016 6,718.00 286.28 1,923,235.76
30/03/2016 6,835.28 299.27 2,045,567.20
23/05/2016 14,240.01 349.82 4,981,438.90
04/06/2016 14,122.28 355.66 5,022,717.41
22/07/2016 15,917.23 331.67 5,279,316.42
31/07/2016 15,770.55 303.55 4,787,102.84
20/08/2016 14,348.51 346.50 4,971,742.63
22/09/2016 15,753.37 358.02 5,639,942.76
30/09/2016 15,822.26 364.99 5,774,996.50
24/10/2016 14,778.27 406.17 6,002,458.74
12/11/2016 13,285.41 375.18 4,984,420.87
22/11/2016 13,491.76 392.84 5,300,115.31
23/12/2016 14,814.09 433.15 6,416,722.65
Total 175,897,007 63,129,777.990
Source: This information was reported by SOMO

103
The following table presents the volumes and values of LPG produced by BGC, and exported
by SOMO during the year 2016:

LPG
Quantity Price Value
B/L Date
(Ton) (USD) (USD)
6/7/2016 1,160.80 209.55 243,242.90
22/07/2016 1,602.48 210.57 337,439.44
29/07/2016 1,569.68 176.62 277,237.57
3/8/2016 1,579.53 194.31 306,919.87
5/8/2016 1,548.31 194.49 301,133.13
9/8/2016 1,474.27 161.40 237,946.35
18/08/2016 1,534.07 161.87 248,319.75
20/08/2016 1,601.10 162.15 259,625.42
31/08/2016 1,523.84 161.99 246,844.67
31/08/2016 1,582.46 162.43 257,039.91
14/09/2016 1,574.10 181.46 285,632.13
14/09/2016 1,549.50 180.25 279,294.82
24/09/2016 3,125.31 230.71 721,049.88
27/09/2016 1,544.96 179.70 277,612.96
28/09/2016 1,546.94 180.77 279,645.35
8/10/2016 3,075.87 277.79 854,441.74
18/10/2016 2,742.85 284.75 781,016.42
Total 30,336.05 6,194,442.3
Source: This information was reported by SOMO

3.4.7. Mining and Minerals Sector in federal Iraq

Iraq did not export minerals during the year 2016, given that the government’s focus was
first to sell minerals domestically to meet domestic demand before being able to export.

104
3.5. KRG Exports

As discussed in Section 3.3 above, the MNR published on its website, monthly export data
for the period from January 2016 to October 2016. The following table presents the KRG
reported export quantiles for the period from January 2016 to October 2016, which were
exported through the Kurdistan pipeline network to the port of Ceyhan in Turkey. With
regards to the quantities exported during the month of January, the value received (in USD)
was not identified in the report.

Total Exported Value Received

Month
(barrels) (USD)

January 18,656,131 -
February 10,151,944 303,943,433
March 10,148,487 207,272,177
April 15,356,651 376,395,901
May 15,904,271 390,748,957
June 15,427,074 561,953,676
July 14,176,761 461,196,477
August 12,763,566 413,994,993
September 16,944,237 611,764,928
October 16,766,563 636,364,810
Total 146,295,685 3,963,635,352
Source: MNR website (http://mnr.krg.org/index.php/en/oil/monthly-export-production-data)

105
4. Revenue Collection

4.1. Materiality (Requirement 4.1)

The MSG considered a quantitative materiality threshold to determine which payments and
revenue streams would be deemed material for the purpose of this EITI report.

The quantitative threshold applied to define materiality was all revenue streams that are known
to contribute two percent or more of the revenue received by the government from the mining
and oil and gas sectors. Two percent is broadly consistent with materiality thresholds used for
other EITI-compliant countries, and lowering the materiality threshold further would not have
significantly increased coverage of the report. In accordance with Requirement 4.1(a), all
revenues and payments whose "omission or misstatement could significantly affect the
comprehensiveness of the EITI Report” were included in the scope of reconciliation.

4.2. Revenue streams

The following is a description of revenue streams in the oil and gas sector in federal Iraq:
i. Crude oil exports: This revenue represents the federal budget total for crude oil
export revenue, as per the records of SOMO. In addition to the revenue generated
from oil exported to international markets, the total export revenue includes crude
oil sales to international oil companies operating in Iraq under licensing round
contracts, equivalent to the value of cost recovery and remuneration fees earned by
those companies. While these figures are reported as sales revenue by SOMO and
are recorded as such in the federal budget, they are, in fact, expenses for the Iraqi
Government.
ii. Corporate Income tax: Under service contracts, IOCs are required to pay corporate
income tax levied at 35% of remuneration fees received during the relevant tax year.
iii. State partner share in remuneration fees: Under service contracts, where a sate
partner holds a share of the consortium’s/company’s total participating interest in
the oil and gas license, the state partner is entitled to receive a share of the
remuneration fee paid, in accordance with its share of total participating interest in
the field license, which typically ranges from 5% to 25%. The state partner’s share is
paid by the Ministry of Oil to the Ministry of Finance, as remittances to the state
treasury.
iv. Treasury share of SOE reported profits: As stated in Section 2.3.2, all state-owned
entities are required to pay 45% of the distributable portion of their net profits to the
state treasury (MoF), in accordance with Law No. 22 of 1997 (as amended).
v. Signature bonus: Signature bonus amounts are determined in service contracts and
are generally payable within a specified period from the effective contract date.
There was no signature bonus payment during 2016.

106
Crude oil product export revenues are not included as direct revenue streams to the government
as explained below:

i. LPG and condensate: LPG and condensate are produced and exported by Basra Gas
Company, which is a mixed sector company that is 51% owned by the state through
South gas Company (as discussed in Section 2.3). LPG and condensate are exported
through SOMO (since it is the only entity legally authorized to export products in
federal Iraq), in exchange for a commission (insignificant amount as compared to
total extractive revenue). However, all revenues from the export of these petroleum
products are deposited into the account of Basra Gas Company. Since South Gas
Company owns a 51% stake in Basra Gas Company, it receives its share of net profits
in accordance with its ownership shares.
ii. Naptha: Naptha is a refined oil product (such as kerosene) produced by the state
owned refineries in Iraq, and exported by SOMO. The OPDC collects the quantities of
Naphtha produced by the refineries and supplies the quantities to SOMO. SOMO then
announces the quantities to be exported and the selling price in US Dollars.
According to SOMO, the proceeds from the Naptha exports are distributed to the
self-funded national companies to cover costs of production (while SOMO receives a
commission for its services), and the net profit is transferred to the Ministry of
Finance through treasury share payments. Therefore, Naphtha export proceeds do
not represent a direct revenue stream for the Government of Iraq.

The following is a description of revenue streams in the mining and minerals sector in federal
Iraq:
i. Treasury share of SOE reported profits: The only revenue stream received by the
Iraqi Government from the mining and minerals sector is the 45% treasury share
payments made by the SOEs operating in the sector.

The following is a listing of revenue streams in the oil and gas sector in Kurdistan Region of
Iraq:

i. Crude oil exports: Crude oil export quantities and revenues earned by KRG were
obtained by referring to monthly export reports published on the MNR website.
However, data published on the MNR website covered the period from January to
October 2016, so the estimate revenue figure for the full year was obtained by
dividing the revenue declared for 9 months, and then multiplying the figure by 12
months. This was done in order to assess the quantitative materiality threshold of
KRG crude oil export revenues.
ii. Royalties
iii. Bonuses
iv. Capacity Building Payments

A description of the revenue streams relating to KRG is included in Section 2.8.2.2

107
 4.3. Materiality of revenue streams
The revenue streams relevant to the extractives sector in Iraq, are shown in the table below.
The table also displays the percentage contribution of each revenue stream towards the total
extractive revenue in Iraq. Crude oil export revenue in both federal Iraq and the Kurdistan
Region are material revenue streams as their contribution to the total extractive sector revenue
exceeds the quantitative materiality threshold of 2%.

Percentage of total MSG decision

Revenue stream extractive revenue to reconcile -
%81 (Y/N)

Received by /
# Paid by 2016
Reported by
Oil and Gas (Federal Iraq)

1 Crude oil exports Oil buyers SOMO* 87.57 Yes

Corporate income
2 IOCs MoO** 1.07 No
tax
3 Signature bonus IOCs MoF 0.00 No
Treasury share of
4 SOE reported profits 0.65 No
(45%)*
South Refineries
4a South Refineries Company MoF 0.14
Company

4b SOMO SOMO MoF 0.05

4c North Oil Company North Oil Company MoF 0.03

4d Basra Oil Company South Oil Company MoF 0.18

4e Missan Oil Company Missan Oil Company MoF 0.20

4f Oil Tankers Company Oil Tankers Company MoF 0.00

Midland Refineries Midland Refineries

4g MoF 0.04
Company Company

Oil Exploration
4h Oil Exploration Company MoF 0.01
Company
State partner share
5 from remuneration MoO MoF 0.44 No
fees
Mining and Minerals (Federal Iraq)
Treasury share of
SOE reported profits
(45%) - The State
6 SOEs MoF 0.005 No
Company of
Fertilizers/ Southern
Region
Oil and Gas (KRG)

7 Crude oil exports Oil buyers MNR**** 9.19 Yes

8 Royalties*** IOCs MNR**** 0.23 No

Capacity building
9 payments and IOCs MNR**** 0.19 No
bonuses***
10 Taxes IOCs MNR**** 0.00 No
Note: Footnotes are on the next page

81
The percentage contribution of revenue streams to total extractive revenue, presented in the table, are based on materiality calculations
made by the MSG.

108
* The proceeds of the crude oil export revenue are deposited by oil buyers into the DFI
account, which is managed by the MoF. SOMO is the entity exporting crude oil; as such, it
is the entity recording the revenues and is therefore the reporting entity for the purpose
of this EITI report.
** The practice of the MoO - PCLD in respect of all tax filings up to financial year 2016 was
to retain an amount of 35% from the remuneration fee payment approved in the first
quarter after the end of the financial year. The PCLD would in turn, transfer the withheld
amounts to the GCT. Therefore, the reporting entity for CIT revenues, for the purpose of
this EITI report, is the MoO.
*** These revenue figures were obtained by referring to publicly available reports published by
two of the four largest oil producers operating in KRG (Report on payments to governments) for
the year 2016. Capacity building payments and bonus payments were grouped together as they
were reported together by one of the oil producers in its Report on payments to governments
(Gulf Keystone).
**** According to reports published by international oil producers operating in KRG (Report on
payments to governments), all payments made in relation to KRG licenses are made to the
Ministry of Natural Resources (MNR).

The MSG has agreed that all revenue streams in the mining, oil and gas sectors that account for
less than 2% of total extractives revenues in 2016 are to be excluded from the scope of
reconciliation (as displayed in the table above).

Based on the MSG’s materiality threshold of 2% of total extractives revenues for selecting
material revenue streams for reconciliation, payments and revenues from the mining sector have
not been considered material. The IEITI report, however, discloses contextual information on the
sector throughout this EITI report.

Crude oil export revenue earned by the KRG is a material revenue stream, whereby its
contribution to the total extractive revenue in Iraq exceeds the qualitative materiality threshold
of 2%. However, despite repeated attempts by the MSG and the IA at trying to attain the KRG’s
participation in the IEITI reporting for the year 2016, no data was reported by the KRG or by the
companies operating under KRG. Consequently, the IEITI represented by the National
Coordinator submitted an adaptive implementation request to the EITI on 27 November 2018,
with respect to coverage of the Iraqi Kurdistan Region in the IEITI 2016 and 2017 reports. The
request was made due to the inability of the Federal Government to compel companies and local
government’s agencies in the region to participate in EITI process.

109
 4.4. Reporting Companies
Reporting entities for the purpose of this EITI report include international oil companies, state-
owned enterprises (SOEs) and government entities. These are outlined below.

4.4.1. International Oil Companies

The MSG determined a materiality threshold of zero for the international oil companies
contributing to the material revenue streams, whereby all companies contributing to the
material revenue streams were required to report during the reporting period (with the
exception of KRG).

As discussed under Section 4.2, the total export revenue includes crude oil sales to international
oil companies operating in Iraq under licensing round contracts, equivalent to the value of cost
recovery and remuneration fees earned by those companies. While these payments are
recorded as revenues by SOMO, they are, in fact, expenses for the Iraqi Government. Therefore,
the MSG has decided to reconcile cost recovery and remuneration fee payments to IOC due to
their importance, given that they are reported by SOMO as part of the oil export revenues. A
three-way reconciliation was performed as follows:
 Reconciliation of cost recovery and remuneration fees between SOMO and the IOCs
receiving such payments
 Reconciliation of cost recovery and remuneration fees between the PCLD (of the MoO),
which is the entity responsible for approving cost recovery and remuneration fees
amounts, and the IOCs receiving the payments

The reporting entities in relation to the material revenue stream, and associated payment
streams, are listed below:

Reporting entity Revenue/Payment streams

International Oil Buyers82 Crude oil export revenue
International Oil Companies83 Cost recovery and remuneration fees

82
The complete list of reporting international oil buyers is included in Annex 9
83
The complete list of reporting IOCs is included in Annex 10

110
 4.4.2. Government entities

Government entities are material entities if they receive payments from the reporting entities
and SOEs during the reporting period. Government entities that do not receive payments, but
keep record of payments, are also included in the list of material government entities. These
entities are:

- Ministry of Oil
- Ministry of Finance

4.4.3. State-owned entities

In relation to material government revenue streams, only one SOE (SOMO) was considered
material, as it is the sole entity responsible for exporting crude oil and therefore maintains
records of exported crude oil quantities and values. In addition to the revenue streams identified
in the table in Section 4.3 above, the MSG considered payment streams between SOES and the
Government, and decided to reconcile the internal service payments (ISP) made by the MoF
through SOMO to the national oil companies (these payments are made on a monthly basis).
ISP are only made to national companies involved in the extraction of crude oil. As discussed in
Section 2.4, such payments have been extended to the Oil Exploration Company during 2016,
due to decision made by the MoO, and therefore the OEC has been included in the scope of
reconciliations. Reporting SOEs are listed below:

Company Reason for selection

1- SOMO maintains record of exported crude oil revenue

SOMO 2- SOMO executes and maintains record of internal service payments
made to only 5 SOEs in the upstream sector.

North Oil Company North Oil Company receives internal service payments from SOMO

Basra Oil Company Basra Oil Company receives internal service payments from SOMO

Midland Oil Company Midland Oil Company receives internal service payments from SOMO

Missan Oil Company Missan Oil Company receives internal service payments from SOMO

Oil Exploration Company receives internal service payments from

Oil Exploration Company
SOMO

111
4.5. Detailed Reconciliations

In this section of the report, the data received from each of the reporting entities is reconciled
with the data reported by the receiving/recording entity for each revenue stream. Variances
are explained to the extent of cooperation of reporting entities in providing relevant
information.

Revenue streams that do not meet the quantitative materiality threshold have been unilaterally
reported by either the revenue recording or receiving entity. Reported amounts for revenue
streams unilaterally declared are included in this section.

Reconciliation of Internal Service Payments (payments between the Government and SOEs), are
also included in this section.

112
 4.5.1. Crude oil export revenue for year 2016

Crude oil export revenue paid by oil buyers is reconciled with data reported by SOMO in the table
below. Figures presented by SOMO are reported on a cash basis. As presented in Section 4.4.1,
the values reconciled include the value of liftings made by IOCs operating in Federal Iraq under
licensing round contracts, equivalent to their respective cost recovery and remuneration fees.

Amount by SOMO Amount by Buyer Difference

No Buyer Note
(USD) (USD) (USD)
1 Al Waha Petroleum 949,382,831 968,787,547 (19,404,716) A
2 API 255,665,418 259,368,241 (3,702,823) B
3 BHARAT OMAN 197,797,902 153,029,265 44,768,637 C
BHARAT
4 24,514,909 24,583,562 (68,653) B
PETROLEUM
BP & PETROCHINA
5 2,902,043,590 2,904,576,090 (2,532,500) D
INTERNATIONAL
6 BP OIL 725,572,194 729,080,080 (3,507,886) B
7 CANAL 549,574,243 549,574,243 - -
8 CEPSA 371,754,858 324,453,926 47,300,932 E
CHENNAI
9 PETROLEUM 617,897,175 631,227,103 (13,329,928) B
CORPORATION LTD
10 CHEVRON 978,911,116 939,274,464 39,636,652 F
CHINA
11 4,096,691,420 4,094,096,758 2,594,662 G
INTERNATIONAL
12 CHINA NATIONAL 1,494,359,889 1,495,864,673 (1,504,784) B
CHINA OFFSHORE
13 371,611,409 372,350,879 (739,470) B
OIL
CNOOC IRAQ
14 365,213,165 365,213,165 - -
LIMITED & TP
15 ENI IRAQ B.V. 846,432,255 849,440,588 (3,008,333) B
ENI SOC
16 (Partnership 194,429,480 194,204,652 224,828 I
contracts )
17 ENI TRADING 341,003,530 341,003,530 - -
18 ESSAR OIL 38,178,999 38,178,999 - -
EXXON MOBIL IRAQ
19 318,330,410 335,898,573 (17,568,163) K
LIMITED
EXXON MOBIL
SALES AND
20 SUPPLY 395,799,826 397,659,814 (1,859,988) B
CORPORTION
GALLOWS
GAZPROM NEFT
21 141,000,083 141,249,751 (249,668) B
BADRA B.V.
GS CALTEX (Project
22 344,651,360 344,651,360 - -
of Karbala Refinery)
GS CALTEX
23 SINGAPORE PTE. 1,344,523,262 1,369,767,228 (25,243,966) L
LTD.
24 GUNVOR 146,095,477 95,997,386 50,098,091 M

113
 Amount by SOMO Amount by buyer Difference
No Buyer Note
(USD) (USD) (USD)
25 HELLENIC 36,058,142 36,058,142 - -
HINDUSTAN
PETROLEUM
26 758,312,457 746,258,101 12,054,356 N
CORPORATION
LIMITED
27 HPCL-MITTAL 707,817,720 639,159,931 68,657,789 O
28 INDIAN 3,418,806,784 3,428,540,616 (9,733,832) B
29 IPLOM 116,170,810 116,899,210 (728,400) B
30 JAPEX 283,819,236 284,778,533 (959,297) B
31 JX NIPPON OIL 518,383,616 516,087,945 2,295,671 P
KOCH SUPPLY &
32 220,119,109 220,759,351 (640,242) B
TRADING
33 KOGAS BADRA B.V. 132,147,008 125,247,199 6,899,809 Q
34 KOGAS ZUBAIR 499,255,063 465,536,228 33,718,835 Q
35 KUWAIT ENERGY84 22,651,516 22,651,516 - -
36 LITASCO 336,441,675 337,729,709 (1,288,034) B
37 LUKOIL Mid-East 2,110,921,802 1,337,499,492 773,422,310 Q
38 MOTOR OIL 713,296,013 716,485,551 (3,189,538) B
NORTH
39 618,246,995 716,524,450 (98,277,455) R
PETROLEUM
OCCIDENTAL
40 ENERGY IRAQ 145,388,719 145,388,719 - -
LLC85
PERTAMINA
41 212,736,520 212,736,520 - -
(PERSERO)
42 PETRO DIAMOND 317,239,599 317,984,456 (744,857) B
43 PETROBRAS 195,037,592 195,037,592 - -
PETROCHINA
44 580,222,138 580,911,714 (689,576) B
HALFAYA
PETROCHINA WEST
45 325,299,060 326,033,698 (734,638) B
QURNA
46 PETROGAL 136,347,160 136,845,964 (498,804) B
47 PETRONAS 192,468,568 194,128,842 (1,660,274) B
48 PETRONAS BADRA 68,271,232 68,271,232 - -
49 PETRONAS GARRAF 547,822,225 548,450,928 (628,703) B
PETRONAS
50 272,689,953 272,689,953 - -
HALFAYA
PETRONAS
51 429,788,526 429,788,526 - -
MAJNOON
52 PHILLIPS 66 1,172,198,606 1,178,815,548 (6,616,942) B
PT PERTAMINA
53 141,612,379 141,612,37986 - -
IRAQ

84
The figures reported by SOMO and Kuwait Energy relates to oil liftings made by Kuwait Energy on behalf of the entire consortium (in Faihaa –
Block 9), which includes Dragon Oil and EGPC
85
The figures reported under Occidental were reported by BOC being the legal successor, since BOC bought Occidentals shares in Zubair field
effective September 2016. Occidental is no longer operating in Iraq, and has not responded to data requests.
86
The figures reported under the PT PERTAMINA IRAQ, SHELL MAJNOON and SHELL WEST QURNA were reported by BOC for to the following
reasons:
 Shell Majnoon reported that it had sold its shares in Majnoon field to BOC, and therefore reliance should be on
information reported by BOC
 PT Pertamina and Shell West Qurna (Phase 1) field did not report the requested information, however, BOC reported

114
 Amount by SOMO Amount by buyer Difference
No Buyer Note
(USD) (USD) (USD)
RELIANCE
54 INDUSTRIES 1,160,500,072 1,097,989,156 62,510,916 S
LIMITED (RIL)
55 REPSOL 552,932,799 505,966,485 46,966,314 T
SARAS SPA -
56 427,490,043 291,591,183 135,898,860 J
MILANO
57 SHELL 366,391,683 277,270,594 89,121,089 U
58 SHELL MAJNOON 741,516,631 663,018,08786 78,498,544 V
SHELL WEST
59 184,652,178 184,652,17886 - -
QURNA
60 SINOCHEM 3,205,534,045 3,228,733,093 (23,199,048) W
61 SK ENERGY 463,153,473 359,584,696 103,568,777 X
62 SOCAR 252,355,472 270,460,415 (18,104,943) AC
63 TOTSA TOTAL 731,211,184 751,075,629 (19,864,445) Y
TOTSA TOTAL
64 HALFAYA 271,939,979 265,023,042 6,916,937 Z
CONTRACT
65 TOYOTA 610,789,754 614,688,041 (3,898,287) B
66 TP BADRA LTD. 28,804,419 28,804,419 - -
67 TP MISSAN 53,520,479 60,778,289 (7,257,810) AA
68 TUPRAS 179,522,511 179,522,511 - -
VALERO
MARKETING
69 890,384,979 859,928,804 30,456,175 AB
&SUPPLY
COMPANY
70 VITOL 88,902,511 90,160,304 (1,257,793) B
Total 43,450,607,236 42,107,690,848 1,342,916,388

Notes:

B Differences noted under note (B) are due to delay penalties reported by SOMO.

the value of liftings made by these IOCs being the license holder of West Qurna (Phase 1) field. The revenue
reported by SOMO in respect of these two companies represents 0.75% of total crude oil export revenue, and therefore,
the non-compliance of this company does not have a material impact on the comprehensiveness of the reconciliation
efforts. None the less, figures reported by BOC were used for the reconciliation purposes for the aforementioned
reason.

115
Notes on the remaining differences are explained in the table below:

Amounts
reported by Amounts reported
SOMO not by buyer not Difference
Ref Notes
reported by the reported by SOMO (USD)
buyer (USD)
(USD)
The differences represent one delay
penalty amounting to USD 210,201
(210,201) -
reported by SOMO not reported by
the buyer.
The difference is due to:
- The value of one invoice related to
2015 amounting to USD
20,444,788 reported by the buyer
not reported by SOMO. (19,404,716)
A
- Difference in the value of one
invoice where the buyer recorded an
- (19,194,515)
invoice amount less than the invoice
amount reported by SOMO by USD
718,735
- The value of one delay penalty
amounting to USD 531,539
reported by the buyer not reported
by SOMO.

The differences represents the

value of 5 invoices related to
November and December 2016 68,515,776 -
totaling USD 68,515,776 reported
by SOMO not reported by the buyer.
C 44,768,637
The difference represents the value
of one invoice related to 2015
amounting to USD 23,747,139 - (23,747,139)
reported by the buyer not reported
by SOMO.
D Unjustified Difference - (2,532,500) (2,532,500)

The differences represent the value

of one invoice related to December
2016 amounting to USD
E 47,300,932 - 47,300,932
48,651,878, and 6 delay penalties
totaling USD 1,350,946 reported by
SOMO not reported by the buyer.

The difference represents the value

of one invoice related to December
2016 amounting to USD
F 46,096,000, and the value of 10 39,636,652 - 39,636,652
delay penalties for a total of USD
6,459,348 reported by SOMO not
reported by the buyer.

116
 Amounts
reported by Amounts reported
SOMO not by buyer not Difference
Ref Notes
reported by the reported by SOMO (USD)
buyer (USD)
(USD)
The difference represents the value
of one invoice reported by SOMO
and not reported by the buyer
amounting to USD 25,737,304, and
G 2,594,662 - 2,594,662
delay penalties reported by SOMO
not reported by the buyer for an
amount of USD 23,142,642

The difference represents the value

of commercialization fees reported
I by the buyer not reported by - 224,828 224,828
SOMO.

The reason for this difference is that

J the buyer reported the figures on 135,898,860 - 135,898,860
accrual basis.

The difference represents USD

(318,993) in delay penalties
reported by SOMO related to terms
contract under LC, not reported by (318,993) -
the buyer.
K The difference represents the value (17,568,163)
of corporate income tax of USD
17,249,170 related to the buyer’s
service contract under licensing - (17,249,170)
rounds, reported by the buyer not
reported by SOMO

The difference represents the value

of one invoice related to December
2016 amounting to USD
91,488,570 -
100,225,923 and delay penalties
totaling USD 8,737,353 reported by
SOMO not reported by the buyer.
L (25,243,966)
The difference represents the value
of 2 invoices related to 2015
totaling USD 116,732,536 - (116,732,536)
reported by the buyer not reported
by SOMO.

The difference represents the value

of 1 invoice related to December
2016 amounting to USD 50,038,464 -
50,038,464 reported by SOMO not
M reported by the buyer. 50,098,091
The difference represents the value
of delay penalties amounting to
- 59,627
USD 59,627 reported by the buyer
not reported by SOMO.

117
 Amounts
reported by Amounts reported
SOMO not by buyer not Difference
Ref Notes
reported by the reported by SOMO (USD)
buyer (USD)
(USD)
The difference represents the value
of 4 invoices related to November
and December 2016 totaling USD
127,829,203, and two delay
127,396,326 -
penalties amounting to USD
432,877 reported by SOMO not
reported by the buyer.
N 12,054,356
The difference represents the value
of 5 invoices related to 2015
totaling USD 115,341,970
- (115,341,970)
reported by the buyer not reported
by SOMO.

The difference represents the value

of 6 invoices related to November
and December 2016 totaling USD
139,265,550, and two delay
136,728,177 -
penalties amounting to USD
2,537,373 reported by SOMO not
O 68,657,789
reported by the buyer.

The difference represents the value

of 4 invoices related to 2015
- (68,070,388)
totaling USD 68,070,388 reported
by the buyer not reported by SOMO.
The difference represents price
differences amounting to USD
P 3,251,182 and delay penalties 2,295,671 - 2,295,671
totaling USD 955,511 reported by
SOMO not reported by the buyer.

The amount reported represents the

value of crude oil quantities lifted by
the buyers as service fees (cost
Q recover and remuneration fees). - 814,040,954 814,040,954
The reason for the difference is
because the buyers have reported
the approved amount of service fees
not the actual value of lifting.
The difference relates to one delay
penalty amounting to USD 179,320 (179,320) -
reported by SOMO not reported by
the buyer.
R (98,277,455)
The difference represents the value
of 2 invoices related to January
2017 totaling USD 98,098,135 - (98,098,135)
reported by the buyer not reported
by SOMO.

118
 Amounts
reported by Amounts reported
SOMO not by buyer not Difference
Ref Notes
reported by the reported by SOMO (USD)
buyer (USD)
(USD)
The differences represents the
value of 8 invoices related to
November and December 2016
totaling USD 161,602,549, and two 160,768,697 -
delay penalties totaling USD
833,852 reported by SOMO not
S reported by the buyer. 62,510,916

The difference represents the value

of 4 invoices related to 2015
- (98,257,781)
totaling USD 98,257,781 reported
by the buyer not reported by SOMO.

The difference represents the value

of one invoice related to December
2016 amounting to USD
T 49,065,620 and 7 delay penalties 46,966,314 - 46,966,314
amounting to USD 2,099,306
reported by SOMO not reported by
the buyer.

The difference represents the value

of one invoice related to December
U 2016 amounted of USD 89,121,089 - 89,121,089
89,121,089 reported by SOMO not
reported by the buyer.

The differences represent one

V 78,498,544 - 78,498,544
invoice related to December 2016.

The differences represent 12 delay

penalties amounted of USD
(11,983,380) -
11,983,380 reported by SOMO not
reported by the buyer.
W (23,199,048)
The difference represents the value
of one invoice related to 2017
amounting to of USD 11,215,668 - (11,215,668)
reported by the buyer not reported
by SOMO.

The difference represents the value

of one invoice related to December
2016 amounting to USD
X 103,568,777 reported by SOMO 103,568,777 - 103,568,777
not reported by the buyer.

119
 Amounts
reported by Amounts reported
SOMO not by buyer not Difference
Ref Notes
reported by the reported by SOMO (USD)
buyer (USD)
(USD)
The difference represents the value
of 9 delay penalties totaling USD
(5,759,045) -
5,759,044 reported by SOMO not
reported by the buyer.
Y (19,864,445)
The difference represents the value
of one invoice related to 2017
amounting to USD 14,105,400 - (14,105,400)
reported by the buyer not reported
by SOMO.

The difference is due to the fact

that the buyer has reported
Z different prices in two invoices than - 6,916,937 6,916,936
the prices reported by SOMO for
the same invoice.

The difference represents the value

of two invoices totaling USD
AA - (7,257,810) (7,257,810)
7,257,810 reported by the buyer
not reported by SOMO.

The difference represents one

invoice related to November and
December 2016 amounting to USD
93,099,312 and 7 delay penalties 90,955,761 -
totaling USD 2,143,551 reported
by SOMO not reported by the
AB buyer. 30,456,175

The difference represents the value

of one invoice related to 2015
amounting to USD 60,499,586 - (60,499,586)
reported by the buyer not reported
by SOMO.

The difference is unjustified, as the

AC buyer did not respond to our - (18,104,943) (18,104,943)
questions regarding the difference.

120
 4.5.1.1. Cost recovery reconciliation

The following table displays the reconciliation of cost recovery between the PCLD (MoO) and
the IOCs for the year 2016. Figures reported by the PCLD represent the cost recovery accrual
for the year 2016, i.e. the amount of cost recovery approved during the year 2016.

Cost recovery/ Cost recovery/

Difference
Field Company PCLD Companies Note
(USD)
(USD) (USD)
BP 1,088,902,188
Rumaila 1,824,004,522 (419,660,278) A
Petrochina 1,154,762,612
Missan CNOOC
503,756,976 503,756,97687 - -
fields TPAO
Petrochina
Halfaya Totsa Total 769,512,138 784,384,37388 (14,872,235) B
Petronas
Petronas 532,277,479
Garraf 556,255,398 (250,018,315) C
JAPEX 273,996,234
West
Qurna Lukoil Mid-East 831,413,778 1,096,631,931 (265,218,153) D
(Phase 2)
TPAO 28,804,419
Petronas 68,271,232
Badra 413,721,446 (101,439,954) E
KOGAS 125,247,199
JSC Gazprom 292,838,550
Al-Waha
Ahdeb 890,471,300 968,787,547 (78,316,247) F
Petroleum
Kuwait Energy
Faihaa
Dragon Oil 42,892,085 42,892,08589 - -
(Block 9)
EGPC
Total 5,832,027,643 6,961,552,825 (1,129,525,182)

Notes:

A The differences is due to the fact that the PCLD reported the data on accrual basis (the cost recovery
approved during 2016 not the cost recovered during 2016)

B The difference is due to the following:

Corporate income tax was withheld from the petroleum costs (cost recovery) instead of the
remuneration fees, as the remuneration fees were not sufficient to cover the annual corporate tax
due for the year. As a result, PCLD deducted the shortfall of tax amounting to USD 14,872,235
from petroleum costs.

C The differences is due to the fact that the PCLD reported the data on accrual basis (the cost
recovery approved during 2016 not the cost recovered during 2016).

87
This figure was reported by the field operator CNOOC Iraq, on behalf of the entire consortium
88
This figure was reported by the field operator Petrochina Halfaya, on behalf of the entire consortium
89
This figure was reported by the field operator Kuwait Energy on behalf of the entire consortium

121
 D The difference relates to a 2015 fourth quarter cost recovery invoice amounting to USD 395,807,645
reported by the company and not reported by PCLD, and a 2016 fourth quarter cost recovery invoice
amounting to USD 130,589,492 reported by the PCLD not reported by the company.

E The differences is due to the fact that the PCLD reported the data on accrual basis (the cost
recovery approved during 2016 not the cost recovered during 2016).

F The differences is due to the fact that the PCLD reported the data on accrual basis (the cost recovery
approved during 2016 not the cost recovered during 2016).

The table below shows reconciliations of cost recovery and remuneration fees of West Qurna
(Phase 1) field and Majnoon field for the year 2016 between the PCLD and the respective IOCs.
As stated in Section 4.5.1, Shell West Qurna, Shell Majnoon, Occidental and Pertamina did not
report on their liftings made during the year 2016 (equivalent to cost recovery and
remuneration fees earned by these companies), however, BOC made such reporting on the basis
that:
1- Shell Majnoon had sold its shares in Majnoon field to BOC, and therefore reliance is
made on information reported by BOC
2- Occidental has sold its shares in Zubair field to BOC, and therefore reliance is made on
information reported by BOC
3- BOC is the license holder of West Qurna (Phase 1) field

Cost recovery and remuneration fees were grouped together for the purpose of this
reconciliation because BOC reported the value of liftings made without differentiation between
cost recovery and remuneration fees.

Cost recovery and Cost recovery and

remuneration fees / remuneration fees/ Difference
Field Company Note
PCLD Companies (USD)
(USD) (USD)

ENI 812,278,414
Zubair
KOGAS 1,444,490,848 465,536,228 21,287,487
Occidental90 145,388,719
ExxonMobil 335,898,574
West Qurna Petrochina 1,428,418,910
(1,284,136,820) A
(Phase 1) Shell West 806,445,221
184,652,178
Qurna90
Pertamina90 141,612,379
Majnoun Shell Majnoon90 663,018,087 (396,242,440)
727,338,455
Petronas 460,562,808
Total 2,978,274,524 4,637,366,297 (1,659,091,773)
Note:

A The differences between PCLD reported figures and BOC reported figures remain unjustified due to not
receiving the required justifications in time, however, part of the difference is due to the PCLD reporting
the data on accrual basis (the cost recovery approved during 2016 not the cost recovered during 2016).

90
The figures in relation to these companies were reported by BOC

122
 4.5.1.2. Remuneration fees reconciliation

The following table displays the reconciliation of remuneration fees between the PCLD (MoO)
and the IOCs for the year 2016. Figures reported by the PCLD represent the remuneration fee
accruals for the year 2016, i.e. the amount of remuneration fees approved during the year
2016.

Remuneration fees Remuneration

Difference
Field Company / PCLD fees / Companies Note
(USD)
(USD) (USD)
BP 387,254,992
Rumaila 400,822,678 (260,088,612) A
Petrochina 273,656,298
Missan CNOOC
- - - -
fields91 TPAO
Petrochina
Halfaya Totsa Total 69,815,036 65,443,53692 4,371,500 B
Petronas
Petronas 16,173,449
Garraf 53,126,281 26,170,533 C
JAPEX 10,782,299
West
Qurna Lukoil Mid-East 119,303,133 240,867,561 (121,564,428) D
(Phase 2)
TPAO
Petronas
Badra91 - - - -
KOGAS
JSC Gazprom
Al-Waha
Ahdeb 218,413,152 218,413,152 - -
Petroleum
Kuwait Energy
Faihaa
Dragon Oil 7,194,218 7,194,21893 - -
(Block 9)
EGPC
Total 868,674,498 1,219,785,505 (351,111,007)

Notes:

A The differences is because the PCLD reported the data on accrual basis (the remuneration fees
approved during 2016 not the remuneration fees received during 2016).

B The difference is due to the net effect of the following:

1- Corporate income tax withheld from cost recovery amounting to USD 14,872,235 (as sated in
Section 4.5.1.1) was added to the value of remuneration fees (in the PCLD records)
2- The companies reported the state partner’s share in remuneration fees amounting to
10,500,735, while the PCLD did not.

91
There were no remuneration fees reported during the year 2016, in respect of these fields
92
This figure was reported by the field operator Petrochina Halfaya, on behalf of the entire consortium
93
This figure was reported by the field operator Kuwait Energy on behalf of the entire consortium

123
C The difference is due to the following:
1- The PCLD reported the data on accrual basis (the remuneration fees approved during 2016 not
the remuneration fees received during 2016).
2- The amount reported in the companies’ column represents the total of figures reported by
Petronas and JAPEX. However, we were unable to identify whether the amount reported by JAPEX
represents its share only, or is representative of field total remuneration fees.

D The difference relates to a 2015 fourth quarter remuneration fees invoice amounting to USD
153,414,362 reported by the company and not reported by PCLD, and a 2016 fourth quarter
remuneration fees invoice amounting to USD 31,849,934 reported by the PCLD not reported by the
company.

For the reconciliation of remuneration fees related to the West Qurna (Phase 1) and
Majnoon fields, please refer to Section 4.5.1.1.

124
 4.5.2. Corporate Income Tax (CIT)

The service contracts signed under licensing rounds require IOCs to pay income tax levied at a
rate of thirty five percent (35%) of the contractor’s taxable profit under the law which shall, as
between the contractors and the national oil companies (MoO entities), be deemed to be the
remuneration fee received during the relevant tax year.

The following table presents the amounts reported by the PCLD for the year 2016, which
represents CIT balances approved during the year. As it relates to Ahdeb field, the CIT reported
in the special purpose financial statements for year 2016, CIT is part of the recoverable
petroleum costs. Therefore, the CIT levied at 35% of remuneration fees is a reimbursable cost
for the Contractor. As it relates to the other fields, for which we received the audited special
purpose financial statements (Zubair, Badra, Garraf, Missan fields, West Qurna (Phase 1 and
Phase 2), Helfaya), CIT is a non-recoverable cost for the Contractors. We did not receive the
audited special purpose financial statements for the remaining fields (Majnoun, Rumaila, and
Faihaa), and hence we could not confirm the recoverability of those expenses.

Tax / PCLD
Oil Field Company name
(USD)
BP
Rumaila 187,446,603
Petrochina
ENI
Zubair KOGAS 64,407,384
Occidental
ExxonMobil
Petrochina
West Qurna (Phase 1) 62,827,345
Shell
Pertamina
CNOOC
Missan fields -
TPAO
Petrochina
Helfaya Totsa Total 33,077,318
Petronas
Shell
Majnoun 28,631,499
Petronas
Petronas
Garraf 18,594,198
JAPEX
West Qurna (Phase 2) LUKOIL Mid-East Ltd 60,549,356
TPAO
Petronas
Badra* -
KOGAS
JSC Gazprom
Ahdeb Al-Waha Petroleum 76,444,603
Kuwait Energy
Faihaa (Block 9) Dragon Oil 2,857,147
EGPC
Total 534,835,453

125
 According to Midland Oil Company (the license holder for Badra field), CIT was not paid
by the contractor, because the contractor did not receive any remuneration fees during
the year.

126
 4.5.3. Treasury share of SOE net profits

These payments made by SOEs to the government (specifically to the MoF) represent the
government’s share of the companies’ net distributable profits (in accordance with Law No. 22
of 1997). Payments from SOEs to the government are deposited with the MoF Treasury, and
for the purpose of this report, have been reported unilaterally by the Ministry of Finance (the
government body receiving the payments).

The table below represents the amounts received by the MoF from SOEs operating in the
extractive sector during year 2016. The amounts presented by the MoF are reported on a cash
basis; therefore, amounts received during 2016 do not necessarily represent amounts accrued
during the fiscal year 2016:

SOE IQD USD Equivalent94

Basra Oil Company 103,224,585,053 87,330,444
SOMO 30,200,429,140 25,550,278
Iraqi Oil Tankers Company 2,327,717,178 1,969,304
Oil Exploration Company 7,428,327,006 6,284,541
The State Company Of Fertilizers/ Southern Region 2,942,491,142 2,489,417
North Oil Company 15,713,629,161 13,294,103
South Refineries 84,614,047,823 71,585,489
Missan Oil Company 117,670,239,534 99,551,810
Midland Refineries 22,975,350,328 19,437,691
Total 387,096,816,365 327,493,077
Source: This information was reported by the MoF

Only one of the eight SOEs operating in the mining sector had paid its share of net profits to the
MoF treasury during 2016. This is because all operational SOEs, excluding the State Company
of Fertilizers, realized a net loss during the calendar year 2016. In addition, the State Company
for Phosphate, and the Mishraq Sulphur Company were not operational during 2016.

SOE payments to the state treasury are made after the final accounts of the SOEs have been
approved by the FBSA. With the exception of one state-owned entity (North Oil Company), the
final accounts of all state-owned entities operating in the oil and gas sector for year 2016 had
not been approved by the FBSA during 2016. Therefore, payments made to the state treasury
represent payments in respect of outstanding balances, accrued in years prior to 2016.
Accordingly, some SOEs have made no payments to the MoF during 2016.

Due to the delay in the FBSA’s audit of the final accounts in Iraq since 2014, many of the
extractive SOEs have not been making payments to the state treasury, which has caused cash
flow issues for the Ministry of Finance. Accordingly, the Ministry of Oil has attempted to resolve
the issue by obtaining the Prime Minister’s approval dated 26 April 2018 on the following:

94
Throughout this report the exchange rate of IQD 1,182 = USD 1 is used to convert from Iraqi Dinar to US Dollar,
which is in accordance with the federal budget approved exchange rate for the year 2016.
127
- SOEs are required to pay 50% of the treasury share (50% of the 45% share of net profits)
to the state treasury before the final accounts are audited by the FBSA.

128
 4.5.4. State partner shares in field remuneration fees

The following table represents the value of the sate partner’s share of remuneration fees paid
during 2016, which is reported by the Ministry of Oil.

State partner Total state partner

Filed Name Sate Partner ownership revenue
%* (USD)

Rumaila SOMO 6 25,744,544

Zubair MOC 5 11,785,983

West Qurna (Phase 1) OEC 5 12,819,371

West Qurna (Phase 2) NOC 25 98,187,529

Majnoon MOC 25 32,496,248

Garraf NOC 25 19,336,914

Faihaa (Block 9)95 - - -

Ahdeb SOMO 25 -

Halfaya BOC 10 18,339,994

Missan fields Iraqi Drilling Company 25 -

Badra OEC 25 -

Total 218,710,583

Source: This data was presented by the MoO

 These percentages reflect the ownership interest of state partners during 2016

95
There is no state partnership in Block 9
129
 4.5.5. Internal Service payments (Requirement 4.5)

The table below represents the value of internal service payments made by the MoF through
SOMO to the NOCs to cover the cost of production that is exported, on a monthly basis. These
payments have been reconciled between SOMO and the national extractive companies due to
their importance.

The following table represents a reconciliation between SOMO and the respective national oil
companies, and the Oil Exploration Company for year 2016:

Amount by SOMO Amount by Company Difference*

Month
(IQD) (IQD) (IQD)

Basra Oil Company 19,000,000,000 19,000,000,000 -

Missan Oil Company 98,000,000,000 98,000,000,000 -
Midland Oil Company 60,000,000,000 60,000,000,000 -
North Oil Company 267,000,000,000 267,000,000,000 -
Oil Exploration
33,000,000,000 27,000,000,000 6,000,000,000
Company**
Total 477,000,000,000 471,000,000,000 6,000,000,000

 The difference is due to a partial settlement of an advance in relation to July

2015 for IQD 6,000,000 reported by SOMO, and not reported by the EOC.

** The Oil Exploration Company’s ISP for the year 2016 (IQD 33 billion) was paid by SOMO
through contributions from the four national oil companies, as per the following
contribution shares:
- 70% from Basra Oil Company
- 5% from North Oil Company
- 10% from Midland Oil Company
- 15% from Missan Oil Company

As evident in the table above, Basra Oil Company receives the lowest amount of internal service
payments, although it accounts for the highest share of total crude oil production rate in Federal
Iraq. At the same time, North Oil Company accounts for a significantly lower share of crude oil
production than BOC, but receives the highest ISP. According to discussions with the FBSA, this
is due to the following reason:
- Allocations are made, taking into consideration the cash flow status of each company.
Companies that have sufficient cash flows, and are able to finance their operations
receive a smaller share than companies that face cash flow shortages.

130
4.6. Subnational direct payments (Requirement 4.6)

4.6.1. KRG Revenue

Crude oil export revenues received by the KRG during 2016:

Allocated to main Retained by

Value realized
producers buyers against Net export revenue
for the exported
Month according to their past received by the KRG
crude oil
PSC entitlement prepayments (USD)
(USD)
(USD) (USD)

January* - - - -
February 303,943,433 (70,933,433) (43,200,644) 189,809,356
March 207,272,177 (36,014,177) - 171,258,000
April 376,395,901 (58,895,901) - 317,500,000
May 390,748,957 (75,262,856) - 315,486,101
June 561,953,676 (81,443,291) (97,840,813) 382,669,572
July 461,196,477 (24,914,718) (63,424,530) 372,857,229
August 413,994,993 (60,346,909) (90,778,431) 262,869,653
September 611,764,928 (75,773,752) (173,376,207) 362,614,969
October 636,364,810 (74,568,710) (153,802,371) 407,993,729
Total 2,783,058,609
Source: MNR website (http://mnr.krg.org/index.php/en/oil/monthly-export-production-data)

 With regards to the quantities exported during the month of January, the value received
(in USD) was not identified in the report.

Based on the information reported by the MNR in the production report (daily gross field
production) for the period from January 2015 to September 2016, which was discussed in
Section 3.3 of the report, the four largest producers of KRG oil (per filed) for the year 2016 are:

1) Tawke – DNO A.S (Genel Energy is also a partner, but DNO A.S is the operator)
2) Taq Taq – TTOPCO (is a special purpose entity established by Genel Energy and Addax
Petroleum, and is the operator of Taq Taq field)
3) Shaikan – Gulf Keystone Petroleum (Operator)
4) Khurmala/Bai Hassan/Avana – KAR (Operator)

We were able to find the reports on payments to governments published by two of the four above
listed companies, in which all payments made to the different governments are declared:

i. Gulf Keystone Petroleum Ltd (GKP): Reports on payments to governments were published
in its website
ii. TTOPCO (is a special purpose entity established by Genel Energy and Addax Petroleum):
Figures reported by Genel Energy on the payments to government’s reports includes
payments made by TTOPCO.

The following tables represent revenues received by the KRG from Gulf Keystone and Genel
Energy in relation to Shaikan, Taq Taq, and Tawke PSCs.
131
Genel Energy plc.

Amount (USD)
Genel Energy plc.
Taq Taq* Tawke**
Royalties 83,170,000 -
Capacity Building Payments 13,600,000 10,900,000
Total 96,770,000 10,900,000
Source: Genel Energy plc. Payments to Government 2016 report

* As reported by Genel Energy, the amount reported for Taq Taq, with the exception of capacity
building payments, is the gross payment made to the Kurdistan Region of Iraq (KRI) by the
operating company (TTOPCO), Genel’s share of these payments is equal to 55%.

** As reported by Genel Energy, payments in relation to Tawke are made by the Operator with
the exception of capacity building payments, which are made directly by Genel in relation to its
interest in the Tawke Production Sharing Contract.

Gulf Keystone Petroleum Ltd (GKP).

Gulf Keystone Petroleum Ltd. Amount (USD)

Royalties 30,522,577
Payables to the MNR offset against
72,577,496
Revenue*
Total 103,100,073
Source: Gulf Keystone Petroleum Ltd. Payments to Government 2016 report

* As reported by GKP, “GKP payables to the MNR include Shaikan Building Payments, production
bonuses, security invoices and PSC charges. These costs were recognized as payables to the
MNR but have been offset against revenue arrears owed to GKP by the MNR”

132
4.7. In-Kind Revenues, barter agreements, and transportation
revenues (Requirements 4.2 -4.4)

According to the MSG, Requirements 4.2, 4.3 and 4.4 are all not applicable in Iraq due to the
following:

- There are no revenues received in-kind by the Iraqi Government

- There are no barter agreements in Federal Iraq, and the IEITI observed through a
review of a sample of PSCs published by the KRG that there are no barter or swap
provisions in KRG oil and gas production sharing contracts.
- There are no transportation revenues received by the Government of Iraq

133
 4.8. Data Quality and Assurance (Requirement 4.9)

4.8.1. Audit and assurance procedures in state-owned entities working

in the extractive sector:

External audit practices:

SOEs in federal Iraq maintain and report their accounts in accordance with the Unified
Accounting System (UAS). They are audited by the Federal Board of Supreme Audit, in
accordance with Law No. 31 of 2011 Law of The Board of Supreme Audit (as amended).

The Federal Board of Supreme Audit undertakes audit programs prepared in accordance with
local accounting principles issued by the Council of Auditing and Accounting Standards of the
Republic of Iraq, the details of which are published on the IEITI website 96.

In addition to the audits conducted by the board, the Board of Supreme Audit also provides
technical assistance in the fields of accounting, oversight, and administration to SOEs (as per
Article 6 of Law No. 31 of 2011).

Internal Controls:

Internal controls adopted by SOEs include internal audit and control establishments, which
operate in accordance with independently prepared work plans and mechanisms. In conducting
their audits, the internal audit functions rely on activity- specific laws and regulations issued by
the Council of Auditing and Accounting Standards of the Republic of Iraq. At year-end, financial
statements are prepared by the financial departments, after they are audited and validated by
the respective internal control functions, and the Internal Control Department at the ministry
site. After completing their preparation, in accordance with the requirements of the Federal
Board of Supreme Audit, the financial statements are presented to the Board of Supreme Audit
to express its opinion on the financial statements.

96
http://ieiti.org.iq/mediafiles/articles/doc-546-2018_11_08_07_14_50.pdf

134
 4.8.2. Audit and assurance procedures in International Oil Companies
(IOCs)

International oil companies operating in Iraq under licensing rounds contracts are required by
the terms of their contracts to establish and maintain a branch office in the Republic of Iraq and
to maintain such office for the term of the contract. Entities registered in Federal Iraq are
required to prepare annual financial statements in accordance with Iraqi Uniform Accounting
Standards (UAS), which are audited by an external auditor.

In addition to the audited financial statements of the IOCs, special purpose financial statements
for each field are prepared in accordance with the terms of the service contracts, and are
audited by external auditors in accordance with International Standards on Auditing (ISA).

4.8.3. Data quality assurance measures

As stated above, SOE’s final accounts are audited by the FBSA. However, due to the absence
of an approved federal budget for the year 2014, all of the national companies’ final accounts
(with the exception of North Oil Company) have not been audited by the FBSA, for the period
between 2014 and 2017. Accordingly, the MSG decided to adopt the following quality assurance
methods for the reporting SOEs:
- Where SOE final accounts are audited by the FBSA, the audited accounts of the SOEs
are obtained
- Where final accounts are not yet audited and approved by FBSA (due to the delay
described above), the companies’ final accounts signed by the Internal Audit Committee
and Board of Directors, is obtained
- In addition to the above, all reporting templates have to be signed and stamped by the
company representative, confirming accuracy of the reported figures

In the case of international oil companies buying crude oil from SOMO, the financial statements
of these companies are audited by the international audit firms (external auditors). The financial
statements of these companies include the results of their business operations, whether they
relate to purchases from SOMO or from their other business activities carried out outside of
Iraq. Therefore, some companies may not agree to disclose their audited financial statements.
Accordingly, the MSG has decided to adopt the following data quality assurance measure to
verify the accuracy of the data provided by these companies, as follows:
- Audited financial statements signed by the companies’ external auditor
- Where audited financial statements are not provided, the approved quality assurance
measure is to receive the invoices issued by SOMO to support the figures reported by
the oil buyers in the reporting templates, and the underlying supporting documents
- In addition to the above, all reporting templates have to be signed and stamped by the
company representative, confirming accuracy of the reported figures

135
In the case of international oil companies operating in Iraq under licensing rounds contracts, the
MSG agreed to adopt the following quality assurance measures:

- Audited financial statements signed by the companies’ external auditor

- Where audited financial statements are not provided, the alternative quality assurance
measure is to receive the special purpose financial statements for the fields, signed by
the field external auditor

136
 4.8.4. Data quality of reporting companies

SOEs

The following table displays the percentage of compliance to data quality assurance
requirements, by SOEs:

- All six reporting SOEs provided signed templates

- Of the six reporting SOEs, only one company had its financial statements audited and
approved by the FBSA. Therefore, only one company submitted its audited financial
statements
- Of the six reporting SOEs, only two presented the 2016 financial statements that have
been approved by the Internal Audit Department and Board of Directors
Financial statements
Financial Statement approved
Signed Templates approved by Internal Audit
by FBSA97
and BOD
100% 33.3% 16.7%

International oil buyers

The following table displays the percentage of compliance to data quality assurance
requirements, by oil buyers:

- Of the oil buyers who completed the reporting templates, 78.3% presented signed and
stamped templates
- Of the oil buyers who completed the reporting templates, 26% presented the related
SOMO invoices to support the amounts reported
- Of the oil buyers who completed the reporting templates, 43.5% presented the audited
financial statements for the year 2016
SOMO
Signed Templates Audited financial statements
invoices
78.3% 26% 43.5%

International oil companies

The following table displays the percentage of compliance to data quality assurance
requirements, by IOCs:

- Of the IOCs who completed the reporting templates, 69.6% presented signed and
stamped templates
- Of the IOCs who completed the reporting templates, 26.1% presented the company’s
audited financial statements for year 2016
- Of the IOCs who completed the reporting templates, 74% presented the audited field
financial statements for year 2016

Company's audited financial

Signed Templates Field financial statements
statements

69.6% 26.1% 74%

97
Only one of six material reporting SOEs submitted financial statements audited by the FBSA

137
From the aforementioned analysis, it is clear that reporting companies favored the approach of
sending signed and stamped reporting templates. Although this is acceptable according to the
approach approved by the MSG, reported data would be of higher credibility if the reporting
packages included copies of audited financial statements.

138
 4.8.5. Reconciliation process

The reconciliation process is based on matching relevant and credible data from two or more
sources accompanied by appropriate explanation of differences. Reporting is made by the
concerned entities in accordance with the set criteria and requirements. Reporting entities were
requested to report the requested data on a cash basis, since all governmental and state owned
entities in Iraq apply the cash accounting basis in their financial reporting under the Iraqi Unified
Accounting System. However, while the PCLD’s financial reporting is performed on a cash
accounting basis, the PCLD reported cost recovery, remuneration fees, and corporate income
tax amounts that were approved during the year 2016 (2016 accrual).

The reconciliation process consisted of the following steps:

a. Reconciliation of the total revenues received by the Government of Iraq from oil exports
as reported by the Ministry of Oil / SOMO and international oil buyers (including
international oil extracting companies who lifted crude oil in respect of their cost
recovery and remuneration fee shares);

b. Reconciliation of total payments made by the Government of Iraq as cost recovery as

reported by the Ministry of Oil / PCLD and international oil extracting companies;

c. Reconciliation of total payments made by the Government of Iraq as remuneration fees

as reported by the Ministry of Oil / PCLD and international oil extracting companies;

d. Reconciliation of total payments made by the Government of Iraq as internal service

payments as reported by the national oil companies and SOMO;

139
 5. Management and distribution of revenues

5.1. Budget Process (Requirement 5.1)

According to Section 6 of the Financial Management and Public Debt Law No. 95 of year 2004
(as amended), the federal budget should be prepared in accordance with economic development
plans, the pursuit of macroeconomic stability, economic policy, and applicable laws and
regulations. In particular, the preparation of the federal budget should be based upon prudent
and conservative forecasts for petroleum prices, petroleum production, and tax and customs
revenue. According to the Law, the Ministry of Finance is responsible for preparing the federal
budget projections in consultation with the Central Bank and other Ministries in their respective
areas of expertise. Section 6 of Law No. 95 requires the Minister of Finance to complete the
annual draft federal budget by September of each year and submit it to the Council of Ministers
(CoM) for approval. The Minister of Finance is then required to submit the budget by 10 October
of each year to the body vested with the national legislative authority for approval. According
to Section 7 of Law. No. 95, after its approval, the annual federal budget is to be published in
the Official Gazette thereby making it available to the public98.

The MSG has come to an understanding that all state revenues are included in the federal
budget, except for revenues generated from the sale of crude oil and gas produced by the
Kurdistan Region. This is explained in the subsequent sections, as follows:

i. Federal Government petroleum revenues:

According to Section 5 of the Financial Management and Public Debt Law No. 95 of year 2004
(as amended), all petroleum revenues shall be recorded in the federal budget as follows:

Section five (Management of Petroleum Revenues):

“1) All proceeds from the sale of petroleum or otherwise derived from current and
prospective petroleum extraction, including from the federal government’s production
shares and royalties, and from the amounts paid in respect of a right to explore for
petroleum resources, and any amounts derived from the investment of amounts in the
petroleum revenue account, shall accrue to the budget. Except as provided in paragraph
2 of this section, below, or as may otherwise be required by applicable United Nations
Security Council Resolutions (UNSCRs), the receipts from the export of petroleum shall
be deposited into the Development Fund for Iraq (DFI) account, or a successor account
to the DFI, hereafter generically referred to as the petroleum revenue account, and
reflected accordingly as receipts and transfers to and from the budget.”

“2) Pursuant to United Nations Security Council Resolution No. 1483 (2003), and
subsequent related UNSCRs, five percent (or any other percentage as may be
determined by the United Nations Security Council or jointly by the internationally

98
http://www.mof.gov.iq/pages/ar/FinanceAdministrationLaw.aspx
140
 recognized, representative government of Iraq and the Governing Council of the United
Nations Compensation Commission in accordance with UNSCR 1483) of the receipts
from the export of petroleum shall be transferred to the Compensation Fund established
in accordance with UNSCR 687 (1991) and subsequent relevant UNSCRs, and the
balance of receipts from the export of petroleum shall be deposited into the petroleum
revenue account. These transfers to the Compensation Fund shall be shown in the
budget.”

The following diagram provides a practical illustration of how revenues from the export sales of
petroleum, petroleum products and natural gas are deposited in the accounts maintained by the
Iraqi Government, and are subsequently distributed:

Diagram 2: Oil and gas sector revenue flows in Federal Iraq

All proceeds from Iraq’s export sales of petroleum, petroleum products and natural gas are
deposited in an Oil Proceed Receipt Account (OPRA), an account held at the Federal Reserve
Bank of New York (FRBNY) for the Central Bank of Iraq (CBI). 95% of these proceeds are required
to be deposited in the Development Fund for Iraq (DFI) account held at the FRBNY. The
remaining 5% of oil export proceeds should be deposited into a UN Compensation Fund
established under UN Security Council Resolution 687 of 1991 and subsequent relevant
resolutions, in accordance with the UN Security Council Resolution No. 1483 of 200399. The DFI

99
http://unscr.com/en/resolutions/doc/1483

141
 funds are subsequently transferred to a Ministry of Finance account held at the CBI, from which
the funds are distributed in accordance with the allocations set out in the Federal Budget.

During the year 2016, there were no transfers made by Iraq to the UN Compensation Fund. This
is due to the adoption of UN Compensation Commission decisions No. 272 (2014), 273 (2015)
and 274 (2016), under which Iraq's requirement to “deposit five per cent of the proceeds from
all export sales of petroleum, petroleum products and natural gas and five per cent of the value
of non-monetary payments of petroleum, petroleum products and natural gas made to service
providers into the Compensation Fund”, have been postponed since 1 October 2014. The
postponement of such transfers was granted by the Government of Kuwait due to the difficult
security circumstances in Iraq100.

ii. Cooperation between the Federal Government and the KRG:

The Federal Budget Act estimates fixed revenue contribution figures from the KRG's crude oil
exports as mentioned hereunder, in return for a 17% share of the total Iraqi budgeted revenues.
For the year 2016, the Federal Budget Act estimates a fixed contribution of 250,000 bpd
produced by KRG, and 300,000 bpd produced by Kirkuk. However, in effect, the KRG did not
transfer the budgeted contribution of oil export revenue to the federal government in 2016,
and accordingly, the 17% KRG budgetary allocation was not transferred to the KRG.

100
https://uncc.ch/sites/default/files/attachments/81%20close.pdf

142
Federal Budget audit

Section 11 (Article 6) of the Financial Management and Public Debt Law No. 95 of year 2004
(as amended), requires the Minister of Finance to prepare and submit annual final accounts of
the federal budget to the Federal Board of Supreme Audit (FBSA) by 15 April of the succeeding
year, for external audit. The FBSA is required to prepare an audit report on the final accounts
by 15 June, and the Council of Ministers shall submit the final accounts and the related audit
report to the body vested with national legislative authority on 30 June (in practice, the national
legislative authority is the Council of Representatives (CoR)) .

According to FBSA, the annual final accounts of Iraq for years 2014 up to 2017 have not been
audited to date. This is because of a delay in submitting the final accounts for 2014 due to the
absence of an approved federal budget for the year 2014 to date (as of 18 October 2018),
despite the existence of budgets for subsequent years. The final accounts of 2014 have been
submitted and their audit by the FBSA is in progress. As for the subsequent years, the final
accounts have not been yet been submitted to the FSBA, as they have not yet been completed,
as of 18 October 2018, by the Ministry of Finance. Consequently, the annual final accounts for
the years 2014 through 2017 have not been approved by the CoR. The importance of issuing
the final accounts lies in the fact final accounts are a representation of actual implementation
of the federal budget and thus displays how the state departments have spent the funds
allocated and funded by the Ministry of Finance.

DFI account audit

In accordance with Article 12 of the UN Council Resolution, the DFI account is to be audited by
independent public accountants approved by the International Advisory and Monitoring Board
of the Development Fund for Iraq.

According to 2016 DFI audited financial statements, the total export sales of petroleum was in
thousand USD 30,684,570 (Refer to Annex 13) while the figure reported by SOMO for the same
year was in thousand USD 43,622,928 as shown in the table below:

Total export sales as Total export sales as

Difference
per DFI report reported by SOMO (Thousand USD)
(Thousand USD) (Thousand USD)

30,684,570 43,622,928 12,938,358

143
Details of this difference is as follows:
Thousand
USD
Total export sales as reported by SOMO 43,622,928
Value of crude oil shipments lifted by IOCs (12,399,270)
Value of crude oil shipments lifted by GS CALTEX
(344,658)
for Karbala Refineries
Value of crude oil shipments lifted by ENI for
(194,430)
Partnership contracts
Total export sales/ DFI report 30,684,570

144
5.2. Insight in to the Federal Budget of 2016

The Federal Budget Act for 2016 was approved in January 2016, and forecasts a total revenue
of IQD 81.7 trillion (approximately USD 69.12 billion). Revenue from the export of crude oil was
estimated at IQD 69.773 trillion (approximately USD 59 billion) at an estimate export rate of
3.6 million barrels per day (bpd) and an average price of USD 45 per barrel. This figure includes
an estimate contribution of 250,000 bpd from the exported crude oil produced by KRG, and
300,000 bpd produced by Kirkuk.

The following table presents the 2016 federal budget forecast revenue, expenditure and
financing figures. Budget oil revenues amounting to IQD 69. 773 billion represent 85.4 of total
budget revenue. The total budget expenditure for 2016 amounted to IQD 105.896 billion, with
75.7% of total expenditures allocated to current expenditures, and 24.3% allocated to capital
expenditures.

Amount
Budget Estimates
(Thousand IQD)
Total Revenue 81,700,803,138
Oil Revenue 69,773,400,000
Non-Oil Revenue 11,927,403,138
Total Expenditures 105,895,722,619
Current Expenses 80,149,411,081
Capital Expenses 25,746,311,538
Planned Deficit 24,194,919,481
Financing the Deficit

Account balances of ministries and non-ministry related entities at government banks 3,188,518,624

Islamic Development Bank loan 590,000,000

Issuance of foreign bonds 2,360,000,000
Japan International Cooperation Agency (JICA) loan 592,000,000
Issuance of public debt bonds to the public 5,000,000,000
Issuance of bonds and transfers of treasury funds to government banks, deducted from the
7,000,000,000
Central Bank of Iraq

Loan from JICA for budget support 284,000,000

Transfers of treasury funds and loans from commercial banks 5,121,400,857

World Bank loan 59,000,000

Source: Federal Budget Act 2016

145
Analysis of capital budget expenditures:

Capital expenditures are divided into three categories, as follows:

i. Investment projects expenditure: This represents amounts allocated to finance
infrastructure projects and other projects, which are transferred to the various
Ministries, who implement such projects through third party contractors.
ii. Governorate Development Program expenditures: This represents amounts allocated
to governorates under the Government Development Program (including Kurdistan
Region provinces), which are distributed in accordance with an estimate of each
governorate’s population. The local government of each governorate is responsible for
implementing such development projects.
iii. Petrodollar allocations: This represents amounts allocated to oil-producing
governorates, where each oil-producing governorate receives a premium for each
barrel of crude oil produced or refined, and for natural gas produced within its borders.

Subnational transfers (Governorate Development Program and Petrodollar allocations) are

further discussed in the following section of this report (Section 5.3).
The following table presents a breakdown of capital expenditure, which includes budgeted
allocations to governorates for the fiscal year 2016:

Amount Percentage of
Type
(Billion IQD) Capital Expenditure

Investment projects expenditures 23.416 91.0%

Governorate Development Program expenditures 1.244 4.8%
Petrodollar Allocations 1.086 4.2%
Total 25.746
Source: Federal Budget Act 2016

Analysis of current budget expenditures (operational expenses):

The following table presents a breakdown of 2016 budgeted current expenditure, as follows:

Percentage of
Type Amount (Billion IQD) Current
Expenditure
Salaries for workers in the country including the security forces 39.145 48.8%
Social welfare 17.704 22.1%
Commodity expenditure 4.506 5.6%
Service expenditures 2.127 2.7%
Maintenance expenditure 0.522 0.7%
Capital goods expenditure 0.270 0.3%
Grants, debt servicing and contributions 14.519 18.1%
External contributions and aids 0.657 0.8%
Special programs 0.700 0.9%

Total 80.150
Source: Federal Budget Act 2016

146
5.3. Subnational transfers (Requirement 5.2)

According to the MoF, there are only two types of subnational transfers, whereby each
governorate's share from the federal budget comes in two tranches: the petrodollar’s allocation
and the governorate's share in the Governorates Development Program.

5.3.1. Petrodollar allocations and transfers

The below is a description of the methodology applied by the MoF for calculating petrodollar
allocations (as presented by the MoF):

- Petrodollar allocations are calculated in accordance with Article 2 (1) of the Federal
Budget Act for year 2016. Article 2 (1) of the federal budget provides that the amount
of USD 5 shall be allocated for every barrel of crude oil produced in the governorate,
and, USD 5 for every barrel of crude oil refined in the governorate refineries, and USD
5 of each 150 cubic meters of natural gas produced in the governorate. According to
the Law, each governorate has the discretion to select from the revenue producing
methods above.
- The quantities of crude oil produced, refined, and gas produced by governorate for the
respective year are presented by the Ministry of Oil – Technical Directorate, and are
verified by the relevant national oil companies.
- The disclosed quantities are then sent to the regulatory departments of the related
producing governorates, for audit and matching purposes. In case differences are
identified, the Ministry of Oil is contacted to address such differences and to work on
reaching final quantities to be reported to the committee formed under the Executive
order No. 9048 on 19 July 2018 for the purpose of validating the petrodollar
calculation.
- The Ministry of Finance, the Ministry of Oil and the Ministry of Planning are informed of
the calculations and are provided with statements showing the quantities sold from
crude oil, refined oil or gas produced, for each producing governorate and according to
the respective revenue producing method selected by the governorates.

147
The following table presents the petrodollar allocations calculated by the MoF in accordance
with the process described above, the actual petrodollar transfers made, and the differences
between allocated and transferred petrodollar amounts for year 2016:

Amounts
Petrodollar Actual Amount allocated but
Petrodollar Actual Amount
Allocations transferred not
Governorate Allocations transferred
(USD (USD transferred
(IQD) (IQD)
equivalent) equivalent) (USD
equivalent)
Al-Basrah 231,170,265,000 160,000,000,000 195,575,520 135,363,790 60,211,730

Al-Muthanna 705,463,000 - 596,838 - 596,838

Karbala - - - - -

Al-Najaf 2,500,000,000 - 2,115,059 - 2,115,059

Salah Al-
- - - - -
deen
Ninawa 9,116,276,000 - 7,712,585 - 7,712,585

Dhi Qar - - - - -

Al-Diwaniyah 3,564,048,000 - 3,015,269 - 3,015,269

Babel - - - - -

Wasit - - - - -

Al-Anbar 5,757,076,000 - 4,870,623 - 4,870,623

Diyala - - - - -

Baghdad 19,833,004,200 - 16,779,191 - 16,779,191

Maysan - - - - -

Kirkuk - - - - -

Total 1,645,730,847,621 160,000,000,000 1,392,327,282 134,861,767 95,301,296

Source: Ministry of Finance

According to the Accounting Directorate at MoF, the difference between allocated and
transferred petrodollar amounts is due to the following:
a. The allocated amounts were not claimed by the concerned governorates, or;
b. The MoF did not receive a letter from the MoP instructing it to transfer the
allocated amounts.

148
 5.3.2. Governorates’ Development Program Allocations and transfers

The purpose of the Governorate Development Program is to finance the reconstruction

projects of all governorates in Iraq, including those within the KRG. The Federal Budget Act
determines an amount for the Governorate’s Development Program, which is distributed to
the governorates in accordance with an estimate of the population of each governorate.

As stipulated in the Federal Budget Act for 2016, the governor in each governorate must submit
a development plan for the governorate to the Ministry of Planning (including its districts and
sub-districts), approved by the provincial council. The MoP assesses and approves the submitted
plans, taking into consideration the most affected areas within the governorate. Once the
Ministry of Planning approves the plan, the allocations are distributed internally by the
governorates based on districts and sub-districts’ relative population size, after setting aside
amounts allocated for strategic projects that benefit more than one area or district, given that
strategic projects costs do not exceed 20% of the total GDP allocation to the
province/governorate.

According to the MoF, no allocations were made to the KRG governorates during 2016 and
2017, as no plans were submitted by the KRG governorates to the MoP.

The following table presents the governorate development allocations calculated by the MoF,
the actual transfers made, and the differences between allocated and transferred governorate
development amounts for year 2016:
Governorates' Actual Amounts
Governorates'
Actual Amount Development Amount allocated but
Development
Governorate transferred Allocation transferred not transferred
Allocation
(IQD) (USD (USD (USD
(IQD)
equivalent) equivalent) equivalent)
Al-Basrah 733,428,955,398 5,000,000,000 620,498,270 4,230,118 616,268,152
Al-Muthanna 33,111,832,000 - 28,013,394 - 28,013,394
Karbala 32,918,825,844 1,851,745,148 27,850,106 1,566,620 26,283,486
Al-Najaf 55,407,040,000 - 46,875,668 - 46,875,668
Salah Al-deen 48,148,561,923 15,700,000,000 40,734,824 13,282,572 27,452,252
Ninawa 61,343,356,098 10,949,500,000 51,897,932 9,263,536 42,634,396
Dhi Qar 107,286,195,278 3,113,500,000 90,766,663 2,634,095 88,132,568
Al-Diwaniyah 58,610,900,000 938,039,000 49,586,210 793,603 48,792,607
Babel 72,438,949,810 12,740,986,168 61,285,068 10,779,176 50,505,892
Wasit 99,729,332,057 2,808,698,450 84,373,377 2,376,225 81,997,152
Al-Anbar 66,346,931,414 46,500,000,000 56,131,076 39,340,102 16,790,974
Diyala 50,520,384,672 5,859,035,800 42,741,442 4,956,883 37,784,559
Baghdad 271,918,350,000 32,696,602,307 230,049,365 27,662,100 202,387,265
Maysan 92,679,340,000 - 78,408,917 - 78,408,917
Kirkuk - - - - -
Total 1,783,888,954,494 138,158,106,873 1,509,212,312 116,885,030 1,392,327,282
Source: Ministry of Finance

149
According to the Accounting Directorate at MoF, the difference between allocated and
transferred governorate development amounts is due to the following:
a. The allocated amounts were not claimed by the concerned governorates, or;
b. The MoF did not receive a letter from the MoP instructing it to transfer the
allocated amounts.

150
5.4. Recent and Ongoing Financial Reforms

The following information was obtained from the Ministry of Finance Open Budget System
website:

The Open Budget System (OBS)

The Ministry of Finance, in cooperation with the World Bank, has established the Open Budget e-
Portal with the aim of making it easy for citizens to access federal budget information, as well as
promoting governmental policy in an attempt to support transparency and open governance. In
addition to having a direct effect on combating corruption, the portal is expected to contribute
to the improvement of the state's financial performance. The data currently on the portal
provides a detailed presentation of the public resources, government expenditures and public
treasury accounts for years 2015 to 2017, allowing the open budget portal user to access
detailed financial data on revenues, expenditures and public debt of the Republic of Iraq101.

According to the OBS website, open budget documents used and uploaded include:

 Pre-budget statement: presents expected total revenues, levels of expenditures and debts,
and sectors’ allocations.
 The executive budget proposal: The government’s detailed plans on priorities of policies, and
ministries and departments’ allocations for the next year.
 The enacted budget: legal documents that empower the executive authority to implement
organizational procedures of the budget.
 The in-year reports include data of the revenues collected, actual expenditures, and debts
accrued within a specific period.
 The mid-year report includes data of the actual budget for the first six months of the year
(revenues, expenditures, debts) for evaluating the assumptions upon which the budget has
been prepared, and modifying budget figures accordingly for the remaining six months.
 The year-end report includes the position of the governmental accounts at the end of the
fiscal year, which includes - ideally - an evaluation of the progress made into achieving the
objectives mentioned in the enacted budget.
 The audit report includes the evaluation of the board of supreme audit of the government’s
financial performance in the past budget year.
 The citizen budget and it is a simplified version of the budget that is used for non-technical
purposes and made in very clear understandable form to make it easy for citizens to grasp
the government’s plans and actions and allows for their feedback for the next fiscal year.

101
http://www.mof.gov.iq/obs/en/Pages/about.aspx

151
 6. Social and economic spending
Social expenditures are contributions made by international oil companies operating in the
extractive industries to the public, specifically to the areas surrounding oil fields, which are
negatively impacted by the activities of the extractive sector. These contributions are made with
the purpose of improving the standard of living, and the economic and social well-being of the
impacted areas. There are two types of social expenditures in Iraq:
- Social contributions mandated through legislation or contracts with the government -
mandatory social expenditures (details of mandatory social expenditures are described
in Section 6.1 below)
- Social contributions made at the discretion of the international oil companies - voluntary
social expenditures (details of voluntary social expenditures are described in Section
6.2 below)

6.1. Mandatory social expenditures (Requirement 6.1)

There are two types of mandatory social expenditures in Iraq, which are the following:

i. International oil companies’ social expenditures mandated by the Council of Minister’s

Energy Committee:

As per the Council of Minister’s ) Energy Committee( Resolution Number 139 of 23 December
2013, international oil companies working in Iraqi fields are obliged to pay an annual amount of
up to USD 5 million per service contract, as social benefits to the areas surrounding fields and
exploration blocks in which they operate. According to the resolution, these expenses are to be
recorded under the contractors’ recoverable petroleum costs, and are therefore, reimbursed to
the contractor. Mandatory social expenditures incurred by IOCs are made in direct coordination
with the local governorates and national oil companies.

The MSG has determined that the value of mandatory social expenditures made by IOCs during
2016 are not material, as compared with total extractive sector revenue (payments made
account to less than 1% of total extractive sector revenues) . Therefore, such payments have
not been included in the scope of reconciliation. For the purpose of this report, disclosure of
mandatory social expenditures was requested from the International oil companies operating in
Iraq under technical service contracts (specifically the field operators). However, in instances
where IOCs did not report the social expenditures made during 2016; the information reported
by field license holders (national oil companies) on behalf of the IOCs was presented. Such
information was provided by the NOCs based on social expenditure reporting made to them by
the IOCs. The following table represents the mandatory social expenditure reporting status for
all active licenses during year 2016 (1st to 4th licensing round fields):

152
Field/Block Operator Mandatory Social Expenditures
Missan Fields
Mandatory social expenditure information was reported by the
(Abu Gharib, CNOOC Iraq
filed operator
Buzurgan, Fauqi)
Petrochina Mandatory social expenditures were reported by the field
Halfaya International FZE operator
Iraq

Qaiyarah Sonangol According to a letter from North Oil Company (license holder
of Al-Najmah and Qaiyarah fields), both fields were not
operational during years 2016 and 2017, and resumed
Najmah Sonangol operations in February 2018

According to Midland Oil Company (license holder for Ahdeb

Al-Waha field), no mandatory social expenditures were made by the
Ahdeb
Petroleum operator of Ahdeb field in 2016 due to a delay in announcing
social projects

Zubair ENI B.V Mandatory social expenditures were reported by the operator
Mandatory social expenditures were reported by Midland Oil
Company (license holder of Badra field), on behalf of the field
Gazprom Neft
Badra operator. We did not receive information directly from the
Badra B.V
contractor in relation to mandatory social expenditures, and
therefore, relied on information presented by MdOC
PETRONAS Iraq Mandatory social expenditures were reported by the
Garraf
Garraf operator
KOGAS Akkas, the operator of Akkas field declared that no
mandatory social expenditures were made by the company
during the year 2016. This was also confirmed by Midland Oil
Akkas KOGAS Akkas
Company (license holder for Akkas field), who stated that field
operations were suspended during 2016 due to the security
situation in Iraq

According to Midland Oil Company (license holder for

Mansuriya field), no mandatory social expenditures were
Mansuriya TPAO made by the contractor of Mansuriya field due to the
suspension of field operations during 2016 resulting from the
security situation in Iraq

Pakistan Petroleum Ltd, the operator of Exploration Block 8,

Pakistan declared that an amount of USD 400,034 was allocated to
Block 8
Petroleum Ltd mandatory social expenditures during 2016, but there were
no payments actually made during the year.
British Petroleum
Rumaila Mandatory social expenditures were reported by the operator
(BP)

Mandatory social expenditures were reported by the Basra Oil

Company (license holder of West Qurna Phase 1), on behalf of
West Qurna
ExxonMobil the operator. We did not receive information directly from
(Phase 1)
ExxonMobil, and therefore, relied on information presented by
BOC

153
 Field/Block Operator Mandatory Social Expenditures

According to a letter from Basra Oil Company (license holder

for West Qurna – Phase2), dated 22 May 2018, sent to the
West Qurna LUKOIL Mid-East
Ministry of Oil – Internal Control Directorate, the West Qurna –
(Phase 2) Ltd
Phase 2 Operator (LUKOIL Mid-East Ltd) did not incur any
recoverable social expenditure (as of the date of the letter)

Mandatory social expenditures were reported by the Basra Oil

Company (license holder of Majnoon field), on behalf of the
Majnoon Shell
operator (Shell). We did not receive information directly from
Shell, and therefore, relied on information presented by BOC
According to Basra Oil Company (license holder for Siba gas
field), Kuwait Energy Co , the operator of Siba has obtained
Kuwait Energy
Siba the Ministry of Oil’s approval for postponing making any social
Co.
expenditure until initial commercial production of the field has
been achieved
LUKOIL Overseas
The filed operator declared that no mandatory social
Block 10 Iraq Exploration
expenditures were made during the year 2016
(LOIE)
Kuwait Energy The filed operator declared that no mandatory social
Block 9
Co. expenditures were made during the year 2016

Social expenditure information was not reported by either the

Block 12 Bashneft IOC or the field license holder (Block 12 is still in exploration
phase, mandatory social expenditures would not be due)

The following tables represent the mandatory social expenditures reported by the IOCs/national
oil for the year 2016:

Funds Recipient/ Amount

Field Field Operator Project Beneficiary
Contractor (USD)

Missan Amara-Musharah road

CNOOC Iraq - Missan Oil Company 50,000
fields maintenance

Source: This information was provided by CNOOC Iraq

Field Funds Recipient/ Amount

Field Project Beneficiary
Operator Contractor (USD)
Construction of 8
Liqaa AL-Ashiqaa
classrooms for Janat Al - 314,933
For Contracting
Burjazia School
Supply of school furniture
including computers,
Roaa Milan
Zubair ENI B.V printers, and various
- Company for 578,948
electrical devices for 15
Trading
schools in El Marbid & AL
Burjazia
Electric Works for AL AL-Emaraa AL-
- 12,280
Burjazia School Mutaaleqa
Total 906,161
Source: This information was provided by Eni B.V

154
 Field Funds Recipient/ Amount
Field Project Beneficiary
Operator Contractor (USD)
Repairing access road to Community
Petrochina
Ashab Al-Husain School Primary School
Halfaya International - 15,210
along 1,200m near PCH (Ashab Al-Husain
FZE Iraq
Basecamp School)
Source: This information was provided by Petrochina International FZE Iraq

Funds Recipient/ Amount

Field Field Operator Project Beneficiary102
Contractor (USD)

West Qurna - - - 400,000

ExxonMobil
(Phase 1)

Source: This information was provided by Basra Oil Company

Funds
Field Amount
Field Project Beneficiary Recipient/
Operator (USD)
Contractor
Al Khora Community,
AMAR ICF, Basra
Basra Directorate of - 13,646
Directorate of Health
Health
Al Khora/North Rumaila
Communities, Rumaila
AMAR ICF, Rumaila
Community Committee, - 16,318
Community Committee
External Government
Stakeholders
Khor Zubair Training
Al Khora Community,
Centre, AMAR ICF, Basra
Basra Directorate of
Directorate of Education, - 757,194
Education, Basra
Basra Directorate of
Directorate of Health
Health
Rumaila Operating
AMAR ICF - 27,500
Organization
Al Khora Community,
Al Hilu Company, AMAR
Basra Directorate of - 440,209
ICF
Health
British
Al Khora Community,
Rumaila Petroleum AMAR ICF, Basra
Basra Directorate of - 232,015
(BP) Directorate of Health
Health
Al Khora Community,
Al Hilu Company, AMAR
Basra Directorate of
ICF, Basra Directorate of - 707,556
Health, Basra Directorate
Health
of Water
North Rumaila
AMAR ICF, Basra
Community, Basra - 21,232
Directorate of Health
Directorate of Health
Al Khora/North Rumaila
Manhel Al Basra Company,
Communities, Qarmat Ali
Al Manar Company, AMAR - 283,037
Local Council, Basra Oil
ICF
Company
Al Khora Community,
AMAR ICF Basra Directorate of - 48,151
Education
North Rumaila
Al Fares United Company,
Community, Basra Oil - 248,250
AMAR ICF
Company
Total 2,795,108
Source: This information was provided by BP

102
According to a letter from ExxonMobil to Basra Oil Company dated 27 February 2018, ExxonMobil has been working with Basra Oil
Company to serve West Qurna 1 community in the areas of Health and Education, since WQ1 project inception.

155
 Field Funds Recipient/ Amount
Field Project Beneficiary
Operator Contractor (USD)
Building a secondary
Basra Directorate Amar Charitable
Majnoon Shell school for girls in Al- 658,111
of Education Foundation
Nashwa area
Source: This information was provided by Basra Oil Company

Field Funds Recipient/ Amount

Field Project Beneficiary
Operator Contractor (USD)
Developing the electrical
Gazprom Neft
Badra network for Badra and Wasit Governorate - 5,996,088
Badra B.V
Jassan areas
Source: This information was provided by Midland Oil Company

Field Funds Recipient/ Amount

Field Project Beneficiary
Operator Contractor (USD)
Equipping the University
Sumer University IT
of Sumer - Kala'at Sukkar - 17,900
College
Garraf Petronas Iraq with Internet network
RO Water Distribution Community within
- 67,237
Project Garraf Oil Field
Total 85,137
Source: This information was provided by Petronas Iraq

ii. According to Article 11 of the Public Companies Law No. 22 of 1997 (as amended), state-
owned entities are required to pay 5% of net profit on social projects. These amounts are
paid directly by the national companies, and are allocated as follows:
- 25% to be paid to the Health Insurance Fund
- 20% to be paid to the Social Security Fund
- 20% to support the MoO Guest House (which is used to create the necessary
accommodation and hospitality for oil sector delegates, official visitors, and
foreign delegations) and the Oil Cultural Center (60%:40%, respectively)
- 5% to support sports clubs in Iraq
- 15% to support residential investment projects in Iraq
- 15% to be allocated to various social initiatives (such as the construction of
schools and nurseries, and support of social service projects)

The MSG has determined that the value of mandatory social expenditures (social contributions)
made by the national companies during the year 2016 is immaterial, as compared with the total
extractive sector revenues, and has therefore decided to exclude such payments from the scope
of reconciliations.

The only mandatory social expenditures in the mining sector are the 5% payments made by
profitable SOEs. Since there was only one profitable mining sector SOE during 2016, only one
payment was expected. However, this information is not disclosed in the report as it was not
readily available by the mining SOE.

156
The following table represent the amounts reported by the extractive SOEs for the year 2016:

Social
National Oil
expenditures Comment
Company
(IQD)
No social expenditures were made by the MOC, as its final
MOC -
accounts were not approved by the FBSA during the year 2016
No social expenditures were made by the BOC, as its final
BOC -
accounts were not approved by the FBSA during the year 2016
MdOC 439,606,972 -

NOC 3,522,801,324 -
Source: This information was provided by the respective NOCs

The following table presents a breakdown of the amounts paid by North Oil Company during the
year 2016. However, these payments are reported on a cash basis and therefore do not
necessarily represent amounts accrued during the year 2016:

Amounts paid
Payment purpose
(IQD)
Health Insurance Fund 1,068,070,247
Social Security Fund 143,503,615
MoO Guest House and the Oil Cultural Center 236,455,309
Amount paid in support of sports clubs in Iraq 323,836,779
Amount paid in support of residential investment projects in Iraq 571,510,335
Various social initiatives 1,179,425,039
Total 3,522,801,324
Source: This information was provided by NOC

The following table presents a breakdown of the amounts paid by Midland Oil Company during
the year 2016. However, these payments are reported on a cash basis and therefore do not
necessarily represent amounts accrued during the year 2016:

Amounts paid
Payment purpose
(IQD)
Amounts paid in support of company employees 5,248,000
Health Insurance Fund 434,358,972
Total 439,606,972
Source: This information was provided by MdOC

157
6.2. Voluntary social expenditures

Voluntary social expenditures are social expenditures made at the discretion of the IOCs.
Voluntary social expenditures are non-recoverable expenditures, which are referred to in the
service contracts (Annex C) as “any costs, charges or expenses including donations relating to
public relations or enhancement of Contractor’s corporate image and interests”.

The MSG has agreed that the value of voluntary social expenditures made by IOCs during 2016
are not material, as compared with the total extractive sector revenues. Therefore, for the
purpose of this report, voluntary social expenditures are unilaterally reported by the IOCs.

The below table represents voluntary social expenditure made by LUKOIL Mid-East Ltd in the
interest of local communities to enhance the operator’s image in accordance with Article 10.4
of Annex C of the DPSC (for year 2016). According to a statement included by LUKOIL Mid-East
Ltd, the projects implemented are according to the Agreement signed in August 2011 and
December 2012 between LUKOIL Mid-East Ltd and Medaina, Qurna and Eiz El-Deen Saleem
administrations for cooperation in the field of education, healthcare, and sport. Based on this
agreement LUKOIL Mid-East Ltd only funded the realization of these social projects while the
Administrations were dealing with the tendering, contractor selection process, contract signing,
use of funds, and project implementation control. All projects were carried out by local
companies and local workforce, which is one of the agreement conditions.

Amount
Contractor Field Project Beneficiary Funds Recipient / contractor
(USD)

Rehabilitate and
develop the multi- Al-Areka Company for Trading
Eiz El-Deen
use playground in Agency and General Trading Ltd
Saleem 126,000
Eiz El-Deen Saleem (a local company from Eiz El-
citizens
Youth and Sport Deen Saleem)
Forum

West Supply of various

LUKOIL Al-Safeer Al-Turkey for
Qurna toys to three Eiz El-Deen
Mid-East Furniture and Kids Toys (a local
(Phase kindergartens in Eiz Saleem 18,429
Ltd company from Eiz El-Deen
2) El-Deen Saleem Sub- citizens
Saleem)
district

Supply of drinking
water to 36 school
Eiz El-Deen Al-Kawthar Water Station (a
buildings in Eiz El-
Saleem local company from Eiz El-Deen 5,600
Deen Saleem Sub-
citizens Saleem)
district, during the
school year

Total 150,029

Source: This information was provided by LUKOIL Mid-East Ltd

158
 The following table presents the voluntary expenditures made by Kuwait Energy during 2016,
in relation to Siba field:

Funds Recipient / Amount

Contractor Field Project Beneficiary103
contractor (USD)

Distributed 150 pieces of

- 3,000
clothing to Siba orphans during
Eid Al-Fitr

Siba community
Kuwait Energy Siba Primary school and Siba town HALI -
hall refurbishment

Restoring Merah Al-Tofoola UNHCR -

Nursery

Total 3,000
Source: This information was provided by Kuwait Energy

The following table presents the voluntary social expenditures made by Petronas Iraq during
2016 in relation to Garraf and Majnoon fields:

Funds Recipient / Amount

Contractor Field Project Beneficiary
contractor (USD)
1. PETROSAINS (Creative
Science and Math Workshop)
2. Embracing Ramadan’ food
distribution to 750
underprivileged families
3. Maukib set-up during
Arba’een for pilgrimages
4. HSE awareness program
at 9 Schools
Garraf Community - 67,699
5. Improvement of Health-
care clinics
6. Improvement of school
Petronas Iraq facilities
7. Providing equipment to IT
laboratory, Sumer University
8. Distribution of winter
clothing to Garraf School
Children
1. Mobile health clinics
2. The Women Volunteers
3. Primary school road
Majnoon safety education Community - 162,612
4. Livelihood projects
5. Distribution of Eid parcels
for children
Total 230,311
Source: This information was provided by Petronas Iraq

The following companies all declared that no voluntary social payments were made during the
year 2016:

103
According to a letter from ExxonMobil to Basra Oil Company dated 27 February 2018, ExxonMobil has been working with Basra Oil
Company to serve West Qurna 1 community in the areas of Health and Education, since West Qurna 1 project inception.

159
 - KOGAS Akkas (the operator of Akkas field);
- Pakistan Petroleum Ltd (the operator of Exploration Block 8);
- Kuwait Energy (operator of Block 9);
- Inpex (contractor for Block 9);
- CNOOC Iraq (operator of Missan fields);
- BP (operator of Rumaila)

JAPEX (contractor in Garraf field) reported that all social expenditures are made by the
operator. The remaining IOCs did not report on whether any voluntary social expenditures were
made during 2016.

6.3. Quasi Fiscal expenditures (Requirement 6.2)

The International Monetary Fund (IMF) defines quasi-fiscal activities as fiscal activities that are
“often introduced by simple administrative decision, are not recorded in budgets or budget
reporting, and typically escape legislative and public scrutiny. They are introduced by
governments to achieve a variety of objectives, such as promoting certain activities,
redistributing income or collecting revenue.” 104

According to the MSG, quasi-fiscal expenditures are not applicable in Iraq.

104
https://www.imf.org/external/np/fad/trans/manual/sec02a.htm

160
6.4. Economic Contribution of the Extractive Industries on the Iraq
Economy (Requirement 6.3)

6.4.1. Overview of the Iraqi economy in 2016

Iraq has been impacted by two crises since 2014: the ISIS insurgency, and the steep decline in
global oil prices105. The ISIS insurgency since mid-2014 has left millions of people internally
displaced, and caused significant destruction to assets and infrastructure leading to
disruptions in production and in trade routes.

The low crude oil prices in 2016 resulted in an average selling price of USD 35.5 per barrel
compared to USD 45 estimated in the 2016 Federal Budget Act. While the quantities of crude
oil exports have increased by 10.18% in 2016 from 2015, the total revenue generated from
crude oil exports have decreased, which means that the quantity of crude oil exports
increased at a lower rate than the decrease in crude oil prices.

The Government has responded to these crises with a mix of fiscal adjustment, financing, and
structural reforms to stabilize the economy, protect social spending and public service
delivery106.

6.4.2. The volume of extractive industries as absolute value and as a

percentage of GDP for the year 2016
The following table displays the changes in GDP indicators from year 2015 to year 2016, based
on MoP preliminary estimates for the year 2016. The table shows that despite the slight
increase in GDP, the GDP per capita has decreased, which indicates that the GDP has increased
at a lower rate than the increase in population.

Economic Indicator 2015 2016 % change

Gross Domestic Product at basic

199,715.70 203,869.80 2.08%
current prices (billion IQD)

Gross Domestic Product at basic

171.1 172.5 0.81%
current prices (billion USD)
GPD per capita at current prices
5671.7 5636.6 -0.62%
(000 IQD)
GPD per capita at current prices
4.9 4.8 -2.04%
(000 USD)
107
Source: Ministry of Planning

105
http://www.worldbank.org/en/country/iraq/publication/economic-outlook-spring-2016
106
http://www.worldbank.org/en/country/iraq/publication/economic-outlook-fall-2016
107
http://www.cosit.gov.iq/documents/national_accounts/national_income/reports/gdp/‫الق‬20%‫والدخل‬20%‫المحل‬20%‫للناتج‬20%‫الفعلية‬20%‫ات‬
‫ي‬ ‫التقدير‬
202016%‫لسنة‬20%‫وم‬
‫ ي‬.pdf
161
The following table was presented by the Ministry of Planning, and is based on annual
preliminary estimates for the year 2016. According to the below table, Iraq’s extractive sector
contributes to the Country’s total estimate GDP by IQD 61,361,951.5 million which translates
into 29.83% of total GDP.

Relative share of GDP (at

Economic Activities Million IQD
basic current prices)
Agriculture, forestry, hunting & fishing 7,832,046.90 3.81%
Mining and quarrying: Crude oil 60,965,276.90 29.64%
Mining and quarrying: Other types of mining 396,674.60 0.19%
Manufacturing industry 4,118,518.50 2.00%
Electricity and water 6,334,599.20 3.08%
Building and construction 19,170,772.80 9.32%
Transport, communications and storage 22,683,246.90 11.03%
Wholesale, retail trade, and hotels & others 19,780,800.40 9.62%
Finance, insurance, real estate and business services:
1,734,192.10 0.84%
Banks and insurance
Finance, insurance, real estate and business services:
14,379,154.50 6.99%
Ownership of dwellings
Social and personal services: General government 41,523,299.70 20.19%
Social and personal services: Personal services 6,760,921.00 3.29%
Total by activities 205,679,503.50
Less: Imputed bank service charge 1,809,671.30
GDP 203,869,832.20
Non-oil GDP 142,904,555.30
Source: Ministry of Planning

162
 6.4.3. Total government revenue from extractive industries for the
year 2016
Actual revenue figures during 2016 indicate that the extractive sector’s contribution to total
government revenue is 96.7%, as shown in in the table below:

Actual Revenue 2016

Revenue
(USD)

Crude oil export revenue 43,450,607,236

Corporate Income Tax (CIT) 534,835,453

State treasury share of SOE net profits 327,493,077

State partner shares in field remuneration fees 218,710,583

Total extractive sector revenue in Federal Iraq 44,531,646,349

Total Revenue in Federal Iraq 46,031,531,234*

Share of extractive sector revenue from total revenue 96.7%

 Actual revenues are reported by the Ministry of Finance on its OBS portal 108, and have
been converted to USD using the approved exchange rate of IQD 1,182 = USD 1.

1% Federal Government Revenue 2016

1%
3%
Crude oil export revenue
1%

Corporate Income Tax (CIT)

State treasury share of SOE net profits

State partner shares in field

remuneration fees

94% Other revenues

108
https://app.powerbi.com/view?r=eyJrIjoiYmFjMTM4NGEtYmQwOC00MDY3LThlMDgtYThhYjUzYWM1MjQxIiwidCI6IjU5NzAxNDZjLWM4YWU
tNDMyNy1iZDAxLTg3YjY2M2Y2NmUyYiIsImMiOjEwfQ%3D%3D

163
 6.4.4. Exports of extractive industries in terms of absolute value and
as a percentage of total exports for the year 2016

The following table presents the value of extractive industry exports compared with total
country exports, for the period from 2013 to 2016. Exports from the oil sector makes up the
majority of total exports. In combination with the limited commodity exports, this leaves the
Iraqi economy vulnerable to oil price fluctuations.

As displayed in the table below, crude oil and oil product exports for the year 2016 make up
99.79% of total exports in Iraq (excluding Kurdistan Region exports).

The following table also shows the continuing decrease in the value of crude oil exports from
the year 2013 to year 2016. While the quantities of crude oil exports have increased by 10.18%
in 2016 from 2015, the value of crude oil exports have decreased by 11.07%.

2013 2014 2015 2016

Commodity
Export Mill Mill Mill Mill
Bill (IQD) Bill (IQD) Bill (IQD) Bill (IQD)
(USD) (USD) (USD) (USD)
Crude oil 104,024.1 89,214.5 98,095.4 84,129.8 57,201.8 49,058.2 51,562.3 43,622.9
Oil
products
Regular - -
33.1 28.4 82.9 71.1 - -
fuel oil
Total 3.6 3.1
2.2 2 1.1 0.9 - -
products oil
Residue of 215.6 184.9
the 167 143.2 - - - -
distillation
Naphtha - - - - 94.6 81.1 71.9 60.8
Total oil
219.2 188.0 202.3 173.6 178.6 153.1 71.9 60.8
products
Commodity
402.2 339.4 241.5 202.7 230.5 191.2 108.3 90.3
export
Total
104,645.5 89,741.9 98,539.2 84,506.1 57,610.9 49,402.5 51,742.5 43,774.0
Exports
Source: Ministry of Planning

Crude oil export value

100,000.00
90,000.00 89,214.50
80,000.00 84,129.80
70,000.00
Million USD

60,000.00
50,000.00 49,058.20
40,000.00 43,622.90
30,000.00
20,000.00
10,000.00
0.00
2013 2014 2015 2016
Year

164
 6.4.5. Employment in extractive sector in the year 2016
The following table presents total number of employees in the MoO and its formations, for the
year 2016:

Employment in the Oil and Gas Sector (Federal Iraq)

# Entity Number of employees
1 Ministry HQ 1,332
2 Oil Exploration Company 1,990
3 Iraqi Drilling Company 8,185
4 Oil Pipeline Company 6,381
5 State Company for Oil Projects (Oil Projects Company) 3,362
6 Heavy Engineering Equipment State Company 2,178
7 State Oil Marketing Company (SOMO) 302
8 Gas Filling Company 7,013
9 Oil Products Distribution Company 22,516
10 South Gas Company 5,319
11 North Gas Company 3,384
12 South Refineries Company 7,249
13 North Refineries Company 9,928
14 Midland Refineries Company 6,878
15 Iraqi Oil Tankers Company 487
16 Basra Oil Company 28,864
17 North Oil Company 12,454
18 Midland Oil Company (MdOC) 2,711
19 ThiQar Oil Company 1,907
20 Missan Oil Company 4,699
21 Petroleum Research & Development Center (PRDC) 354
Total 137,493
Total number of employees in Iraq during 2016109 1,534,094
Percentage of employment in the oil and gas sector
(public and governmental entities), relative to the total 8.96%
number employment in Iraq during 2016

109
The total number of employees in Iraq was obtained from the MoP through the IEITI

165
 Employment in the oil and gas extractive SOEs
# Entity Number of employees
1 North Oil Company 12,454
2 Midland Oil Company (MdOC) 2,711
3 ThiQar Oil Company 1,907
4 Missan Oil Company 4,699
5 Basra Oil Company 28,864
6 Oil Exploration Company 1,990
Total 52,625
Total number of employees in Iraq during 2016110 1,534,094
Percentage of employment in the oil and gas extractive SOEs,
3.43%
relative to the total number employment in Iraq during 2016

The following table presents total number of employees in MoIM (including its formations), for
the year 2016:

Employment in the Mining Sector (Federal Iraq)

Entity Number of employees
Ministry of Industry and Minerals111 117,482
Total number of employees in Iraq during 2016 1,534,094
Percentage of employment in the mining sector (public
and governmental entities), relative to the total number 7.65%
employment in Iraq during 2016

110
The total number of employees in Iraq was obtained from the MoP through the IEITI
111
The total number of employees in the Ministry of Industry and Planning was obtained from the MoP through the IEITI

166
 6.4.6. Employment under licensing rounds during the year 2016
The following table illustrates the total number of employees in licensing round fields during
2016. The below figures were reported by the respective national oil companies (filed license
holders). No information was received in relation to the remaining fields and blocks awarded
under licensing rounds.

Field employees during the year 2016

Number of Number of Percentage of Percentage of
Total field
Field national foreign national foreign
employees
employees employees employees employees
Rumaila 6,851 503 7,354 93.2% 6.8%
Zubair 2,483 206 2,689 92.3% 7.7%
West Qurna
1,675 134 1,809 92.6% 7.4%
(Phase 1)
Garraf 275 460 735 37.4% 62.6%
Majnoun 652 811 1,463 44.6% 55.4%

West Qurna
611 546 1,157 52.8% 47.2%
(Phase 2)

Siba 97 6 103 94.2% 5.8%

Block 8 1 6 7 14.3% 85.7%
Badra 1,265 783 2,048 61.8% 38.2%
Ahdeb 2,776 1,019 3,795 73.1% 26.9%
Total 16,686 4,474 21,160
Source: data received from the respective NOCs

167
The following table presents the total employment by IOCs in their respective local Iraq
branches, during the year 2016.

IOC (Iraq branch) employees during the year 2016

Number of Number of Total Percentage Percentage
IOC name Field Name national foreign number of of national of foreign
employees employees employees employees employees
Al-Waha
Ahdeb 856 111 967 88.5% 11.5%
Petroleum
BP Iraq Rumaila 6,644 441 7085 93.8% 6.2%
ENI Iraq B.V Zubair 13 379 392 3.3% 96.7%
Kogas Akkas 4 45 49 8.2% 91.8%
Petrochina Halfaya 1040 404 1444 72.0% 28.0%
West Qurna
LUKOIL Mid-East 630 1028 1658 38.0% 62.0%
Phase 2
PPL Asia E&P
Block 8 1 3 4 25.0% 75.0%
B.V Iraq
Petronas Iraq Garraf 338 342 680 49.7% 50.3%
CNNOC Iraq Missan fields 1,570 238 1808 86.8% 13.2%
Siba 61 11 72 84.7% 15.3%
Kuwait Energy
Block 9 53 8 61 86.9% 13.1%
Inpex Block 10 1 1 2 50.0% 50.0%
LUKOIL
Overseas
Block 10 2 37 39 5% 95%
Exploration
(LOEI)
Total 11,213 3,048 14,261
Source: data received from the respective IOCs

JAPEX (contractor in Garraf field) declared that “all manpower for the project, either Iraqi
nationals or foreigners, has been employed by the Operator”.

168
 6.4.7. Training under licensing rounds

The following table reflects the value of amounts spent by IOCs during 2016 on training
courses, technology, and scholarships in accordance with the contract terms – Training,
Technology and Scholarship Fund (TTS fund), in addition to training courses conducted
voluntarily or based on requests from the national oil companies. Amounts paid by IOCs in
respect of the TTS fund, are mandatory expenditures as per the contract terms, however, do
not constitute a form of mandatory social expenditures.

Number of Cost Training

IOC Field Training course name
beneficiaries (USD) requirement
1-Oil and Gas refining and
12
analysis

Al-Waha 2- HSE for oil and gas industry

Ahdeb 12 318,559 TTS Fund
Petroleum safety

3- Field Development planning

12
at oil and gas facility

BP Rumaila - - 625,490 -
1- Introduction to Finance
12 79,710
Management
2- Auditing of Contracts 9 91,470 Voluntary
3- Piping and Long Distance
ENI Zubair 12 37,000
Pipelines

4- English Language 317 168,000

TTS Fund
5- HSE 9,466 473,298

1- The Fiducially Procurement

system used by contractor in - 67,400
contracts and licensing
2- Service contracts,
Petroleum licenses and - 134,500
sharing contracts
3- Modern techniques in
- 130,349 TTS Fund
Petrochina Halfaya planning and following up
4- Financial Obligation in
- 163,021
contracts and Licensing
5- Gas Processing (LPG-LNG-
NLG) production, - 216,339
management and handling
6- English Language Training
- 90,420
for MOC
International Arbitration
15 61,500
Course
West
LUKOIL Mid- Technology payments (not
Qurna N/A 105,000 TTS Fund
East ltd training course)
(Phase 2)
Scholarship payments (not
N/A 848630
training course)

Siba No training programs were undertaken during the year 2016

Kuwait
Energy
Block 9 No training programs were undertaken during the year 2016

169
 Payment /
Number of Cost
IOC Field Training course name training
beneficiaries (USD) requirement

Inpex Block 10 No training programs were undertaken during the year 2016

Kogas Akkas No training programs were undertaken during the year 2016

PPL Asia No training programs were undertaken during the year 2016
Block 8
E&P B.V Iraq
1- Operation and
maintenance of 10 207,081 TTS Fund
LUKOIL
centrifugal pump
Overseas
Block 10 2- Oil refining Catalytic
Exploration 10 208,587 TTS Fund
process
(LOEI)
3- Advanced Vibration
10 210,967 TTS Fund
Monitoring System

Missan
CNOOC Iraq Various (Refer to Annex 14 for details) 985,272 TTS Fund
fields

PT.
West
Pertamina
Qurna - - 522,789112 TTS Fund
International
(Phase 1)
- Iraq

Shell Majnoun - - 4,592,217113 TTS Fund

Total 10,337,599

112
According to the contractor, the details of the training costs is with the field operator.
113
This figure was reported by BOC on behalf of Shell

170
 7. Outcomes and impact

7.1. Data accessibility and public debate (Requirements 7.1 and 7.2)

According to the IEIT Standard, the MSG should ensure that the EITI Report is comprehensible,
actively promoted, publicly accessible and contributes to public debate.

Accordingly, the IEITI report for the year 2016 will be:

- Published in Arabic, Kurdish and English languages, as follows:

o Ten hard copies of IEITI report for each language
o 1,000 electronic copies containing IEITI report in three languages and
executive summary of the report in three languages on a business card size
flash memory
- Produced in electronic form (excel or csv format) which contains the tables and figures
from the print report. In accordance with requirement 7.1.c, the MSG is to make the
EITI Report available in an open data format (xlsx or csv) online.
- Provide summary data from the EITI Report electronically to the International
Secretariat according to the Standardized reporting format available from the
International Secretariat.

7.2. Observations and Recommendations

Observation Recommendation
Consistent with previous reporting periods, the  It is recommended that the MSG maintain
following key challenges were observed: communication throughout the year with the
different reporting entities to emphasize the
 Delayed completion or partial completion of importance of timely completion of reporting
reporting templates and other information templates and document requests, with strict
requests adherence to the requirements set forth by
the Independent Administrator (IA) in terms of
 Failure to respond to follow-up queries from data completion and quality assurance.
the Independent Administrator  The MSG should engage the IA for future EITI
Reports earlier in the year to allow additional
Despite extensive follow-up with the reporting
lead time, in acknowledgement of the data
entities, some reconciliation differences remain
collection challenges.
unexplained.

Although delays in reporting data was noticed by It is recommended that more efforts are exerted
governmental and non-governmental entities with non-governmental entities operating in the
operating in the extractive sector in Iraq, it was extractive sector of Iraq to explain the importance
noted that the governmental entities were more of this initiative and to get their buy in. This will
ready in addressing the requirements of the this strengthen the communication channels with the
initiative than were the non-governmental entities. IEITI and further facilitate the reporting process
and access to data.

171
 Observation Recommendation
As with previous reporting periods, the The accounting standards in Iraq are currently
inconsistency in reporting, in terms of applicable being developed with the aim of becoming in line
accounting standards, between the international with the International Financial Reporting
companies and SOEs, created many of the Standards, but until this is implemented, it is
reconciliation discrepancies. recommended that the MSG bring these issues to
the attention of the different reporting entities
through workshops and regular meetings.
Adopting this approach would enhance the quality
of reported data and the efficiency of the
reconciliation process.

The Mining Sector in Iraq is not as developed as the It is recommended that more attention is given to
Oil and Gas Sector, which is understandable in the the Mining Sector in Iraq by the government and
sense that Iraq is a major oil and gas producer and the IEITI could play a major role in this activity by
the mining sector did not get the needed attention. building awareness among the different entities
Nonetheless, the mining sector is important and operating in this sector and the government and
obtaining the required information for the purpose bringing it up to speed in terms of laws and
of this IEIT report posed a challenge due to regulations governing this sector, licensing
awareness issues by the Ministry of Industry and rounds, marketing initiatives and reporting
Minerals and its subsidiaries of the reporting requirements that are up to international
requirements of the EITI Standard. standards.

The PCLD did not disclose the weightings of the We recommend that the PCLD enhance the
technical and financial criteria used to pre-qualify comprehensiveness of its reporting with regards to
companies in the first phase of the license round the processes applied in awarding and transferring
bidding process, and to transfer shares in oil and license shares to reach a higher level of compliance
gas licenses. In addition, the PCLD did not disclose with the EITI standard.
whether there were any amendments to the
contract terms (for all active licenses) during For further transparency, the MSG recommends
2016. that the PCLD publish on its website a description
of the instructions for participating in the bidding
process of licensing rounds.

It was noted that petrodollar allocations and While the difference is potentially due to
Governorate Development Program allocations allocations that have been carried forward from
reported by the MoF, were higher than the previous years, the MSG recommends that the MoF
amounts allocated in the Federal Budget Act for report annual allocations, clearly identifying the
the year 2016. amounts that have been carried forward from
previous years.

It was noted that each of the national oil companies It is recommended that a unified mechanism for
applies a different methodology for calculating gas calculating gas production be adopted by all
production costs. national oil companies, to allow for consistency in
cost calculation.

Challenges were faced by the Independent The MSG recommends that the South Gas
Administrator in obtaining data from Basra Gas Company representative (which owns 51% of Basra
Company, whereby Basra Gas Company’s response Gas Company shares), issues written instructions
in relation to some of the data requests was that to Basra Gas Company requiring the company to
information is confidential and would not be report all data requested by the IEITI and any
reported. representative party.

172
7.3. Follow up on recommendations

Annual activity reports are published on the IEIT website to demonstrate actions taken and
progress made against previous recommendations. The progress against the recommendation
of the IEITI report for the year 2015 can be found in the IEITI Annual Progress Report for year
2016114 published on its website. In addition, progress has been made against a number of
EITI recommendations based on the Validation of the 2015 IEITI report. Although not all the
benefits of the action points were noticeable during the 2016 reporting period, it is expected
that these changes will continue to drive improvements in the completeness and accuracy of
data relating to the extractive sector in Iraq for future EITI reports. Progress made against the
following recommendations, was primarily based on information provided by the Iraqi EITI, as
follows:

Recommendation Action points taken

In accordance with requirement 1.1, the In response to this recommendation, the MSG exerted the
government should demonstrate that it is fully, following efforts:
actively and effectively engaged in the EITI
process. The government should demonstrate its 1- The MSG’s Internal Governance Policy was approved by the
commitment to the EITI by appointing a MSG in its meeting no. 54 dated 4 June 2018, and
government lead to chair the process and ensure stipulates that the Chair of the MSG should preferably be a
that senior government officials are represented Minister.
and engaged in the multi-stakeholder group. The 2- On 13 December 2018, the MSG obtained preliminary
government should also ensure that links are approval to appoint the Deputy Prime Minister of Energy
made between Iraq’s EITI’s objectives and /Minister of Oil as the Chair of the MSG (the MSG
ongoing work within their respective agencies. authorized the National Coordinator to approach the
Deputy Prime Minister in that regard).
3- The Iraqi Government, represented by the General
Secretariat of the Council of Ministers provided the State
Council with the draft Extractive Industries Transparency
Committee Law (Letter No. 39321 on 4 December 2017),
for review.
4- A commission was formed to ensure the proper
implementation of the EITI corrective actions (Decree No.
40397 dated 14 December 2017 issued by the Iraqi
Government)
5- Executive Order No. 135 dated 21 December 2017, was
issued by the Iraqi Government, to form the Extractive
Industries Transparency Committee
6- The Minister of Oil approved the adoption of the work plan
submitted by the MSG’s government representatives, in
relation to direct disclosure project (based on executive
order no. 52 dated 1 February 2018). In addition, the
Ministry of Oil’s Legal Affairs Office issued a letter to
circulate the plan to the concerned parties, for adoption by
national oil companies.

114
http://ieiti.org.iq/ar/listing/reports-and-publications/activity-report

173
 Recommendation Action points taken

In line with Requirement 1.2, the MSG should

develop a plan to engage more actively with the 1. The MSG arranged multiple meetings to motivate active
industry constituency, for instance through the industry participation. In addition, a letter was sent by the
Iraq Oil Company Forum. To galvanise industry’s MSG explaining the responsibilities of the respective
attention, the MSG should ensure extensive industry participants
consultations with industry are undertaken to 2. Substitutes for the representatives of the International Oil
ensure EITI implementation objectives are Companies on the MSG were elected as follows:
consistent with priorities of the industry  Mr. Mustafa Mohammad Reda, an alternate for Mr.
constituency. Zaid Yaseri (representative of BP), to attend MSG
meetings when Mr Zaid is unable to attend
 Mr. Ghassan Alsidawi, an alternate for Mr. Gati Al-
Jebouri (representative of LUKOIL Mid-East), to attend
MSG meetings when Mr Gati is unable to attend
 Mr. Najm al-Ta’ie, an alternate for Mr. Abd Malik Jaffar
(representative of PETRONAS), to attend MSG
meetings when Mr Abd Malek is unable to attend

In line with Requirement 1.3, to strengthen 1. The MSG civil society representatives were elected on 15
implementation, civil society members of the MSG September 2018
may wish to consider formalizing and 2. The MSG adopted the use of Arabic as the MSG’s working
strengthening their mechanisms for canvassing language (Meeting No. 44 on 17 May 2017)
the broader constituency on key EITI documents,
in order to broaden public oversight of EITI
reporting and implementation. Basic
improvements in MSG governance such as the use
of Arabic as the working language should
encourage more active civil society participation
In line with Requirement 1.4, to strengthen 1. The MSG representatives were restructured in accordance
implementation, the MSG should update its with Executive Order No. 135 dated 21 December 2017
internal governance rules to cover all provisions 2. MSG representatives nomination/election procedures
of Requirement 1.4, develop a language policy were published on IEITI website and the official
that is conducive to achieving the goals of newspapers (in Arabic and Kurdish languages), in addition
implementation in Iraq and publish procedures for to the official website of the General Secretariat of the
nominating and changing MSG representatives, Council of Ministers and it’s affiliate in KRG.
including the duration of mandates. The MSG 3. The MSG drafted the Extractive Industries Transparency
should revisit its internal decision-making Committee Law, which was approved.
procedures to ensure statutory MSG rules are in 4. The MSG issued an Internal Governance Policy in line with
line with current practice and treat each of the EITI requirements
constituencies as equal. The MSG should also 5. The duration of mandates of the MSG representatives was
clarify whether there is a practice of per diems for stipulated in the Internal Governance Policy adopted by
attending EITI meetings or other payments to the MSG
MSG members, consider keeping public 6. In its meeting No. 35 dated 12 October 2015, the MSG
attendance records and consider posting MSG commissioned the IEITI National Secretariat to pay an
minutes online. amount of IQD 500,000, to the members of the civil
society representatives for each official meeting held by
the MSG, with the condition of making this payment only
once a month if there are multiple MSG meetings held in
one month.
7. The MSG minutes of meeting are published on the IEITI
website.

174
 Recommendation Action points taken

In line with Requirement 1.5, MSG members The MSG issued a work plan reflecting the national priorities of
should in the future consult with stakeholders the extractive industries, and specified a timeframe for its
from all constituencies and ensure that national implementation (May 2018 – April 2019)
priorities are adequately reflected in the work
plan in order to continue building on the recent
efforts to bring the work plan in line with the EITI’s
requirements
MSG should ensure that future IEITI Reports 1. The MSG outlined all applicable laws governing the
provide descriptions of the main laws and fiscal extractive sectors in Iraq (including KRG). In addition, the
terms related to the mining, oil and gas sectors IEITI prepared and published on its website, a study of the
and of recent or ongoing reforms legal framework applicable to the extractive sector in Iraq.
2. The MSG identified the roles and responsibilities of the
entities in charge of overseeing the extractive sectors in
Iraq. This information has been presented in the IEITI 2016
report. In addition, a description of the recent and ongoing
legal reforms were identified by the MSG and have been
described in the report.
In line with Requirement 2.2, the MSG should 1. The PCLD has provided the Iraqi ETI with the technical and
ensure that future IEITI Reports clearly define the financial criteria used in awarding licenses under all five
number of licenses (including Technical Service licensing rounds conducted up to year 2018. This process
Contracts) awarded and transferred in the year(s) has accordingly been described in the report.
under review in both mining and oil and gas, 2. Despite numerous efforts exerted by the MSG, IEITI and
describe the actual process and highlight any non- the IA, KRG and the companies operating in the Kurdistan
trivial deviations in practice. The MSG should Region did not report the requested information. Due to
clarify the technical and financial criteria (and the KRG’s lack of cooperation in the IEITI 2016 reporting
their weightings) used for assessing allocations process, all information included in the report is based on
and transfers of licenses and equity in TSC publicly available information. As it relates to the KRG,
consortia, both for any discretionary oil and gas
limited information was available on the Ministry of Natural
contracts (including in the KRG) and for mining
Resources and the KRG’s website in relation to the
license awards and transfers. The MSG may also
wish to comment on the efficiency of the current licensing process applied when entering into PSCs with
contract allocation and transfer system as a IOCs, or when assigning ownership interest in PSCs.
means of clarifying procedures and curbing non- Publicly available information was described in the report.
trivial deviations. However, information relevant identified online was
included in the report.
3. The Ministry of Mining did not provide the Independent
Administrator with a description of the criteria used when
contracting with private and public sector companies, or
when transferring ownership interest in a contract.

The MSG should ensure that future IEITI Reports

provide all information covered under 1. The IEITI website is currently a repository of applicable
Requirement 2.3 for all licenses held by material laws and regulations, licensing round contract templates,
companies (including both oil and gas and mining) and the PCLD’s licenses register.
or provide a link to where such license
information is available to the public. The MSG 2. The MSG worked on ensuring that the current IEITI Report
may also wish to work with the MoO and MIM to provides all information covered under Requirement 2.3
disclose license information for all material
companies through a publicly accessible cadastral
system and provide free access to such a register
online.

175
 Recommendation Action points taken

In line with Requirement 2.4, the MSG should The MSG worked with the Government and different
work with government representatives to clarify governmental bodies such as the MoO to clarify the Federal
the Federal Government’s policy on contract Government’s policy on contract disclosures. Accordingly, the
disclosure and document any instances of identified state policy on contract disclosures has been
contract disclosure either through future IEITI disclosed in the 2016 IEITI report.
Reports or through other channels such as the
IEITI website. The MSG is also encouraged to
undertake a detailed review of which PSCs have
been published by the KRG, with a view to
clarifying the practice of contract disclosure in
the KRG.

In line with Requirement 2.5, the MSG should The MSG has published a roadmap for disclosing beneficial
clarify the government’s policy on beneficial ownership information in Iraq, on the website of the IEITI. For
ownership disclosure in future IEITI Reports and the purpose of the Iraq EITI 2016 report, national oil and gas
provide the legal ownership of all material companies were required to disclose all secondary contracts
companies. The MSG may wish to consider how worth over USD 100 million, clarifying the name of the
reporting of transfers of equity in TSC consortia company, value of the contract, and the date of signing the
and mining licenses under Requirement 2.2 may contract. Accordingly, the IEITI would request from the Ministry
help support work on beneficial ownership of Trade (Companies registrar) the beneficial ownership
disclosure. information of individuals/entities with ownership stake of 10%
or more in the contracting company.
The MSG should ensure that all aspects of 1. The MSG has defined SOEs in accordance with Law No. 22
Requirement 2.6 are adequately addressed of 1997 (as amended). As per the Law, mixed sector
during the scoping for future IEITI Reports. It companies are not considered state-owned entities, and
should clearly establish its definition of SOEs to are governed by a different law (Law No.21 of 1997).
delineate the SOEs within the scope of EITI 2. The MSG has identified all SOEs operating in the extractive
reporting. The MSG should include a industries, and has described the fiscal relationships
comprehensive list of SOEs and their subsidiaries between the state owned entities and the government.
in the next IEITI Report, clarifying the financial 3. The MSG has provided a description of both the statutory
relations in practice between SOEs and and actual financial relations between the government and
government as well as any loans and loan SOEs.
guarantees from the government or SOEs to 4. The MSG has also provided a descriptive illustration of the
upstream mining, oil and gas companies. The MSG financial relations between the government entities, SOEs,
may wish to work closely with MoO and the NOCs and international companies involved in the extractive
to shape the structure of routine disclosures as a sector in Iraq (oil buyers and companies working in Iraq
means of publishing information required under under service contracts), in both mining, and oil and gas
the EITI Standard on a timelier basis. sectors.
5. There MSG has clarified that, while the law (Law No. 22 of
1997 as amended) allows public companies to obtain and
grant third-party financing. In practice, SOEs do not obtain
direct third-party financing.

In line with Requirement 3.2, the MSG should 1. The 2016 IEITI report discloses the volumes of production
ensure that future IEITI Reports disclose the in the extractive sector for oil, gas and minerals, and
production volumes and values for all every provides a description of the methods adopted by each of
extractives commodity produced, including crude the national oil companies in the calculation of volumes
oil, natural gas and every mineral produced. To and cost of oil and gas production.
continue improving under Requirement 3.1, the 2. The IEITI report for year 2016 clearly distinguishes
MSG may wish to expand its coverage of the between fields under the control of the federal and
mining sector by including more specific updates regional government.
on current production, primarily
in quarrying.

176
 Recommendation Action points taken

In line with Requirement 4.1, the MSG should 1. The MSG considered a quantitative materiality threshold to
consider undertaking a comprehensive scoping determine which revenue streams would be deemed
study to consider options for defining materiality material for the purpose of the 2016 IEITI report.
thresholds ahead of agreeing the ToR for its next 2. The quantitative threshold applied to define materiality
EITI Report. The MSG should ensure that all was all revenue streams and payments that are known to
material revenue flows (in both petroleum and contribute two percent or more of the revenue received by
mining) listed under Requirement 4.1.b are the government from the mining and oil and gas sectors.
included in the scope of reconciliation and that 3. The MSG considered a zero materiality threshold for
the materiality threshold for selecting companies companies contributing to the material revenue streams in
ensures that all payments that could affect the Iraq.
comprehensiveness of EITI reporting be included 4. The IEITI report for 2016 includes the IA’s assessment of
in the scope of reconciliation. The list of material the materiality of omissions, for companies that did not
companies should also clearly be defined. The report the requested revenue related data.
MSG is invited to consider whether setting a 5. Where material companies did not report their respective
quantitative materiality threshold for selecting revenue-related data, the IEITI report presented the
companies would ensure these aims are met. The revenue unilaterally disclosed by the Government.
MSG should ensure that Iraq’s next IEITI Report
includes the IA’s assessment of the materiality of
omissions, its statement on the
comprehensiveness of the IEITI Report and that
full unilateral government disclosure of material
revenues from non-material companies is
included. In accordance with requirement 8.3.c.i,
the MSG is required to develop and disclose an
action plan for addressing weaknesses in data
comprehensiveness documented in the initial
assessment and Validator’s report within three
months of the Board’s decision, i.e. by 26 January
2018.
While there is no evidence of barters or The IEITI has reviewed a sample of contracts published on the
infrastructure agreements in the KRG, the MSG is website of the KRG, and did not identify any barter provisions
encouraged to examine all of the published KRG or swaps within the PSC terms.
PSCs to assess the potential for infrastructure
provisions or barter components of these PSCs in
line with Requirement 4.3

In line with Requirement 4.4, the MSG is strongly The MSG has clarified that the Government receives its share of
encouraged to review the financial statements of the revenues generated by the six transportation, marketing
the six SOEs engaged in transportation, and distribution state owned entities through the 45% treasury
distribution and marketing of oil and gas to share remittances, which is applicable to all SOEs operating in
assess the materiality of any potential revenues Iraq.
to government, through transfers to the MoF.
In line with Requirement 4.5, the MSG should 1. The MSG has clarified the financial relations between SOEs
clarify the scope of transactions between SOEs and the government, and has assessed the materiality of
and other government agencies as well as such transactions.
between SOEs and companies in the mining, oil 2. The MSG has determined that Internal Service payments,
and gas sector. Drawing upon the MSG’s definition which are made by the MoF (though SOMO) to national oil
of SOEs under Requirement 2.6, the MSG should companies to cover cost of production that is exported,
ensure future IEITI Reports disclose the
should be reconciled in the IEITI 2016 report, due to their
disaggregated value of such financial
importance, regardless of their quantitate materiality. In
transactions for the year under review. Given the
lack of clarity surrounding financial relations addition, the MSG has clarified that Oil Exploration
between oil and gas SOEs and the government, Company has started receiving ISP from SOMO during
the MSG is encouraged to consider whether 2016, due to its indirect involvement in the export process
reconciliation of such financial transactions (both (through its exploration work).
statutory and ad hoc) would further the broader
objective of transparency in transactions between
SOEs and government.

177
 Recommendation Action points taken

The MSG should secure the KRG's active The MSG and the IA repeatedly attempted to attain the KRG’s
participation in scoping and shaping Iraqi EITI participation in the IEITI reporting for the year 2016; however,
disclosures of direct subnational payments under no data was reported by the KRG or by the companies operating
Requirement 4.6. The MSG is encouraged to
consider whether working with the MoO and the under KRG. Consequently, the IEITI represented by the National
KRG to establish its own regional-level structure Coordinator submitted an adaptive implementation request to
for EITI implementation could ensure more the EITI on 27 November 2018, with respect to coverage of the
efficient coverage of subnational direct Kurdistan Region in the IEITI 2016 report.
payments. The KRG’s EITI MSG could publish its
own reports, which could then be included in the
national IEITI Reports

The MSG should ensure that all reconciled All reconciled financial data is disaggregated by revenue
financial data is disaggregated by company, stream, government entity, and where possible, by company (in
revenue stream and government entity. some instances reconciled data is presented by field).

In line with Requirement 4.9, the MSG should The auditing practices of reporting companies and government
ensure that a review of actual auditing practices entities were described in the IEITI’s scoping study, and
by reporting companies and government entities accordingly data quality assurance measures, were determined
be conducted before agreeing procedures to jointly by the MSG and the IA to ensure the reliability of reported
ensure the reliability of EITI information. The MSG information in the IEITI 2016 report.
should also ensure that the ToR for the IA is in line
with the standard ToR approved by the EITI Board
and that its agreement on any deviations from the
ToR in the final EITI Reports be properly
documented. The MSG should also ensure that the
IA include an assessment of whether the
payments and revenues disclosed in the EITI
Reports were subject to credible, independent
audit, applying international auditing standards
as well as a description of follow-up on past EITI
recommendations.

In line with Requirement 5.1, the MSG should The MSG assessed all revenue streams and determined that all
work with the IA in preparing the next IEITI Report revenues are recorded in the federal budget with the exception
to clearly trace any mining, oil and gas revenues of the KRG revenues.
that are not recorded in the national budget and
clearly explain the allocation of any off-budget
revenues. To further strengthen implementation
under Requirement 5.3, the MSG could consider
tracking more comprehensively the spending of
extractive industry revenues earmarked for
specific purposes. This form of annual diagnostic
of public financial management would be of
particular relevance to the IMF’s standby
agreement with Iraq.
In line with Requirement 5.2, the MSG should The MSG identified the types of subnational transfers applicable
assess the materiality of subnational transfers in Iraq, and ensured that the IEITI Report provides:
and ensure that future IEITI Reports provide the
specific formula for calculating subnational  the specific formula for calculating subnational
transfers linked to extractives revenues to transfers linked to extractives revenues to individual
individual governorates, disclose any material governorates,
subnational transfers and any discrepancies  disclose any material subnational transfers and any
between the transfer amount calculated in discrepancies between the transfer amount
accordance with the relevant revenue sharing calculated in accordance with the relevant revenue
formula and the actual amount that was sharing formula and the actual amount that was
transferred between the central government and transferred between the central government and
each relevant subnational entity. each relevant subnational entity

178
 Recommendation Action points taken

In line with Requirement 5.3, the MSG could Budgetary oil price and production assumptions are included in
consider working with relevant stakeholders the Annual Federal Budget Act of Iraq.
including parliamentarians to ensure that future
EITI Reports provide additional information on
budgetary oil price and production assumptions
as well as revenue forecasts.

In line with Requirement 6.1, the MSG should 1. The IEITI conducted a social expenditures study to identify
clarify ensure that reporting of mandatory social all mandatory and voluntary social expenditures.
expenditures be disaggregated by type of 2. The MSG has assessed the materiality of mandatory social
payment and beneficiary, clarifying the name and expenditures
function of any non-government (third party)
beneficiaries of mandatory social expenditures.
The MSG may also wish to consider the feasibility
of reconciling mandatory social expenditures.

The MSG should ensure that future IEITI Reports The current IEIT report provides extractive industries share of
provide the extractive industries, in oil and gas as GDP, government revenues, exports and employment in
well as mining in Iraq (including Kurdistan), share absolute and relative terms.
of GDP, government revenues, exports and
employment in absolute and relative terms. It
should also ensure that the location of all
significant production is clearly delineated.

In line with Requirement 7.1, IEITI should ensure 1. The IEITI reports are published on the IEITI website and
that future reports are comprehensible, actively made available in an open data format online. In addition,
promoted, publicly accessible and contribute to reports are made available on USB flash drives in order to
public debate. IETI should consider developing a encourage the different parties to share information easily
communications strategy that looks beyond 2. The Terms of Reference for the IEITI reports for years
building brand recognition to addressing the 2016 and 2017 have been published on the IEITI website.
national priorities identified in the work plan. IEITI
should also agree a clear policy on the access,
release and re-use of EITI data and make EITI
Reports available in an open data format online.

In line with Requirement 7.3, the MSG should 1. The MSG made several and extensive efforts to attain
consider how to act upon lessons learned in KRG’s participation in the initiative, as follows:
regards to the KRG and identify opportunities to  The MSGF issued an order to establish a team of MSG
increase engagement with stakeholders there. members to meet with KRG representatives (MSG
The MSG could also take a proactive role in Decision No. 51 dated 7 January 2018 and the
formulating its own recommendations. underlying executive order no. 53 dated 1 February
2018). KRG did not respond to the MSG’s request for
meetings
 A letter No. 293 dated 8 August 2018 was directed
by the IEITI to the Kurdistan Regional Government -
Ministry of Natural Resources, to facilitate the
mission of the IA in obtaining data related to the KRG,
but there was no response from the KRG.
 The MSG tried to arrange for a meeting between Mr.
Khaled Naqshbandi (former Kurdistan Region civil
society representative on the MSG) and Mr. Amanj,
Cabinet Secretary at the Kurdistan Regional
Government, but without success.
2. The MSG attempted to encourage the civil society to elect
their representative from the Kurdistan Region and
specified the election date on 22 September 2018, but the
elections did not take place due to certain protests at the
election site in Kurdistan.

179
 Recommendation Action points taken

In line with Requirement 7.4, the MSG should 1. Annual progress reports are published on the IEITI website.
ensure that annual progress reports reflect 2. The MSG uses annual progress reports to monitor
activities in the year under review clearly and that implementation of action points to address
progress against the work plan is clear. The MSG recommendation, and efficiently improve the work plans.
should also ensure that all stakeholders are given 3. The annual progress reports reflect the annual activities
an opportunity to provide input to the annual carried out by the MSG.
progress report and that their views are
adequately reflected. As secretariat staff
participating in meetings makes up a large part of
the annual progress report’s listed activities, the
MSG may wish to consider what kind of activities
the report should include. The MSG should also
consider drafting and publishing annual progress
reports in Arabic to improve the dialogue between
stakeholders and ensure that there is a common
understanding of the activities carried out by the
MSG in the year under review.

180
 Annex 1 – List of bidders during the first licensing
round
Companies
Plateau
Bidding companies or Bid Rem. Fee
Field production Comments
(consortia) (RFB) $/b
target (PPT)
B/d
Awarded at a remuneration fee
BP+CNPC 3.99 2,850,000 of $2/barrel, which was set by the
Rumaila Ministry of Oil (MRF)

ExxonMobil + Petronas 4.8 3,100,000

Total 7.5 900,000

Awarded at a remuneration fee
ExxonMobil + Shell 4 2,326,000 of $1.9/barrel, which was set by
the Ministry of Oil (MRF)
West Qurna Repsol+
(Phase 1) 19.3 650,000
Statoil + Maersk
LUKOIL + ConocoPhillips 6.49 1,500,000
CNPC + Japex +
2.6 1,900,000
Petronas
Awarded at a later date to (Eni+
Eni + Sinopec+ Oxy + Kogas) at a remuneration
4.8 1,125,000
OXY + Kogas fee of $2.3/barrel, which was set
by the Ministry of Oil (MRF)

Zubair ExxonMobil+ Sell+ Petronas 4.8 850,000

ONGC + Gazprom+
9.9 525,000
TPAO
CNPC+BP 4.09 1,075,000
Awarded at a later date to
(CNOOC + TPAO) at a
Missan fields CNOOC + Sinochem Co. 21.4 450,000 remuneration fee of $2.3/barrel,
which was set by the Ministry of
Oil (MRF)

Kirkuk Shell + CNPC + Sinopec + TPAO 7.89 825,000 The field was not awarded

ConocoPhillips +CNOOC +
Bai-Hussain 26.7 390,000 The field was not awarded
Sinochem Co.
Edison + Kogas +
The field was not awarded
Akkas Petronas + CNPC+ 38 425mmscfd
in that round
TPAO
The field was not awarded
Al-Mansuriya No Bidder
in that round

Source of tables in Annex 1 through Annex 5 is the Ministry of Oil - PCLD

181
 Annex 2 – List of bidders during the second licensing
round

Companies
Bidding companies or Bid Rem Fee Plateau
Field Comments
(consortia) (RFB) $/b Production Target
(PPT) B/d

The winning consortium

Shell + Petronas 1.39 1,800,000 at a remuneration fee of
Majnoon $1.39/barrel
Total + CNPC 1.75 1,405,000

ONGC + TPAO + Oil India 1.76 550,000

The winning consortium

CNPC + Petronas + Total 1.4 535,000 at a remuneration fee of
Halfaya $1.4/barrel

Eni + Sonangol+ CNOOC +

12.9 400,000
Korea Gas + Occidental

Statoil + LUKOIL 1.53 600,000

Total 1.71 1,430,000
PETRONAS + Pertamina +
1.25 1,200,000
Petro Vietnam
West Qurna
(Phase 2) BP + CNPC 1.65 888,000
The winning consortium
Statoil + LUKOIL 1.15 1,800,000 at a remuneration fee of
$1.15/barrel
TPAO + ONGC 2.76 200,000
Kazmunai + Kogas +
2.55 185,000
Edison
Garraf The winning consortium
Petronas + Japex 1.49 230,000 at a remuneration fee of
$1.49/barrel
Pertamina 7.5 150,000
The winning consortium
Gazprom + TPAO + Kogas
Badra 6 170,000 at a remuneration fee of
+ Petronas
$5.5/barrel
The winning company at
Qaiyarah Sonangol 12.5 120,000 a remuneration fee of
$5/barrel
The winning company at
Najmah Sonangol 8.5 110,000 a remuneration fee of
$6.0/barrel
East Baghdad No Bidder
Eastern Fields No Bidder

Middle Furat No Bidder

182
 Annex 3 – List of bidders during the third licensing
round
Companies
Bid Rem Plateau
Bidding companies or
Field Fee (RFB) Production Comments
(consortia)
$/BOE Target (PPT)
MMSCFD

TPAO + Total S.A 19 375

Akkas
The winning consortium at a
Kogas + Kazmunai Gas 5.5 400
remuneration fee of $5.5/barrel

The winning consortium at a

Energy + TPAO Kuwait 7.5 100
remuneration fee of $7.5/barrel
Siba

Kazmunai Gas 16 65

TPAO + Kuwait Energy The winning consortium at a

Mansuriya 10 320
+ Kogas remuneration fee of $7/barrel

183
 Annex 4 – List of bidders during the fourth licensing
round
Bidding
Block No. companies or Bid Rem Fee (RFB) $/BOE Comments
(consortia)
Block No.1 No bidder
- -
No bidder
Block No.2
- -
No bidder
Block No.3
- -
No bidder
Block No.4
- -
No bidder
Block No.5
- -
No bidder
Block No.6
- -
No bidder
Block No.7
- -
Pakistan The winning company at a remuneration fee
5.38
Petroleum Ltd of $5.38/barrel
Block No.8
Japex + Itochu 10.57

Kuwait Energy + The contract was later awarded to the Kuwait

Block No.9 TPAO + Dragon 6.24 Energy + Dragon Oil consortium at a
oil remuneration fee of $6.24/barrel
Petro Vietnam +
Bashneft + 7.07
Premier Oil
LUKOIL Overseas The winning consortium at a remuneration
Block No.10 5.99
+ Inpex fee of $5.99/barrel
Kuwait Energy +
6.24
Dragon oil

Block No.11 No Bidder

Petro Vietnam + The contract was later awarded to the
Block No.12 Bashneft + 6.24 Bashneft + Premier consortium at a
Premier Oil remuneration fee of $5/barrel

184
 Annex 5 – List of bidders during the fifth licensing
round
Company
Contract Area Company Name MRPB RPB
Interest

Gilabat-Qumar Crescent Petroleum 100% 16.65% 9.21%

Khashim Ahmer-Injana Crescent Petroleum 100% 20% 19.99%

Naft Khana Geo-Jade Petroleum 100% 24.45% 14.67%

Zurbatiya No Offer

Shihabi No Offer

Huwaiza Geo-Jade Petroleum 100% 7.16% 7.15%

United Energy Group

Sindbad 100% 6.11% 4.55%
(UEG)

FAO No Offer

Jabal Sanam No Offer

Crescent Petroleum Crescent Petroleum 100% 13.76% 13.75%

Arabian Gulf No Offer

185
Annex 6 – Map of Iraqi oil and gas fields (Licensing
rounds in federal Iraq)

186
 Annex 7 – Coordinates of Iraqi oil and gas fields
(Licensing rounds in Federal Iraq)
All field and block coordinates listed in Annex 7 was obtained from the PCLD

First licensing round:

Missan Fields
Abu Ghirab Field Buzurgan Field Fauqi Field
Cornerpoint Northing Easting Cornerpoint Northing Easting Cornerpoint Northing Easting
B 3,575,400 734,500 A 3,546,300 739,500 A 3,549,800 740,400
C 3,573,500 731,700 B 3,544,000 730,000 B 3,561,250 734,400
D 3,591,000 718,500 C 3,562,000 716,500 C 3,566,000 734,400
E 3,593,750 711,500 D 3,568,800 706,200 D 3,566,000 741,655
F 3,595,750 714,000 E 3,579,500 707,000 E 3,564,800 741,655
G 3,592,000 723,250 F 3,579,000 710,000 F 3,563,750 740,800
H 3,582,250 730,500 G 3,565,700 723,600 G 3,562,350 739,400
I 3,581,675 729,200 H 3,546,300 739,500 H 3,561,825 738,100
J 3,581,000 730,710 I 3,561,300 738,450
K 3,577,650 731,600 J 3,559,300 739,000
L 3,577,500 733,500 K 3,558,500 738,400
L 3,556,350 741,400
M 3,555,850 741,050
N 3,555,300 741,800
O 3,555,500 743,050
P 3,555,450 744,150
Q 3,555,800 744,600
R 3,553,750 748,000
S 3,552,800 749,000
T 3,552,700 749,300
U 3,549,800 749,300
V 3,549,800 740,400

187
First licensing round (excluding Ahdeb field):

Rumaila Ahdeb
Cornerpoint Northing Easting Cornerpoint Northing Easting
A 3,407,000 733,107 A A-548800 3,604,950
B 3,369,290 730,070 B B-576300 3,590,800
C 3,333,000 744,840 C C-569650 3,582,850
D 3,332,982 744,031 D D-544400 3,596,100
E 3,332,962 743,134
F 3,332,947 742,449 West Qurna (Phase 1)
G 3,332,923 741,331 Cornerpoint Northing Easting
H 3,332,895 740,068 A 3,426,000 714,000
I 3,332,884 739,543 B 3,426,000 731,000
J 3,332,871 738,942 C 3,400,000 731,000
K 3,332,847 737,867 D 3,400,000 714,000
L 3,332,819 736,555 E 3,426,000 714,000
M 3,332,812 736,239
N 3,332,790 735,181 Zubair
O 3,332,771 734,323 Cornerpoint Northing Easting
P 3,332,756 733,612 A 3,399,000 750,600
Q 3,332,729 732,317 B 3,363,500 760,200
R 3,332,699 730,895 C 3,353,000 771,000
S 3,332,691 730,504 D 3,329,100 771,000
T 3,332,670 729,538 E 3,331,700 764,000
U 3,332,649 728,502 F 3,331,700 760,700
V 3,332,400 728,185 G 3,361,800 742,200
W 3,331,904 727,551 H 3,393,200 738,600
X 3,331,606 726,657 I 3,399,000 750,600
Y 3,331,761 726,600
Z 3,331,764 726,593
AA 3,347,378 717,116
CC 3,361,650 714,500
DD 3,407,000 714,500
EE 3,407,000 733,107
FF 3,400,000 732,535

188
Second licensing round:
West Qurna (Phase 2) Halfaya
Cornerpoint Northing Easting Cornerpoint Northing Easting
A 3,450,350 713,250 A 3,516,150 717,250
B 3,450,350 723,900 B 3,514,000 732,500
C 3,426,000 731,000 C 3,510,615 737,850
D 3,426,000 714,000 D 3,506,250 740,000
E 3,436,600 713,350 E 3,501,000 748,150
F 3,499,250 747,300
Majnoon G 3,497,000 737,250
Cornerpoint Northing Easting H 3,505,000 723,380
A 3,477,750 748,000 I 3,515,000 717,000
B 3,477,750 754,500
C 3,432,250 756,000 Badra
D 3,429,500 758,750 Cornerpoint Northing Easting
E 3,425,000 751,500 A 3,665,195 596,358
F 3,435,000 745,000 B 3,663,195 597,358
G 3,447,250 741,250 C 3,650,750 602,400
H 3,457,750 742,000 D 3,657,195 590,358

Qaiyarah Najmah

Cornerpoint Northing Easting Cornerpoint Northing Easting

A 3,972,500 337,000 A 3,978,500 329,250

B 3,967,696 343,115 B 3,977,196 333,365
C 3,964,846 349,665 C 3,973,196 337,365
D 3,958,796 348,765 D 3,969,250 334,000
E 3,961,196 342,365 E 3,971,196 330,365
F 3,963,496 339,365 F 3,973,750 326,500
G 3,969,000 334,000

Garraf

Cornerpoint Northing Easting

A 3,528,250 586,500
B 3,523,000 601,750
C 3,512,500 614,750
D 3,505,500 610,250
E 3,518,750 582,750

189
Third licensing round:
Mansuriya Siba

Cornerpoint Northing Easting Cornerpoint Northing Easting

A 3,786,000 490,000 A 3,368,000 805,000

B 3,772,000 500,000 B 3,354,000 789,000
C 3,770,000 498,000 C 3,360,000 787,000
D 3,770,000 494,000 D 3,373,000 791,000
E 3,780,000 486,000
F 3,784,000 486,000

Akkas

Cornerpoint Northing Easting

A 3,792,000 678,500
B 3,787,000 682,500
C 3,783,000 684,000
D 3,781,500 686,000
E 3,771,000 700,000
F 3,760,000 710,000
G 3,750,000 710,000
H 3,745,000 700,000
I 3,750,000 690,000
J 3,780,000 665,000
K 3,790,000 667,500

190
Fourth licensing round:
Block 8 Block 9
Cornerpoint Northing Easting Cornerpoint Northing Easting
A 3,767,000 498,000 A 3,432,725 765,650
B 3,760,000 500,000 B 3,433,225 785,225
C 3,740,000 534,000 C 3,398,000 785,225
D 3,715,000 575,000 D 3,398,000 765,650
E 3,650,000 578,000
F 3,650,000 535,000 Block 12
G 3,700,000 534,000 Cornerpoint Northing Easting
H 3,700,000 500,000 A 3,400,000 360,000
I 3,740,000 500,000 B 3,400,000 490,000
J 3,740,000 470,000 C 3,340,000 536,000
K 3,745,000 470,000 D 3,340,000 410,000

Block 10
Cornerpoint Northing Easting
A 3,460,000 530,000
B 3,450,000 562,000
C 3,430,000 605,000
D 3,415,000 625,000
E 3,400,000 625,000
F 3,400,000 650,000
G 3,360,000 650,000
H 3,360,000 625,000
I 3,423,000 538,000
J 3,452,000 514,000

191
Annex 8 – Map of Iraqi oil and gas fields (KRG)

192
 Annex 9 – Coordinates of Iraqi oil and gas fields
(KRG)
Ain Sifni Akri Bijeel

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 36 44 05 42 59 04 320 042 4067 331 Point A 36 51 58 43 40 49 382 370 4080 837

Point B 36 44 18 43 14 20 342 768 4067 294 Point B 36 46 41 44 04 29 417 438 4070 662

Point C 36 45 13 43 14 45 343 406 4068 983 Point C 36 42 28 44 18 13 437 805 4062 683

Point D 36 43 56 43 19 48 350 884 4066 467 Point D 36 39 02 44 22 23 443 951 4056 300

Point E 36 44 23 43 39 04 379 577 4066 846 Point E 36 34 39 44 15 35 433 758 4048 249

Point F 36 36 44 43 33 20 370 830 4052 821 Point F 36 36 48 44 00 46 411 716 4052 445

Point G 36 32 05 43 29 51 365 500 4044 300 Point G 36 44 33 43 51 12 397 536 4059 522

Point H 36 35 39 43 17 33 347 250 4051 194 Point H 36 44 14 43 53 04 400 395 4066 302

Point I 36 39 51 42 59 09 320 000 4059 500 Point I 36 46 36 43 40 44 382 100 4070 900

Arbat Atrush

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 35 41 06 45 30 30 545 986 3949 122 Point A 36 53 56 43 20 19 351,977 4,084,954

Point B 35 16 33 45 51 38 578 264 3903 961 Point B 36 51 58 43 40 49 382,370 4,080,837

Point C 35 12 21 45 46 47 570 980 3896 145 Point C 36 46 36 43 40 44 382,100 4,070,900

Point D 35 27 32 45 25 00 537 799 3924 011 Point D 36 48 42 43 30 59 367,655 4,075,019

Point E 35 33 16 45 20 31 531 002 3934 583 Point E 36 48 55 43 18 20 348,857 4,075,711

Point F 35 38 47 45 25 23 538 285 3944 795 Point F 36 49 42 43 20 25 351,977 4,077,104

Baranan Barda Rash

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 35 27 32 45 25 00 537 799 3924 011 Point A 36 32 05N 43 29 51E 365 500 4044 300

Point B 35 12 21 45 46 47 570 980 3896 145 Point B 36 31 13N 43 43 35E 385 977 4042 422

Point C 35 05 40 45 42 06 563 951 3883 730 Point C 36 28 00N 43 47 49E 392 200 4036 400

Point D 35 12 38 45 27 21 541 485 3896 486 Point D 36 24 29N 43 41 30E 382 700 4030 000

Point E 35 21 24 45 19 16 529 171 3912 629 Point E 36 26 24N 43 30 32E 366 358 4033 785

Pulkhana Erbil
Latitude Longitude
X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec)
Point A 34 57 35 44 32 39 458,386 3,868,672 Point A 392000 4036500

Point B 35 01 35 44 39 42 469,142 3,876,034 Point B 416000 4020000

Point C 34 47 44 44 55 03 492,441 3,850,381 Point C 411000 4016500

Point D 34 45 54 44 50 11 485,028 3,847,006 Point D 397000 4018000

Point E 34 43 28 44 42 52 473,851 3,842,519 Point E 383000 4030000

193
 Bazian Bina Bawi

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 35 47 18N 44 51 55E 487 823 3960 471 Point A 36 16 15 44 18 01 437 138 4014 203

Point B 35 28 22N 45 12 49E 519 366 3925 488 Point B 36 16 41 44 19 55 440 000 4015 000

Point C 35 25 02N 45 06 17E 509 496 3919 304 Point C 36 19 23 44 20 36 441 059 4019 967

Point D 35 41 17N 44 49 08E 483 608 3949 365 Point D 36 13 11 44 29 21 454 088 4008 427

Point E 35 42 17N 44 50 59E 486 395 3951 209 Point E 36 07 16 44 35 48 463 692 3997 443

Point F 35 43 25N 44 51 21E 486 966 3953 291 Point F 36 05 53 44 31 06 456 640 3994 930

Point G 35 45 24N 44 49 38E 484 380 3956 980 Point G 36 08 07 44 25 44 448 614 3999 114

Point H 36 10 39 44 23 25 445 172 4003 813

Central Dohuk Ber Bahr

Latitude Longitude
X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec)
4103
Point A 37 03 06 42 35 19 285 577 Point A 323 658 4095 715
317
4107
Point B 37 05 23 42 40 25 293 240 Point B 327 174 4093 034
347
4107
Point C 37 05 41 42 57 01 317 832 Point C 337 851 4089 544
347
4100
Point D 37 01 46 42 57 10 317 911 Point D 328 900 4077 765
106
4095
Point E 36 59 28 43 01 06 323 658
715
4081
Point F 36 51 30 42 54 33 313 596
196
4081
Point G 36 51 26 42 50 24 307 438
196

Dinarta Garmain
Latitude
Longitude Latitude Longitude
(deg min X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec)
sec)
Point A 37 00 40 43 54 19 402 608 4096 666 Point A 34.63551 45.3713 534031.75 3832686.29

Point B 37 02 05 43 57 35 407 489 4099 244 Point B 34.79561 44.91737 492441.35 3850381.01

Point C 36 45 27 44 33 07 460 014 4067 931 Point C 34.96277 44.94763 495219.19 3868916.11

Point D 36 39 16 44 29 37 454 738 4066 657 Point D 34.98045 45.02579 502353.68 3870875.46

Point E 36 37 22 44 24 26 446 991 4053 174 Point a 35.06713 45.16177 514750 3880500

Point F 36 39 02 44 22 23 443 951 4056 300 Point b 35.03623 45.2075 518926.57 3877080.68

Point G 36 42 28 44 18 13 437 805 4062 683 Point c 35.02421 45.26352 524040 3875760

Point H 36 46 41 44 04 29 417 438 4070 662 Point d 35.00764 45.29284 526720 3873930

Point I 36 51 02 43 44 56 388 468 4079 015 Point e 34.98434 45.40145 536640 38871380

Point J 36 56 21 43 46 48 391 368 4088 831 Point f 34.87771 45.58477 553441.19 3859637.79

Point K 36 56 47 43 53 30 401 314 4089 499 Point G 34.80646 45.52121 547673.04 3851704.89

Point H 34.6507 45.45126 541352.78 3834401.17

194
 Sindi Amedi Harir
Latitude Longitude Latitude Longitude
X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)
Point A 37 12 45 N 43 38 20 E 379222 4119299 Point A 36 39 02 44 22 23 443 951 4056 300

Point B 37 02 05 N 43 57 35 E 407489 4099244 Point B 36 37 22 44 22 26 446 991 4053 174

Point C 37 00 40 N 43 54 19 E 402608 4096665 Point C 36 35 07 44 24 17 446 753 4049 029

Point D 36 56 47 N 43 53 30 E 401314 4089499 Point D 36 31 31 44 27 24 451 367 4042 358

Point E 36 56 21 N 43 46 48 E 391368 4088831 Point E 36 25 16 44 29 52 454 972 4030 768

Point F 36 56 16 N 43 43 59 E 387178 4088720 Point F 36 28 39 44 23 36 445 645 4037 082

Point G 37 00 10 N 43 38 18 E 378852 4096047 Point G 36 28 05 44 22 39 444 221 4036 044

Point H 37 02 13 N 43 38 49 E 379673 4099827 Point H 36 24 31 44 24 38 447 157 4029 433

Point I 37 05 48 N 43 17 36 E 348326 4106959 Point I 36 23 32 44 23 01 444 709 4027 627

Point J 37 05 48 N 43 03 26 E 327342 4107347 Point J 36 25 54 44 17 47 436 930 4032 054

Point K 37 12 29 N 43 03 16 E 327368 4119718 Point K 36 23 44 44 14 21 431 780 4028 102

Point L 37 12 09 N 42 40 13 E 293240 4119886 Point L 36 28 59 44 06 50 420 628 4037 878

Point M 37 08 06 N 42 40 20 E 293240 4112389 Point M 36 34 24 43 57 03 406 126 4048 065

Point N 37 07 39 N 42 26 15 E 272367 4112082 Point N 36 36 48 44 00 46 411 716 4052 445

Point O 36 34 39 44 15 35 433 758 4048 249

Shakal Tawke

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 34 38 08 45 22 17 534 032 3832 686 Point A 37 07 39 42 26 15 272 367 4112 082

Point B 34 47 44 44 55 03 492 441 3850 381 Point B 37 08 06 42 40 20 293 240 4112 389

Point C 34 45 54 44 50 11 485 028 3847 006 Point C 37 12 09 43 40 13 293 240 4119 886

Point D 34 32 56 45 04 55 507 518 3823 022 Point D 37 12 29 43 03 16 327 368 4119 718

Point E 34 34 05 45 09 36 514 676 3825 162 Point E 37 05 48 43 03 26 327 342 4107 347

Point F 34 32 30 45 12 50 519 630 3822 237 Point F 37 05 41 42 57 01 317 832 4107 347

Point G 34 34 02 45 15 08 523 126 3825 073 Point G 37 05 23 42 40 25 293 240 4107 347

Point H 34 32 33 45 17 30 526 768 3822 338 Point H 37 03 06 42 35 19 285 577 4103 317

Point I 37 03 52 42 22 29 266 595 4105 251

195
 Taq Taq Dohuk
Latitude Longitude
X (mE) Y (mN)
(deg min sec) (deg min sec)
1 36 07 06.00 N 044 28 03.76 E Point A 296978 4112389

2 36 05 49.36 N 044 31 01.37 E Point B 296978 4107347

3 36 07 12.00 N 044 35 54.35 E Point C 317832 4107347

4 36 07 12.00 N 044 43 12.00 E Point D 317911 4100106

5 35 55 12.00 N 044 43 12.00E Point E 327174 4093034

6 35 45 24.20 N 044 49 37.95 E Point F 351977 4084954

7 35 43 24.61 N 044 51 21.17 E Point G 351977 4077104

8 35 42 16.99 N 044 50 58.62 E Point H 345355 4074146

9 35 41 17.04 N 044 49 07.80E Point I 342768 4067294

10 35 45 17.00 N 044 43 30.00 E Point J 304710 4067356

11 35 55 12.00 N 044 30 17.08E Point K 298547 4071762

12 35 55 12.00 N 044 22 48.00 E Point L 309823 4087727

13 36 03 57.59N 044 22 48.00 E Point M 284825 4105440

Point N 265980 4105251

Point O 272243 4112089

Shaikan Sangaw North

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 36 48 55 43 18 20 348 857 4075 711 1 35 23 25 N 44 52 18 E 488 339 3916 338

Point B 36 48 42 43 30 59 367 655 4075 019 2 35 28 05 N 45 03 04 E 504 636 3924 948

Point C 36 46 36 43 40 44 382 100 4070 900 3 35 25 02 N 45 06 17 E 509 496 3919 304

Point D 36 44 23 43 39 04 379 577 4066 846 4 35 18 22 N 45 12 49 E 519 410 3907 007

Point E 36 43 56 43 19 48 350 884 4066 467 5 35 09 49 N 45 07 21 E 511 145 3891 192

Point F 36 45 13 43 14 45 343 406 4068 983

Point G 36 48 02 43 16 00 345 355 4074 146

Sulevani Sangaw South

Latitude Latitude
Longitude Longitude
(deg min X (mE) Y (mN) (deg min X (mE) Y (mN)
(deg min sec) (deg min sec)
sec) sec)
Point A 37 03 52 42 35 19 266 595 4105 251 Point A 35 18 22 45 12 49 519 410 3907 007

Point B 37 03 06 42 35 19 285 577 4103 317 Point B 35 05 43 45 25 09 538 210 3883 689

Point C 36 51 26 42 50 24 307 438 4081 196 Point C 35 03 54 45 21 17 532 347 3880 313

Point D 36 48 47 42 46 24 301 378 4076 449 Point D 35 05 32 45 12 04 518 327 3883 273

Point E 36 46 13 42 44 34 298 547 4071 762 Point E 35 09 49 45 07 21 511 145 3891 192

196
 Sarta Shorish

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 36 40 33 43 51 12 397536 4059522 Point A 36 16 15 44 18 01 437 138 4014 203

Point B 36 36 48 44 00 46 411716 4052445 Point B 36 10 39 44 23 25 445 172 4003 813

Point C 36 34 24 43 57 03 406126 4048065 Point C 36 08 07 44 25 44 448 614 3999 114

Point D 36 28 59 44 06 50 420628 4037878 Point D 36 07 06 44 28 04 452 099 3997 205

Point E 36 20 55 44 05 41 418768 4023000 Point E 36 03 58 44 22 48 444 167 3991 447

Point F 36 19 17 44 03 39 415700 4020000 Point F 35 55 12 44 22 48 444 064 3975 253

Point G 36 28 00 43 47 49 392200 4036400 Point G 35 58 20 44 16 10 434 134 3981 101

Point H 36 31 13 43 43 35 385977 4042422 Point H 36 10 45 44 09 30 424 308 4004 160

Point I 36 33 18 43 44 49 387850 4046250

Point J 36 38 30 43 46 13 390066 4955827

Shakrok Rovi
Latitude
Longitude Latitude Longitude
(deg min X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec)
sec)
Point A 36 28 05 44 22 39 444 221 4036 044 Point A 36 46 45 43 40 44 382100 4070900

Point B 36 28 39 44 23 36 445 645 4037 082 Point B 36 44 23 43 53 04 400395 4066302

Point C 36 23 22 44 33 23 460 210 4027 221 Point C 36 40 42 43 51 12 397536 4059522

Point D 36 13 14 44 48 02 482 063 4008 426 Point D 36 38 39 43 46 13 390066 4055827

Point E 36 08 55 44 44 07 476 180 4000 454 Point E 36 33 28 43 44 49 387850 4046250

Point F 36 23 32 44 23 01 444 709 4027 627 Point F 36 31 23 43 43 35 385977 4042422

Point G 36 24 31 44 24 38 447 157 4029 433 Point G 36 32 14 43 29 51 365500 4044300

Qara Dagh Miran

Latitude Longitude Latitude Longitude

X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec) (deg min sec)

Point A 35 28 22 45 12 49 519 366 3925 488 Point A 35 54 09 44 59 05 498 628 3973 147

Point B 35 12 38 45 27 21 541 485 3896 486 Point B 35 50 31 45 04 44 507 123 3966 422

Point C 35 05 40 45 42 06 563 951 3883 730 Point C 35 33 16 45 20 31 531 002 3934 583

Point D 35 00 54 45 39 08 559 448 3874 893 Point D 35 27 32 45 25 00 537 799 3924 011

Point E 34 54 58 45 37 08 556 545 3863 906 Point E 35 21 02 45 18 58 528 718 3911 965

Point F 35 05 43 45 25 09 538 210 3883 689 Point F 35 28 22 45 12 49 519 366 3925 488

Point G 35 25 02 45 06 17 509 469 3919 304 Point G 35 47 18 44 51 55 487 823 3960 471

197
 Chia Surkh Topkhana
Latitude Longitude
X(mE) Y(mN)
(deg min sec) (deg min sec)
Point A 34 27 00 N 45 26 07 E Point A 489,078 3,895,533

Point B 34 32 33 N 45 17 30 E Point B 483814.506 3900462.395

Point C 34 38 08 N 45 22 17 E Point C 484283.194 3902337.147

Point D 34 39 03 N 45 27 05 E Point D 485421.436 3913451.744

Point E 34 38 23 N 45 31 16 E Point E 488339 3916338

Point F 34 54 58 N 45 37 08 E Point F 498767 3904840

Point G 34 49 56 N 45 43 03 E Point G 518327 3883273

Point H 506795 3874322

Hawler Safen
Longitude
Latitude Latitude Longitude
(deg min X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec)
sec)
Point A 26 26 24 43 30 32 366 358 4033 785 Point A 36 25 54 44 17 47 436 930 4032 054

Point B 36 24 29 43 41 30 382 700 4030 000 Point B 36 23 32 44 23 01 444 709 4027 627

Point C 36 18 05 43 51 10 397 000 4106 000 Point C 36 08 55 44 44 07 476 180 4000 454

Point D 36 17 06 44 00 32 411 000 4016 000 Point D 36 07 12 44 43 12 474 803 3997 295

Point E 36 10 45 44 09 30 424 308 4004 160 Point E 36 07 16 44 35 48 463 692 3997 443

Point F 36 02 59 43 56 43 405 000 3990 00 Point F 36 13 11 44 29 21 454 088 4008 427

Point G 35 58 25 43 52 03 397 891 3981 622 Point G 36 19 23 44 20 36 441 059 4019 967

Point H 36 05 21 43 43 18 384 915 3994 592 Point H 36 23 44 44 14 21 431 780 4028 102

Point I 36 02 47 43 37 05 375 507 3989 979 Point I 36 25 54 44 17 47 436 930 4032 054

Point J 36 10 49 43 27 33 361 433 4005 036 Point J 36 23 32 44 23 01 444 709 4027 627

Point K 36 13 04 43 33 10 369 919 4009 088 Point K 36 08 55 44 44 07 476 180 4000 454

Point L 36 11 48 43 35 07 372 800 4006 700 Point L 36 07 12 44 43 12 474 803 3997 295

Point M 36 17 27 43 41 25 382 400 4017 000 Point M 36 07 16 44 35 48 463 692 3997 443

Point N 36 18 48 43 33 01 369 860 4019 675 Point N 36 13 11 44 29 21 454 088 4008 427

Point O 36 22 25 43 31 58 368 276 4026 378 Point O 36 19 23 44 20 36 441 059 4019 967

198
 Qush Tapa Kurdamir
Longitude
Latitude Latitude Longitude
(deg min X (mE) Y (mN) X (mE) Y (mN)
(deg min sec) (deg min sec) (deg min sec)
sec)
Point A 36 10 45 44 09 30 424 308 4004 160 Point A 34 38 8 45 22 17 534031.75 3832686.29

Point B 35 58 20 44 16 10 434 134 3981 101 Point B 34 47 44 44 55 3 492441.35 3850381.01

Point C 35 55 12 44 22 48 444 064 3975 253 Point C 34 57 46 44 56 51 495219.19 3868916.11

Point D 35 50 54 44 11 28 426 445 3958 058 Point D 34 58 50 45 1 33 502353.68 3870875.46

Point E 35 45 50 44 11 28 426 876 4030 768 Point E1 35 5 31 45 12 4 518326.91 3883273.04

Point F 35 58 25 43 52 03 397 891 3981 622 Point E2 35 3 54 45 21 17 532347.44 3880312.81

Point G 36 02 59 43 56 43 405 000 3990 000 Point E3 35 5 43 45 25 9 538210.27 3883689.15

Point F 34 54 58 45 37 8 556544.53 3863905.79

Point G 34 48 23 45 31 16 547673.04 3851704.89

Point H 34 39 3 45 27 5 541352.78 3834401.17

Source: PSCs published on the KRG’s website

199
Annex 10 – Map of Mineral locations in Iraq

200
Annex 11 – Reporting Companies: International Oil
Buyers

Company Name

API GS CALTEX SINGAPORE PTE. LTD.

BHARAT OMAN GUNVOR

BHARAT PETROLEUM HELLENIC

HINDUSTAN PETROLEUM CORPORATION
BP OIL
LIMITED
CANAL HPCL-MITTAL

CEPSA INDIAN

CHENNAI PETROLEUM CORPORATION LTD IPLOM

CHEVRON JX NIPPON OIL

CHINA INTERNATIONAL KOCH SUPPLY & TRADING

CHINA NATIONAL MOTOR OIL

CHINA OFFSHORE OIL NORTH PETROLEUM

ENI TRADING PERTAMINA ( PERSERO )

ESSAR OIL PERTAMINA ENERGY SERVICE

EXXON MOBIL SALES AND SUPPLY CORPORTION
PETRO DIAMOND
GALLOWS
LITASCO PETROBRAS

PERTAMINA ENERGY SERVICE SARAS TRADING SA.

PETRO DIAMOND SHELL

PETROBRAS SINOCHEM

PERTAMINA ENERGY SERVICE SK ENERGY

PETRO DIAMOND SOCAR

TOTSA TOTAL VALERO MARKETING &SUPPLY COMPANY

TOYOTA VITOL

TUPRAS

201
Annex 12 – Reporting Companies: International Oil
Companies (working in Iraq under licensing round
service contracts)
Company Name
AL WAHA PETROLEUM
BP
PETROCHINA RUMAILA
CNOOC IRAQ
DRAGON OIL (BLOCK9)LIMITED
EGYPTIAN GENERAL PETROLEUM
ENI IRAQ B.V
EXXONMOBIL IRAQ
GAZPROM NEFT BADRA B.V.
JAPEX
KOGAS BADRA B.V.
KOGAS IRAQ B.V
KUWAIT ENERGY COMPANY
LUKOIL Mid-East Ltd
OCCIDENTAL IRAQ B.V
PERTAMINA
PETROCHINA HALFAYA
PETROCHINA WEST QURNA
PETRONAS BADRA
PETRONAS GARRAF
PETRONAS HALFAYA
PETRONAS MAJNOON
SHELL MAJNOON
SHELL WEST QURNA
TOTSA TOTAL
TP BADRA LTD.
TP MISSAN
Basra Oil Company

202
 Annex 13 - DFI 2016 Statement of Proceeds of Oil
Export Sales
Development Fund for Iraq

STATEMENT OF CASH RECEIPTS AND PAYMENTS

For the year ended 31 December 2016

IN THOUSAND USD

2016 2015

Total export sales of petroleum as reported by SOMO 30,684,570 35,457,722

Less:

Demurrage claims deducted from export sales invoices )91,011( )80,508(

Proceeds deposited in Oil Proceeds Receipts Account

)4,525,505( )2,024,192(
after end of period

Add:

Proceeds deposited in Oil Proceeds Receipts Account

2,026,487 3,993,419
related to prior export sales invoices

Amounts transferred by the Central Bank of Iraq for

0 5,698,776
crude oil shipments by international oil companies

Interest on delayed bank transfers 21 8

Total Proceeds deposited in Oil Proceeds Receipts

28,094,562 43,045,225
Account

Amounts transferred to the United Nation

0 0
Compensation Fund (5%)

Net proceeds deposited in the Development Fund for

28,094,562 43,045,225
Iraq (95%)

203
 Annex 14 – Breakdown of training expenditures
The following table presents a breakdown of training expenditures incurred by CNOOC Iraq in relation
to Missan fields:

Budgeted
Training Training Amount paid
No. of training Training
Training course Name accredited Cost during 2016
beneficiaries amount requirement
hours (USD) (USD)
(USD)

Programmable Logic
1,386 11 192,700 120,753 120,753 TTS Fund
Controllers Training

Petroleum Accounting &

1890 15 209,475 205,000 205,000 TTS Fund
Treasury

Senior safety shift 2 2142 17 244,388 220,237 220,237 TTS Fund

Instrumentation
900 15 17,250 16,500 16,500 TTS Fund
Process Control Shift 2

Instrumentation
840 14 17,250 16,500 16,500 TTS Fund
Process Control Shift 3

Diesel Generators/
Engines Maintenance 780 13 17,250 16,500 16,500 TTS Fund
Shift 3

Project Management
570 19 9,000 8,250 8,250 TTS Fund
shift 1

Project Management
630 21 9,000 8,250 8,250 TTS Fund
shift 2

Pump Maintenance Shift

900 15 17,250 16,500 16,500 TTS Fund
3

IELTS Scholarship N/A 4 1,260 1,260 1,260 TTS Fund

Lab Equipment for

N/A 1 850,000 620,090 59,609 TTS Fund
PRDC

Training Center N/A 1 4,000,000 3,426,600 466,650 TTS Fund

204
 Budgeted
Training Training Amount paid
No. of training Training
Training course Name accredited Cost during 2016
beneficiaries amount requirement
hours (USD) (USD)
(USD)

Valve Maintenance Shift

960 16 17,250 16,500 16,500 TTS Fund
1

Project Management
660 22 9,000 8,250 8,250 TTS Fund
shift 3

Performance Appraisal
420 14 9,000 8,250 8,250 TTS Fund
Shift 1

Performance Appraisal
450 15 9,000 8,250 8,250 TTS Fund
Shift 2

Performance Appraisal
360 12 9,000 8,250 8,250 TTS Fund
Shift 3

NASP Constructions 690 23 646,00 646,00 - TTS Fund

NASP General Industry 600 20 1,485 1,485 - TTS Fund

Total 5,639,558 4,727,425 985,272

Source: CNOOC Iraq

205
 Annex 15 – National oil and gas companies
mechanisms for calculating production quantities
and production costs
i. Missan Oil Company: the following section was prepared by Missan Oil Company

Mechanism of measuring crude oil production quantities:

- Crude oil produced is measured using metering systems of financial accounting and correcting (Net
Standard Volume) using daily measurement records. The quantities are confirmed by performing
monthly reconciliation
- Excess crude oil returned to Missan refinery is calculated using installed meters. The quantities are
confirmed by performing daily reconciliation.
- At the beginning of the measurement, crude oil in storage tanks is calculated according to the
beginning balance inventory
- At the end of the measurement, crude oil in storage tanks is calculated according to the ending
balance inventory
- Crude oil produced by each field is calculated according to the following criteria:
o Ending balance inventory is deducted from beginning balance inventory and the result (±)
is added or subtracted to/from the total processed quantity
o Excess oil quantity is deducted from total processed quantity

Crude oil field production = total processed quantities – returned excess ± inventory difference

- Final quantities are divided among the production fields across the Company using a correction
factor

The mechanism of measuring extracted gas amounts

- Gas produced for the field = standard amount of crude oil produced x GOR value for the field ÷
1,000,000 (extracted gas is measured using Million Cubic Feet per Day Gas)
- In the fields where meters have been installed and are operating, produced gas is calculated using
metering systems. Monthly reconciliations are performed and documented in jointly prepared
minutes of meetings.

Calculating crude oil barrel cost:

production cost + production services cost – production residuals + beginning balance inventory –
ending balance inventory + marketing costs + administrative services costs + 382 and 3834
accounts + account 391 – Gas costs – account 42,43,45,46,48,49.
1) Missan Oil Company does not have a specific mechanism of calculating gas cost (since gas
is associated with crude oil production). Therefore, the Ministry determined a fixed price
amounting to IQD50/M3
2) The Refinery Company and the Ministry of Electricity are accounted according to the cost
of crude oil barrel, which is determined prior to the beginning of each financial year
according to the above formula (taking into consideration the production costs for the next
year).
3) The Refinery Company and the Ministry of Electricity are accounted for sales gas according
to a fixed price IQD50/M3

206
 4) Crude oil transfer cost = quantity of processed barrels / 6.2898 square meter (every 1000
M3 is for IQD 250)

ii. North Oil Company: the following section was prepared by North Oil Company

1. The mechanism of measuring the quantities of extracted oil

1) Quantity of extracted crude oil is measured through performing production tests in the fields
using insulators and test tanks, and corrected according to standard conditions
2) Total daily production rates are measured and corrected to meet standard conditions
according to the average daily production rates per reservoir
3) Quantity of oil produced is measured depending on the property transfer meters of the
drainage outlets and beneficiaries (export, refineries, stations, electricity, etc.)
4) Quantity of crude oil extracted from each reservoir is amended and corrected to meet the
standard conditions

2. The mechanism of measuring the quantities of extracted gas

A. Associated Gas
1) Extracted gas quantity is measured through performing production tests of the reservoirs
located in the fields using gas meters installed on test insulators (if found), and corrected
according to standard conditions
2) Total daily production rates are measured and corrected to meet standard conditions
according to the quantity of associated gas received from the company's compression
stations
3) Final quantity of extracted associated gas is measured in accordance to North Gas Company
monthly reports of associated gas discharge. Periodic reconciliations are performed
between the two companies

B. Dome Gas
1) Quantity of dome gas extracted from Jambur and Ajil fields is measured through performing
production tests of the reservoirs located in the fields using gas meters installed on test
insulators (if found), and corrected according to standard conditions
2) Total daily production rates are measured and corrected to meet standard conditions
according to the quantity of dome gas received by South Jambur and Ajil fields. The rates
are measured based on the beneficiary’s property transfer meters (North Gas Company,
National Power Plants). Total daily production rates are calculated, and corrected, to meet
standard condition
3) Final quantity of extracted dome gas is measured in accordance to the beneficiaries monthly
reports of fuel gas discharge
4) Quantity of dome gas extracted from each reservoir is amended and corrected to meet
standard rates, and is finally used to calculate the quantity of dome gas extracted from both
fields (Jambur and Ajil)

3. The mechanism of calculating production costs of a crude oil barrel

𝑁𝑒𝑡 𝑜𝑝𝑒𝑟𝑎𝑡𝑖𝑛𝑔 𝑐𝑜𝑠𝑡𝑠
Production costs of a crude oil barrel =
𝑁𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑐𝑟𝑢𝑑𝑒 𝑜𝑖𝑙 𝑏𝑎𝑟𝑟𝑒𝑙𝑠 𝑝𝑟𝑜𝑑𝑢𝑐𝑒𝑑

207
4. The mechanism of calculating production costs of Million Cubic Feet per Day Gas
𝐺𝑎𝑠 𝑝𝑟𝑜𝑑𝑢𝑐𝑡𝑖𝑜𝑛 𝑜𝑝𝑒𝑟𝑎𝑡𝑖𝑛𝑔 𝑐𝑜𝑠𝑡𝑠
Production costs of Million Cubic Feet per Day Gas =
𝑄𝑢𝑎𝑛𝑡𝑖𝑡𝑦 𝑜𝑓 𝑝𝑟𝑜𝑑𝑢𝑐𝑒𝑑 𝑔𝑎𝑠

5. The mechanism of calculating crude oil barrel returns to refineries and electricity

A- Refineries companies: calculated using the planned price (after confirming it), and at the end of
the year. Differences between the planned price and actual price are settled, and according to
central instruction, the Ministry of Finance accounts for the difference.

B- Power Plants: calculated using a planned price (after confirming it).

6. The mechanism of calculating Million Cubic Feet per Day Gas sales returns to gas companies

Calculated using a planned price and under the company’s budget after approving it. Differences
between schematic and real prices are settled at year-end.

7. The mechanism of calculating transportation costs of a crude oil barrel within the extractive
companies’ network
𝐺𝑟𝑜𝑠𝑠 𝑜𝑝𝑒𝑟𝑎𝑡𝑖𝑛𝑔 𝑐𝑜𝑠𝑡𝑠 𝑟𝑒𝑙𝑎𝑡𝑒𝑑 𝑡𝑜 𝑜𝑖𝑙 𝑡𝑟𝑎𝑛𝑠𝑝𝑜𝑟𝑡𝑎𝑡𝑖𝑜𝑛
Transportation costs =
𝑄𝑢𝑎𝑛𝑡𝑖𝑡𝑖𝑒𝑠 𝑜𝑓 𝑏𝑎𝑟𝑟𝑒𝑙𝑠 𝑝𝑟𝑜𝑑𝑢𝑐𝑒𝑑

8. The mechanism of calculating transportation costs of gas within the Pipeline Companies’ network
:

𝐺𝑟𝑜𝑠𝑠 𝑜𝑝𝑒𝑟𝑎𝑡𝑖𝑛𝑔 𝑐𝑜𝑠𝑡𝑠 𝑟𝑒𝑙𝑎𝑡𝑒𝑑 𝑡𝑜 𝑜𝑖𝑙 𝑡𝑟𝑎𝑛𝑠𝑝𝑜𝑟𝑡𝑎𝑡𝑖𝑜𝑛

Transportation costs =
𝑄𝑢𝑎𝑛𝑡𝑖𝑡𝑦 𝑜𝑓 𝑔𝑎𝑠 𝑝𝑟𝑜𝑑𝑢𝑐𝑒𝑑

208
iii. Basra Oil Company: the following section was prepared by Basra Oil Company

First: The mechanism of crude oil production (measured using the two methods specified below
(the unit is in barrels)):

Method 1: According to Metering Systems:

The quantity of crude oil produced is measured using metering systems of financial accounting
and correcting (Net Standard Volume) using daily measurement records. Quantities are confirmed
using monthly reconciliation procedures between all parties involved in the crude oil production
(fields and companies).

Method 2: According to (ULLAGE):

This method is no longer present in production accounts due to the installation of meter systems
for financial accounting (as in the first method). In addition, this method is considered an
alternative measurement method and is used in the event of malfunction or maintenance of meter
systems for long periods, whilst taking into consideration the application of all standard conditions
when used.

Method 3: Reverse balancing:

1) Crude oil quantities provided for internal drainage (electricity and refineries) are calculated
using metering systems, and corrected to standard conditions.
2) Crude oil exported via the southern ports is calculated either by using metering systems, or
“ULLAGE”. The quantities are corrected to standard conditions, and bills of lading showing
the exported quantities are issued.
3) Calculating total processing quantities (internal + export).
4) Inventory readings of crude oil warehouses are recorded at 12:00 am at the beginning of
the period.
5) Inventory readings of crude oil warehouses are recorded at 12:00 pm at the end of the
period.
6) The inventory ending balance shown in point 5 above is deducted from the inventory
beginning balance shown in point 4 above, the result (±) is then added or subtracted to/from
the total processed quantities.
7) Excess oil returned from Basra Refinery is measured using the meter found in Basra
Refinery, and is corrected to the standard conditions through daily measurements. The
quantities are confirmed by performing monthly reconciliations.
8) Condensate mixed with exported oil is measured using metering systems found in the ‘Siba
field’. The quantities are confirmed by performing monthly reconciliations.
9) Field production is calculated using the following equation:
Crude oil field production = total processed quantities (point 3) ± inventory difference
(point 6) – returned excess (point 7) – condensates (point 8)

Based on the above, and to avoid any difference between the first and third methods; the quantities
in method 1 are corrected using a ‘Correction Factor’.

Second: The mechanism of measuring extracted gas quantities (measured using the two methods
specified below):

209
 Method 1: According to metering systems:
In the fields where meters have been installed and are operating, produced gas quantities are
measured using metering systems. Monthly reconciliations are performed and documented in
jointly prepared minutes of meetings.

Method 2: According to the “GOR” value:

1) Produced gas quantity is measured using a “GOR” value for each reservoir (depending on
the oil field).
2) The below equation illustrates the mechanism of calculating gas quantities for each field:
Gas produced for the field = standard quantity of crude oil produced x GOR value for the
field ÷ 1,000,000 (extracted gas is measured using mmscfd)

Method of calculating barrel cost:

 Total expenditures
Wages
Commodity Supplies
Service Supplies
Depletion
Contributions
Prior years' expenses related to the activity
 deductions from total expenditures
Affiliates’ Wages
Depreciation expenses
Miscellaneous Revenue
Service Activity Revenue
Prior years' revenue related to the activity
= Net Expenditures divided by number of produced barrels
= Barrel cost without profit margin * profit margin
= Actual barrel cost including profit margin

iv. Midland Oil Company: the following section was prepared by Midland Oil Company

The method used by Midland Oil Company to calculate the quantity of crude oil produced in its fields
is based on the budget formula as follows:

Production = (Change in inventory) + exports – received quantities

According to the MdOC, this method is used by most extractive companies including the IOCs
investing in some of the oilfields managed/owned by the company. There are measurement meters
along production lines to measure crude oil quantities produced, noting that measurement of
quantities is in accordance with standard conditions.

There are two methods to calculate the quantity of associated gas produced:

1) The use of meters along the gas line leaving the gas isolators, and this is the method adopted
by the company in measuring gas quantities produced from producing fields.
2) Relying on the gas/oil ratio (GOR) of produced oil, which according to MdOC is an old method
that is not adopted by the company.

Method of calculating the production cost of barrel of crude oil:

 Barrel cost = total expenses/ total production

210
  Profit margin = 20% of barrel cost
 Final price = barrel price + profit margin

Method of calculating the production cost of mmscfd of gas:

The company does not have a separate formula for calculating the value of gas production, since all
gas produced is associated gas, and not free gas, and therefore the cost is calculated within the cost
of crude oil production.

Method of calculating the value of proceeds from the sale of a barrel of crude oil to refineries and
electricity directorates:

Total sales revenue = Quantities prepared (barrels) * agreed price/barrel

v. North Gas Company: the following section was prepared by North Gas Company

The mechanism of measuring gas is summarized as follows:

1) North Oil Company (NOC) provides North Gas Company (NGC) with the Associated
Petroleum Gas (APG) and the gas from domes via a gas receiving terminal using four multi-
track ultrasonic meters, which are 0.5% accurate and designed according to a measurement
and calibration criteria. The multi-track ultrasonic meters belong to NOC, and are approved
by both, NOC and NGC. NOC does not have special meters for measuring the quantities of
gas sent to NOC
2) Hydrocarbon liquids and condensate are measured using four thermally corrected turbine
meters
3) Sales gas produced for Oil Pipelines Company is measured using two ultrasonic meters
operating under both production lines
4) Measured quantities are reconciled and documented in the minutes of meetings held
between the relevant parties according to the following manner:
i. The opening balance is recorded at 12:00 am on the first day of each month
ii. The ending balance is recorded at 12:00 am on the last day of each month

211
vi. Basra Gas and South Gas Company: the following section was prepared by Basra Gas Company

Contract Price for Raw Gas (CPRG)

The Contract Price for Raw Gas for any calendar month shall be determined in accordance with the
following formula:

CPRG = [(1-ML) * IPRG * Cx] + [(ML * RPRG)]

Where:

CPRG is the Contract Price for Raw Gas applicable in the relevant Month, expressed in U.S Dollars
per Mmscf;
Cx is an inflation factor = (1 + 0.02)n, provided that during the first year after the BGDA
Effective Date, Cx shall be 1;
N is the number of years, expressed as an integer, between the BGDA Effective Date and the
date of calculation of the Contract Price for Raw Gas;
ML is the Matching Level determined on the most recent Calculation Date, expressed to four
decimal places;
IPRG is the lnitial Price for Raw Gas, being USD 16.95 per MMscf; and
RPRG is the Reference Price for Raw Gas applicable in the relevant Month, expressed in Dollars
per MMscf.

Calculation of n and Cx:

BGDA Effective Date is November 2011, so n = 5, and Cx = 1.1041

Calculation of ML:-
𝐴
𝑀𝐿 =
𝐵
( 𝑥 𝐷)
𝐶

where:

A is the sum of Capitalisable Costs incurred and Cash Calls paid by the Private
Shareholders up to the Calculation Date (without double counting), expressed in
U.S. Dollars;
B is the sum of the Proportionate Shares of the Private Shareholders;
C is the Proportionate Share of SGC; and
D is the sum of the lnitial Asset Transfer Price plus the Additional Assets Transfer
Price of any Additional Assets which have been the subject of a completion on or
prior to First Completion Date, expressed in U.S Dollars

Calculation of A:

212
 A is the sum of Capitalizable Costs incurred and Cash Calls paid by the Private Shareholders
up to the Calculation Date (without double counting), expressed in U.S. Dollars;

Calculation of D:

D is the sum of the Initial Asset Transfer Price plus the Additional Assets Transfer Price of
any Additional Assets which have been the subject of a Completion on or prior to First
Completion Date, expressed in U.S Dollars

Calculation of Reference Price for Raw Gas (RPRG):

The Reference Price for Raw Gas ("RPRG") for any Month shall be determined in accordance with the
following formula:

RPRG = [(X * R) + ((1 – X) * W)] / V

Where:
V is the total volume of Raw Gas supplied during the immediately preceding month*,
expressed in million standard cubic feet (mmscf)

X is a constant determined for each calendar year. For the calendar year in which the
BGDA Effective Date occurs, "X" shall be equal to 0.1000 (or 10%).

R is the sum, expressed in U.S Dollars and without double counting, of:
i. the Dry Gas Payment for the immediately preceding month*; plus
ii. the LPG Payment for the immediately preceding month; plus
iii. the Condensate Payment for the immediately preceding month; plus
iv. the sales proceeds from the sale of other Petroleum Products (if any) and Ancillary
Products (if any) by BGC in the immediately preceding month pursuant to any Sale
and Purchase Agreement; plus
v. the sales proceeds from the sale of electricity (if any) by BGC in the immediately
preceding month pursuant to any agreement for such sales (which electricity has
been produced using Raw Gas delivered to BGC by SGC); less
vi. all Taxes (other than corporate income tax) payable by BGC in respect of the sale of
any of the aforementioned products in any month (less any value added or other
taxes that are recovered in the relevant month, either by deduction from amounts
payable to a Government Agency or through a refund); less
vii. the cost of any transport and delivery beyond the applicable delivery points for the
aforementioned products to the extent that such costs are incurred by BGC; less
viii. any fees paid to SOMO pursuant to the SOMO Marketing Agency Agreement in
respect of the sale of the aforementioned products.

W is the windfall adjustment expressed in US Dollar

Calculation of V:

213
V is the total volume of Raw Gas supplied during the immediately preceding month, expressed
in million standard cubic feet (mmscf).

Calculation of W
W is the windfall adjustment expressed in US Dollar which is determined in accordance with
following formula:
W=K x DV x D
Where:
K is a constant with value 0.75;
DV is the volume of Dry Gas sold under the Dry Gas Supply Agreement during the immediately
preceding month expressed in MMBtu;
D equals Contract Price for Dry Gas Price minus Baseline Price for Dry Gas Price, expressed in
USD/MMBtu.
Both contract Price for Dry Gas and Baseline Price for Dry Gas are for the same month as
the volume of Dry Gas used in the calculation for W

Calculation of D
D equals Contract Price for Dry Gas Price minus Baseline Price for Dry Gas Price, expressed in
USD/MMBtu.

Calculation of Baseline Price for Dry Gas

The Baseline Price for Dry Gas, expressed in USD/MMBtu, is determined in accordance with the
following formula:

Baseline Price for Dry Gas = [(1-ML] * (IPDG * CX)] + [(ML * BP)]

Where,
IPDG is the Initial Price for Dry Gas, being USD 1.04 per MMBtu;
CX is an inflation factor = (1 + 0.02) n, provided that during the first year after the
BGDA Effective Date, CX shall be 1:
n is the number of years, expressed as an integer, between the BGDA Effective Date
and the date of calculation of the Contract Price for Raw Gas;
ML is the Matching Level determined on the most recent Calculation Date, expressed
to four decimal places;
BP represents Contract Price for Dry Gas under assumed pricing conditions for Brent
Crude Oil, expressed in US Dollar per MMBtu,

Calculation of BP

214
BP represents contract Price for Dry Gas under assumed pricing conditions for Brent Crude Oil,
expressed in US Dollar per MMBtu, and determined in accordance with the following
formula:
BP = F * [(BB * CX * Z) - Y]/ H

Where:
F is a constant with value of 0.336;
BB is a constant with value 50 reflecting the baseline value of Brent Crude Oil;
Z is a constant with value 0.82 reflecting the slope in the linear relationship between
HSFO prices and Brent Crude Oil prices;
Y is a constant with value 6 reflecting the intercept in the linear relationship between
HSFO prices and Brent Crude Oil prices; and
H is a constant with value 5.794 reflecting the heating value of a metric ton of
HSFO expressed in MMBtu.

Calculation of Contract Price for Raw Gas (CP RG):

Putting all the above values in the formula for Raw Gas Price:
CPRG= [(1-ML) * IPRG * CX] + [(ML * RPRG)]

Calculation of real price of dry gas:

The real price of dry gas refers to the dry gas price after deducting the windfall component and it
is always less than the contract price of dry gas. The Windfall component "W" provides a discount
to adjust for the variation of the global prices of Dry Gas, this adjustment is included in the Raw
Gas pricing formula as per the agreement.

This calculation is detailed in the following steps.

First, the Windfall component is deducted from the total Dry Gas payment instead of being added
to the Raw Gas payment.

Second, the Windfall Discount is calculated by dividing the Windfall component by the volume of
dry gas of the current month.

The Real Price of Dry Gas is the Effective Price of Dry Gas (CPDG) minus the Windfall Discount.

215
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