As He Exits, Bremer Leaves Contractors With Limited Immunity From Iraqi Law
On June 27, 2004, one day before the Coalition Provisional Authority ("CPA") turned over authority to the Iraqi Interim Government ("IIG"), the CPA revised its Order Number 17, addressing the status of contractor personnel when performing contracts or grant agreements with the CPA, the Multinational Force (MNF), or any "Sending State" (i.e., country providing support for the MNF or humanitarian or reconstruction assistance to Iraq). The revised order, which continues in effect after the transition to the IIG, provides a level of immunity from Iraqi laws or regulations -- including licensing or registration requirements -- with respect to the terms and conditions of such contracts or grants and from Iraqi legal process, but only with respect to "acts performed . . . pursuant to the terms and conditions of a Contract or any sub-contract thereto" and subject at any time to waiver by the Sending State.
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