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This report sets out Uganda's progress in strengthening anti-money laundering and counter terrorist financing measures since their 2016 assessment. Since its 2016 mutual evaluation, Uganda has made progress in addressing deficiencies; the ESAAMLG has re-rated the country on 13 of the 40 Recommendations.

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 Posted:  09, Nov 18


The ESAAMLG Council of Ministers adopted the Mutual Evaluation Report (MER) to the Republic of Uganda through a Round Robin Process On June 30, 2016. In Line With The Procedures For ESAAMLG 2nd Round Of Mutual Evaluations And Follow-up Process, The ESAAMLG Task Force Of Senior Officials Discussed And Adopted The MER At Its Meeting Held In Arusha, Tanzania In April, 2016. This Is The Second Mutual Evaluation To Be Conducted Under The International Standards On Combating Money Laundering And The Financing Of Terrorism And Proliferation [The Financial Action Taskforce (FATF) Recommendations] Issued In February 2012 And The Revised Methodology For Assessing Technical Compliance With The FATF Recommendations And Effectiveness Of AML/CFT Systems, Issued In 2013.

This Report Highlights The Anti-Money Laundering/Combating Terrorist Financing (AML/CFT) Measures In Place In Uganda And Analyses The Level Of Compliance With The FATF Recommendations And The Level Of Effectiveness Of Uganda’s AML/CFT Systems. It Also Identifies The Gaps In Uganda’s AML/CFT Regime And Provides Recommendations On How It Could Further Be Strengthened.

Key Highlights Of The Report Are As Follows:-

  • The AML/CFT Legal And Institutional Frameworks Of Uganda Have Been Strengthened Following The Enactment Of The Anti-Money Laundering Act In 2013 And The Establishment Of The Financial Intelligence Authority. However, There Are Still Significant Gaps In The Legal Framework And Apparent Conflicts Between The AMLA And The Financial Institutions Act, 2004 With Respect To Suspicious Transaction Reporting.
  • Since The AML/CFT Regime Is Relative New, There Is Low Level Of Effectiveness Especially In The Area Of AML/CFT Supervision, Analysis And Use Of Financial Intelligence, ML/TF Investigation And Prosecutions. Some Sectors Of Reporting Institutions Such As Designated Non-financial Businesses And Professions, Are Yet To Start Implementing The Laws And Regulations.
  • On Uganda’s Risk Profile, The Assessors Noted That The Country Has Not Yet Carried Out National Or Sectoral ML/TF Risk Assessment. Hence, There Is Very Little Understanding Of ML/TF Risks By The Authorities And Reporting Institutions (except For Subsidiaries Of International Banks). As Such, Authorities And The Reporting Institutions Have Not Put In Place Mitigating Measures Relevant And Commensurate With The Nature And Severity Of Risks Facing The Country.
  • The Report Further Notes That Uganda Doesn’t Have The Necessary Legal Framework And Administrative Arrangements To Facilitate Effective Implementation Of Targeted Financial Sanctions Related To Terrorism, Terrorist Financing And Proliferation In Compliance With The United Nations Security Council Resolutions 1267 And 1373, Including The Successor Resolutions.
  • Absence Of Legal Provisions In The AMLA And The Respective Sectoral Laws Which Designates Authorities With The Responsibility For AML/CFT Supervision And Lack Of Administrative Sanctions May Have Contributed To The Low Level Of Compliance By Reporting Institutions.
  • On The Way Forward, The Report Urges Uganda, As A Matter Of Priority, To Carry Out National Or Sectoral Money Laundering And Terrorism Financing (ML/TF) Risk Assessment, Develop An Informed Risk-based Action Plan Commensurate With The Identified ML/TF Risks And Deficiencies Highlighted In This MER And Implement The Recommendations.

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 Posted:  09, Jan 17


The ESAAMLG Council of Ministers approved and adopted the mutual evaluation report for the Republic of Uganda at its August 2007 meeting.  The report was prepared by the World Bank. Before its approval by the Council of Ministers the report was discussed and adopted by the ESAAMLG Task Force of Senior Officials at its meeting in August 2007.
The report records the significant steps taken by the authorities in Uganda to develop and implement the anti- money laundering (AML) /combating the financing of terrorism (CFT) framework.  An AML Bill has been approved by Cabinet while amendments have been brought to the Financial Institutions Act in 2004 to address some of the preventive measures that apply to financial institutions.  Uganda took important legislative steps to fight terrorism and terrorist financing with the adoption of the Anti-Terrorism Act 2002.

The report also identifies some areas of deficiencies in the AML/CFT regime of Uganda.  It makes comprehensive recommendations on the actions that the authorities in Uganda need to take in the short and medium terms to fully meet the international standards.

ESAAMLG Secretariat
March 2009

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 Posted:  08, Jan 17