Uganda AML & Sanctions Compliance

Uganda — AML & Compliance FAQs

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• Who regulates AML and sanctions compliance in Uganda?

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  AML/CFT compliance in Uganda is overseen by several authorities. The Financial Intelligence Authority (FIA) is Uganda’s primary AML/CFT body — it supervises reporting entities, analyses financial intelligence, coordinates with law enforcement, and issues compliance guidance. The Bank of Uganda (BoU) is the primary prudential supervisor for banks and financial institutions, enforcing risk-based AML/CFT compliance across the sector. The Capital Markets Authority (CMA) supervises securities and investment firms for AML obligations. The Uganda Microfinance Regulatory Authority (UMRA) oversees non-bank financial institutions and microfinance. The Uganda Registration Services Bureau (URSB) administers beneficial ownership compliance for registered businesses. Uganda’s AML framework is anchored in the Anti-Money Laundering Act 2013 and Anti-Money Laundering Regulations 2015, as amended in 2022.

• What is Uganda’s current FATF status?

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  Uganda was removed from the FATF Increased Monitoring list (grey list) in February 2024 after completing its action plan. Uganda was also removed from the EU high-risk jurisdictions list in June 2025, fully normalising its international standing. Uganda is a member of ESAAMLG and remains actively engaged in regional AML/CFT cooperation — Uganda hosted the ESAAMLG 49th Task Force meeting in March–April 2025. While grey list status has been resolved, the FIA has identified areas in the Anti-Money Laundering Act requiring further amendment for full FATF compliance, and VASP regulation remains underdeveloped.

• What AML/CFT obligations apply to businesses in Uganda?

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  Accountable persons under Uganda’s AML Act — including commercial banks, microfinance institutions, forex bureaus, mobile money operators, casinos, real estate agents, accountants, lawyers, and dealers in precious metals — must conduct customer due diligence (CDD) and enhanced due diligence (EDD) for higher-risk relationships, file Suspicious Transaction Reports (STRs) with the FIA, screen customers against UN sanctions lists, implement internal AML/CFT programmes, and maintain records for 10 years. Importantly, a January 2025 amendment to Schedule 2 of the Anti-Money Laundering Act removed NGOs and churches from the list of accountable persons — these entities are no longer subject to STR obligations under the AML Act.

• What are Uganda’s key money laundering and terrorism financing risks?

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  Uganda’s principal ML/TF typologies include: corruption and misappropriation of public funds; proceeds from cross-border smuggling across Uganda’s extensive borders; wildlife and natural resource trafficking; drug trafficking; and terrorism financing risk arising from Uganda’s proximity to conflict-affected jurisdictions — South Sudan, the Democratic Republic of Congo, and Somalia — where armed groups and extremist networks are active. Informal value transfer systems and unregulated mobile money channels are also identified risk vectors. Uganda’s 2024 National Risk Assessment (NRA) identified virtual assets as an emerging risk requiring dedicated regulatory attention.

• What are Uganda’s record-keeping requirements?

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  Uganda’s Anti-Money Laundering Act requires reporting entities to retain transaction records and customer due diligence documentation for 10 years — significantly longer than many regional peers and the FATF’s minimum five-year standard. This applies to all transactions conducted or CDD carried out from the date of the transaction or the end of the business relationship. Compliance teams should ensure document management systems are configured to meet the full 10-year retention requirement.

• What sanctions screening obligations apply to businesses in Uganda?

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  Uganda implements UN Security Council sanctions. Businesses operating in Uganda must screen customers, beneficial owners, and transaction counterparties against the UN consolidated sanctions list. Uganda has no domestic autonomous sanctions list. Given Uganda’s removal from the EU high-risk list in June 2025, EU-regulated counterparties are no longer required to apply enhanced due diligence to Ugandan relationships solely on the basis of EU high-risk country status. US OFAC designations should still be considered for any transaction with a USD exposure or US correspondent relationship.

• How can Anqa Compliance support businesses operating in Uganda?

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  Anqa Compliance provides AML solutions built for the practical realities of compliance in East African markets. Our platform supports risk-based CDD, automated UN sanctions screening, transaction monitoring configured to Uganda’s cross-border and TF typology risks, and STR reporting aligned with FIA Uganda requirements — helping financial institutions and accountable persons demonstrate robust, evidenced compliance as Uganda’s regulatory framework continues to develop post-grey-list.