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Uganda AML & Sanctions Compliance Guide

Compliance Guide 2026

Uganda AML & Sanctions Compliance Guide

Expert guide to navigating Uganda's AML/CFT and sanctions compliance landscape. Essential reading for financial institutions, compliance officers, and regulatory professionals operating in Uganda.

Uganda Compliance Overview

Uganda Country Profile

Uganda exited the FATF grey list in February 2024 after completing its action plan. The Financial Intelligence Authority (FIA) supervises AML/CFT compliance under the Anti-Money Laundering Act 2013. A January 2025 amendment to the AML Act (Schedule 2) excluded NGOs and churches from the definition of accountable persons — a departure from FATF NPO risk guidance.

  • Financial Intelligence Authority (FIA) — Uganda's FIU and primary AML/CFT supervisor
  • Bank of Uganda (BoU) — Prudential supervisor for banks and financial institutions
  • Capital Markets Authority (CMA) — Capital markets supervision

Regulatory Framework

  • Anti-Money Laundering Act 2013 (as amended)
  • Financial Intelligence Authority Act 2014
  • AML (Amendment) Act 2017 — extended obligated entities
  • AML Act Schedule 2 amendment (January 2025) — NGOs and churches excluded from accountable persons

Core obligations:

  • Customer identification and verification (CDD/EDD)
  • STR filing with FIA Uganda
  • 10-year record retention (among the longest in the region)
  • Sanctions screening — UN Security Council lists

FATF Status & Post-Exit Obligations

FATF Grey List Exit — February 2024

Uganda was removed from FATF Increased Monitoring at the February 2024 Plenary. Grey list entry was in June 2020. Post-exit, Uganda continues active domestic supervision and reporting entities are expected to maintain the reforms implemented during the action plan period.

  • Grey list entry: June 2020
  • Grey list exit: February 2024
  • No EU high-risk listing
  • ESAAMLG member — next mutual evaluation cycle pending

NGO/Church Exemption — January 2025

A January 2025 amendment to Schedule 2 of the AML Act excluded NGOs and churches from the definition of accountable persons under Uganda's AML/CFT framework. This removes them from FIA supervision — a departure from FATF Recommendation 8, which requires risk-based supervision of the NPO sector. Financial institutions serving NGO or church customers should apply their own EDD independently of FIA oversight.

  • NGOs and churches excluded from FIA-supervised accountable persons — AML Act Schedule 2 amendment, January 2025
  • Financial institutions must maintain EDD for NGO/church customers on their own risk assessment
  • TF risk through the NGO sector remains a compliance concern regardless of FIA scope change
  • Monitor for FATF follow-up on this regulatory gap at next mutual evaluation

Risk Environment & Typologies

Key Money Laundering Typologies

  • Corruption proceeds — public procurement and government contracting
  • Gold and mineral smuggling from DRC and South Sudan
  • Trade-based money laundering through informal cross-border trade
  • Real estate investment by politically exposed persons
  • Mobile money fraud and misuse

High-Risk Sectors

  • Banking and MFIs — large informal sector interface
  • Mobile money — widespread with limited CDD controls
  • Real estate — cash investment and PEP risk
  • Mining and minerals — cross-border smuggling, DRC gold transit
  • NGO sector — TF misuse risk; NGOs and churches now outside FIA supervision following January 2025 AML Act amendment

Compliance Requirements

STR Reporting & Record Keeping

  • File STRs with FIA Uganda for suspected ML or TF
  • 10-year record retention — one of the region's most stringent requirements
  • Tipping off is prohibited
  • Verify current reporting thresholds and deadlines at fia.go.ug

Sanctions Compliance

  • UN Security Council consolidated list — mandatory screening
  • No autonomous Uganda sanctions list
  • Low direct OFAC exposure — screen for US nexus transactions
  • DRC-linked minerals transactions — verify UN Group of Experts reporting for sanctioned actors

Regulatory Resources

Key Red Flags — Uganda

  • Mineral transactions (gold, coltan) with undisclosed origin or chain of custody
  • NPO accounts with unusual cash flows or cross-border remittances
  • PEP-linked real estate purchases without source of wealth documentation
  • Mobile money patterns inconsistent with customer profile
  • Cross-border transfers to or from DRC or South Sudan without clear trade rationale

Official Resources