Higher Risk
 
Medium Risk
 
Info n/a
 
Lower Risk
Bilateral exchange of information
Agreements in place?
    No
Sanctions:

None applicable

____________________________________________________

Offshore Jurisdiction Blacklists:

Information unavailable.

____________________________________________________

US State Department Money Laundering Report - 2011:

Uganda is not a major hub for narcotics trafficking or terrorist
financing, but it is a growing site for money laundering. Ugandan
efforts to combat money laundering are hampered by the
continued absence of comprehensive anti-money laundering
legislation, severe resource constraints, and internal government
corruption. Counterfeit U.S. currency is a recurring problem.
Uganda’s inability to monitor formal and informal financial
transactions, particularly along porous borders with Sudan,
Kenya, Tanzania, and the Democratic Republic of Congo render
Uganda vulnerable to more advanced money laundering activities
and potential terrorist financing. Money laundering in Uganda
derives from a wide range of activities, including government
corruption, misappropriation of public funds and foreign
assistance, abuse of the public procurement process, abuse of
religious charities, land speculation, car theft, arms and natural
resource smuggling, and exchange control violations. Uganda’s
active informal economy also provides a fertile environment for
money laundering as Uganda’s black market for smuggled and
counterfeit goods takes advantage of porous borders and lack of
customs and tax collection enforcement capacity.

DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO

CRIMINALIZATION OF MONEY LAUNDERING:

“All serious crimes” approach or “list” approach to predicate
crimes: Not applicable

Legal persons covered: criminally: NO civilly: NO

CRIMINALIZATION OF TERRORIST FINANCING:

Ability to freeze terrorist assets without delay: NO

UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES

(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)

KNOW-YOUR-CUSTOMER RULES:

Covered entities: Banks, finance companies and microfinance
institutions, foreign exchange bureaus, insurance companies and
the securities sector

Enhanced due diligence procedures for PEPs: Foreign: NO
Domestic: NO

SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:

Covered entities: Banks, finance companies and microfinance
institutions, foreign exchange bureaus, insurance companies and
the securities sector

Number of STRs received and time frame: 80 reports in 2010

Number of CTRs received and time frame: Not applicable

MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:

Prosecutions: 0

Convictions: 0

Assets forfeited: criminally: Not available civilly: Not available

RECORDS EXCHANGE MECHANISM:

With U.S.: NO

With other governments/jurisdictions: NO

Uganda is a member of the Eastern and Southern Africa Anti-
Money Laundering Group (ESAAMLG), a Financial Action Task
Force-style regional body. Its most recent mutual evaluation
report can be found here: http://www.esaamlg.
org/userfiles/UGANDA_MER1.pdf

ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:

Uganda has not criminalized money laundering. The Uganda Anti-
Money Laundering Committee (UAMLC), comprised of multiple
Ugandan government ministries and chaired by the Bank of
Uganda (BOU), has worked with advisors to draft a
comprehensive anti-money laundering (AML) bill based on
international standards. The UAMLC completed the draft AML bill
in 2003, and Cabinet approved the bill in January 2005. The draft
legislation was submitted to Parliament in 2009 and has not come
up for a vote.

Current efforts to combat money-laundering are piecemeal and
based on other legislation such as the Anti-Terrorist Act of 2002
and the Financial Institutions Act of 2004. The Anti-Terrorist Act
makes terrorist financing illegal, but does not place it in the
overarching framework of money laundering, and there is no
evidence that it has been used to effectively prosecute financiers
of terrorism. There is no suspicious transaction reporting
requirement for terrorist financing under this act.

The Financial Institutions Act provides the BOU with the ability to
freeze accounts they believe hold funds which are the proceeds
of crime, but does not provide procedures for releasing funds or
forfeiture. It also gives the BOU authority to set know-your-
customer and suspicious transaction reporting requirements for
financial institutions, foreign exchange bureaus, and deposit-
taking microfinance institutions. However, reporting procedures
remain unclear and insufficient whistleblower protection limit the
efficacy of these regulations. The Insurance Commission and
Capital Markets Authority also have know-your-customer and
suspicious transaction reporting guidelines for their regulated
entities, but no firm regulations.

The Criminal Investigations Department (CID) of the Ugandan
Police Force is responsible for investigating financial crimes.
However, until Parliament approves the AML legislation, the CID
maintains only limited authority to investigate and prosecute
money laundering violations. The CID is understaffed and lacks
adequate training in financial investigation techniques related to
AML and terrorist financing. Internal corruption within the CID also
hampers police investigative capacity. According to GOU officials,
criminals often have access to technology that is more
sophisticated than what is available to police investigators. The
Inspectorate General of Government has the power to investigate
cases brought to it by the public, but in practice has not
investigated AML and terrorist financing cases.

Many Ugandans working abroad use an informal cash-based
remittance system to send money to their families. Annual
remittances are Uganda’s largest single source of foreign
currency and totaled $414 million in 2008/2009. Remittances are
used primarily for consumption purchases.

Counterfeit U.S. currency is a problem. In one common counterfeit
scheme, counterfeiters sell fake U.S. currency marked or
“masked” by black ink or a special stamp. The seller offers this
currency at a discount because of the markings, and claims the
bills can be exchanged or “unmasked” at a U.S. embassy or bank.
In mid-2008 in eastern Uganda, police arrested an individual in
possession of more than $1 million in counterfeit U.S. currency.
Highlighting Uganda’s unwillingness to crack down on
counterfeiters in cases involving well-connected individuals, police
subsequently released the individual from custody, and he later
disappeared.

The Government of Uganda should become a party to the UN
Convention for the Suppression of the Financing of Terrorism and
the UN Convention against Transnational Organized Crime.

____________________________________________________

US State Dept Narcotics Report 2012:

Drug production and trafficking within Uganda remain relatively
low, but Uganda’s Anti-Narcotic Unit (ANU) reports that drug
abuse and trafficking are increasing among Uganda’s youth due
to poverty, unemployment, and Uganda’s high level of population
growth. Domestic narcotic production is primarily limited to
growing cannabis for local consumption and regional export to
Rwanda, Tanzania, Kenya, Sudan, and the Democratic Republic
of the Congo (DRC). Cannabis cultivation occurs throughout the
country and increased during 2011 due to expanding regional
demand and the lack of more profitable crops. Reports of illegal
trafficking of heroin and cocaine also increased as traffickers
exploited Uganda’s porous borders, rising corruption, and
Ugandan law enforcement’s inadequate equipment and training.
There are no national studies on the prevalence and type of drug
usage in Uganda, but health care professionals, social workers,
and NGOs report that marijuana is the most widely used drug due
to its accessibility and low cost.

The absence of national crime reporting statistics and corruption
within the police and the justice system prevent an accurate
accounting of law enforcement efforts. Between January and
October 2011, the ANU seized 14 kilograms of heroin and three
kilograms of cocaine. Reported seizures of cannabis dropped to
300 kilograms in 2011 from 894 in 2010. Uganda successfully
prosecuted 4,260 people for drug-related offenses in 2011 and
uprooted 14 acres of cannabis plants. Traffickers sometimes use
Uganda and Entebbe International Airport as a transit route to
South Africa, China, the United States, and Europe. Primary
sources of drugs include India, Thailand, Pakistan, Afghanistan,
and Iran.

Uganda’s National Drug Policy and Authority Act addresses drug
possession, production, use, and trafficking, but penalties are not
severe, with maximum sentences ranging from a three-year prison
sentence to a fine of approximately $700. Comprehensive national
drug legislation was recently taken up again by the Ugandan
parliament, but no action was taken. This legislation has been
pending since 2007. If approved, this legislation would strengthen
criminal penalties for drug traffickers, increase the government’s
authority to confiscate assets, and establish a national
coordination body to oversee treatment and rehabilitation of
abusers and to manage regional international counternarcotics
cooperation efforts. Uganda is a party to the 1988 UN Drug
Convention, the 1971 UN Convention Against Psychotropic
Substances, and the 1961 UN Single Convention as amended by
its 1972 Protocol. Uganda is also a party to the UN Convention
against Transnational Organized Crime and the UN Convention
against Corruption. As a matter of government policy, the
Ugandan government does not encourage or facilitate illicit
production or distribution of narcotic or psychotropic drugs or
other controlled substances.

Resource constraints complicate Uganda’s ability to combat illicit
drugs. The ANU employs fewer than 100 officers but estimates
that it requires 500 officers to effectively combat Uganda’s illicit
drug trade. The deaths of the ANU’s two sniffer dogs further
reduced its effectiveness. Entebbe International Airport, Uganda’s
only major airport, does not have a specialized x-ray machine for
detecting ingested drugs, and the ANU has no reliable drug test
kits to determine if suspected drugs are, in fact, prohibited
substances.

The United States regularly engages with the Ugandan
government and law enforcement agencies on a variety of law
enforcement issues to improve Uganda’s capacity to enforce its
laws and investigate crime. The United States has assisted
Uganda’s counter-narcotics efforts with law enforcement training
courses and general investigative skills training, focusing on
major case management and evidence collection. The United
States also established a community policing project at the
National Police Training Academy.

Uganda does not have an organized campaign to sensitize the
public to the dangers of drug abuse, but local government
officials, religious leaders, and civil society raise awareness of the
negative consequences of drug use. Ugandan law enforcement
officials often link violent crimes to drug use, noting that many
individuals arrested for other crimes have criminal histories of
drug use or possession. The Ugandan government operates one
rehabilitation center at Butabika Referral Mental Hospital, and
NGOs provide additional treatment options.

The Uganda Police Force (UPF) is a willing partner in the fight
against narcotics trafficking. However, UPF officers, along with
border and airport enforcement officers, are in dire need of
additional training, equipment, and resources to curb the illegal
drug trade. Any improvement in Uganda’s capability to combat the
production, trafficking, and consumption of narcotics will depend
on increasing the resources and training for the ANU, reducing
corruption, and passing comprehensive national drug legislation.

____________________________________________________

US State Dept Trafficking in Persons Report 2011
(introduction):

(Tier 2)

Uganda is a source and destination country for men, women, and
children subjected to forced labor and sex trafficking. Ugandan
children are exploited in forced labor within the country in fishing,
agriculture, mining, stone quarrying, brick making, road
construction, car washing, scrap collection, bars and restaurants,
and the domestic service sector, and are exploited in prostitution.
Ugandan children are taken to other East African countries for
similar purposes, and are also forced to participate in illegal
border smuggling of various goods, including counterfeit items
and illicit drugs. Karamojong women and children are subjected to
domestic servitude and forced cattle herding in Karamoja, and are
transported to Kampala and other urban areas by traffickers who
force them to beg in the streets, or engage in prostitution or
domestic servitude. During the reporting period, Ugandan sex
trafficking victims were discovered in Denmark, Oman, and
Malaysia. Security companies and employment agencies in
Kampala continued to recruit Ugandans to work as security
guards, laborers, and drivers in the Middle East; some workers
reported conditions indicative of forced labor, including passport
withholding, nonpayment of wages and lack of food. South Asian
and Chinese migrant workers are subjected to forced labor in
Uganda in construction, transportation, trade, and service
activities, and South Asian crime networks transport South Asian
children to the country for prostitution. Children from the
Democratic Republic of the Congo (DRC), Rwanda, Burundi,
Kenya, Tanzania, and Sudan are subjected to forced agricultural
labor and prostitution in Uganda. Until August 2006, the Lord’s
Resistance Army (LRA) abducted children and adults in northern
Uganda to serve as soldiers, sex slaves, and porters. While there
have been no LRA attacks in Uganda since that time, some
Ugandan children remain captive with LRA elements currently
located in the DRC, Central African Republic, and southern Sudan.

The Government of Uganda does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. While the government began
two prosecutions of four suspected trafficking offenders, among
the first to be charged under Uganda’s 2009 anti-trafficking law,
there were no convictions during the reporting period and no
action taken in 16 trafficking investigations outstanding since
2009. While the protection and prevention provisions of the 2009
anti-trafficking act have not been fully implemented or funded, the
government referred over 150 trafficking victims to government
and NGO care centers. The government monitored the activities
of the 20 licensed external labor recruiting agencies and barred
them from sending Ugandans to work as domestic employees
abroad due to the high risk of exploitation; however the
government also reissued a license to a recruiting agency
connected to a past alleged trafficking case of domestic workers
to Iraq.

For full report click here

____________________________________________________

US State Dept Terrorism Report 2010

Overview: The Somali-based al-Shabaab posed the most
significant terrorist threat to Uganda. Al-Qa’ida (AQ)-linked
terrorists moving between the Horn of Africa, North Africa, and
Europe used Uganda as a transit point. While in transit, AQ
members were believed to have illegally procured government
documents and engaged in recruitment activities. In response to
the July 11 bombings and continued threat levels, the
Government of Uganda increased efforts to track, capture, and
hold individuals with suspected links to terrorist organizations.
Uganda's Joint Anti-Terrorism Taskforce, which is composed of
military, police, and intelligence entities, led Uganda's
counterterrorism response.

In addition to investigating and charging terrorist bombing
suspects, Uganda continued to pursue the Lord's Resistance
Army in coordination with the Democratic Republic of Congo,
Sudan, and the Central African Republic.

2010 Terrorist Incidents: On July 11, two al-Shabaab suicide
bombers attacked an Ethiopian restaurant and a Rugby Club in
Kampala where Ugandans and others gathered to watch the
World Cup finals, killing 76 people and wounding many more.
Accomplices to the suicide bombers detonated a separate
explosive device, in addition to the bomb detonated by the suicide
bomber, at the Rugby Club. A fourth bomb placed at a nightclub
failed to explode.

Legislation and Law Enforcement: Following the Kampala
bombings, U.S. law enforcement worked closely with Uganda to
gather evidence and investigate the terrorist attacks. This
collaboration improved the coordination and levels of information
sharing between Uganda's own security services and
strengthened police capacity to investigate terrorist incidents. An
archaic criminal records system that relies on fingerprint cards to
connect individuals with past crimes continued to hinder Ugandan
police. Uganda continued to need a modern criminal records
management system to conduct effective counterterrorism
cooperation.

Uganda continued to process travelers on entry and departure at
two international airports and four land borders with the Personal
Identification Secure Comparison and Evaluation System.

Countering Terrorist Finance: Uganda’s comprehensive draft anti-
money laundering legislation has long been pending before
Parliament. As a result, current efforts to combat money
laundering are piecemeal and based on older legislation. The Anti-
Terrorist Act made terrorist financing illegal, and there was no
evidence that the Ugandan government used it to prosecute
effectively financiers of terrorism. In addition, the list of terrorist
organizations covered by the bill was static, and only included
four terrorist organizations (al-Qa'ida and three domestic
organizations). There was no suspicious transaction-reporting
requirement for terrorist financing. The Inspectorate General of
Government has the power to investigate cases brought to it by
the public, but in practice has not investigated money laundering
and terrorist financing cases. The Criminal Investigations
Department (CID) of the Uganda Police Force was responsible for
investigating financial crimes. However, until Parliament approves
the anti-money laundering legislation, the understaffed and
undertrained CID maintains only limited authority to investigate
and prosecute money-laundering violations. According to
Ugandan government officials, criminals often had access to
technology that was more sophisticated than what was available
to police investigators. Internal corruption within the CID also
hampered police investigative capacity.

Regional and International Cooperation: Uganda signed the
Beijing Convention on the Suppression of Unlawful Acts Relating
to International Civil Aviation and the Protocol to the Convention
for the Suppression of Unlawful Seizure of Aircraft at the
conclusion of an International Civil Aviation Organization
diplomatic conference in September. The Ugandan government is
a strong advocate for cross-border solutions to persistent security
concerns in the Great Lakes Region and East Africa. Burundi and
Uganda were the only two troop contributing nations participating
in AU Mission in Somalia.

Countering Radicalization and Violent Extremism: Because
regions lacking rule of law are often incubators of extremism,
Ugandan law enforcement is working with the United States to
improve levels of collaboration and trust between the police force
and the public in northern Uganda.

____________________________________________________

Links:

Worldwide AML Legislation (International Bar Association)
Tables & Rankings
Are there Sanctions in force against it? (UN/EU/US)
N
?
Is it on FATF list of non-cooperative countries?
N
?
Is it on OECD list of uncooperative Tax Havens?
N
?
OECD - Implementation status of Tax Standard
 
?
Is it on EU 'white' list of equivalent jurisdictions?
N
?
Offshore Finance Center (Original IMF List)?
N
?
Is it on the US Secretary of Treasury list of jurisdictions of
Primary Money Laundering concern?
N
?
Is it on the US Secretary of State list of jurisdictions
identified to be supporters of International Terrorism?
N
?
Is it on US Department of State International Narcotics
Control Majors List?
N
?
US Dept of State Money Laundering assessment (INCSR)
M
?
Government Actions (For further info see INCRS below):
 
?
-  Criminalized Drug Money Laundering?
N
 
-  Criminalized Beyond Drugs?
N
 
-  Record Large Transactions?
Y
 
-  Maintain Records Over Time?
Y
 
-  Report Suspicious Transactions?(NMP)?
Y
 
-  Egmont Financial Intelligence Units?
N
 
-  System for Identifying/Forfeiting Assets?
N
 
-  Arrangements for Asset Sharing?
N
 
-  Cooperates with International Law Enforcement?
Y
 
-  International Transportation of Currency?
N
 
-  Ability to Freeze Terrorist Assets w/o Delay?
Y
 
-  Disclosure Protection "Safe Harbor"?
N
 
-  Criminalized Financing of Terrorism?
Y
 
-  States Party to 1988 UN Convention?
Y
 
-  International Terrorism Financing Convention?
Y
 
 
Ranking
2011
Ranking
2010
 
Corruption (Transparency International)
143 (out of
183)
127 (out of
178)
?
Ease of doing business (World Bank)
123 (out of
183)
122 (out of
183)
?
FATF 40 + 9 recommendations
Mutual Evaluation Report: 2009
Further Tables
C
L
P
N
N/A
    C  -  Fully Compliant ,   
    L  -  Largely Compliant,    
    P  -  Partially Compliant    
    N  -  Non-Compliant
1
0
13
34
1
Legal Systems
 
1. Money Laundering Offence
N
 
14. Protection & no tipping-off
N
2. ML offence – mental element and
corporate liability
N
 
15. Internal controls,
compliance & audit
P
3. Confiscation and provisional
measures
N
 
16. DNFBP – R.13-15 & 21
N
4. Secrecy laws consistent with the
Recommendations
C
 
17. Sanctions
N
5. Customer due diligence
P
 
18. Shell banks
N
6. Politically exposed persons
N
 
19. Other forms of reporting
N
7. Correspondent banking
N
 
20. Other NFBP & secure
transaction techniques
N
8. New technologies & non
face-to-face business
N
 
21. Special attention for
higher risk countries
N
9. Third parties and introducers
N
 
22. Foreign branches &
subsidiaries
N/A
10. Record keeping
P
 
23. Regulation, supervision
and monitoring
P
11. Unusual transactions
N
 
24. DNFBP - regulation,
supervision and monitoring
N
12. Designated Non-Financial
Businesses and Professions – R.5,
6, 8-11
N
 
25. Guidelines & Feedback
N
13. Suspicious transaction reporting
N
     
Institutional and other
measures
 
26. The FIU
N
 
31. National co-operation
N
27. Law enforcement authorities
N
 
32. Statistics
N
28. Powers of competent authorities
P
 
33. Legal persons –
beneficial owners
N
29. Supervisors
P
 
34. Legal arrangements –
beneficial owners
N
30. Resources, integrity and training
N
 
 
 
International Co-operation
 
35. Conventions
P
 
38. MLA on confiscation and
freezing
N
36. Mutual legal assistance (MLA)
N
 
39. Extradition
N
37. Dual criminality
P
 
40. Other forms of
co-operation
P
Nine Special
Recommendations
 
SR.I Implement UN instruments
P
 
SR VI AML requirements for
money/value transfer services
P
SR.II Criminalise terrorist financing
P
 
SR VII Wire transfer rules
N
SR.III Freeze and confiscate
terrorist assets
N
 
SR.VIII Non profit
organisations
P
SR.IV Suspicious transaction
reporting
N
 
SR.IX Cross Border
Declaration & Disclosure
N
SR.V International co-operation
N
 
 
 
*Please note that FATF deems that a country has significant aml deficiencies if
any of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated
either Partially of Non-Compliant. These are marked in red.

For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -        

R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV

Please also note that any risk assessment should take into consideration all
follow-up reports.
UGANDA
KnowYourCountry
-  Know Your Customer Provisions
Y
 
-  Criminalized Tipping Off?
N
 
-  Report Suspected Terrorist Financing?
Y
 
-  State Party to United Nations TOC?
Y
 
-  State Party to United Nations CAC?
Y
 
Local AML News / Sanctions
Tax Information
Business Information
Last Updated:   16 April 2012