Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Uganda UG

Domains covered

8 of 8

Sources

157

Role actions

Horizon <90d

Jurisdiction profile

FATF status: Compliant Tier: B Risk direction: Stable Enablement vs enforcement: Mixed

Uganda's AML/CFT/CPF regime rests on the Anti-Money Laundering Act 2013 (amended 2017) and AML Regulations 2015, supervised by the Financial Intelligence Authority (FIA) and Bank of Uganda.

Uganda exited FATF increased monitoring in February 2024 and the EU high-risk third-country list in June 2025 after ESAAMLG-verified technical-compliance improvements, but structural exposure persists via gold/mineral transit, EACOP oil finance, and PEP corruption networks.

Key deficiencies

Customs and due-diligence gaps enabling DRC conflict-gold consolidation and re-export via Ugandan traders and refineries
Risk-based (rather than blanket) supervision of the NPO sector remains incomplete, per FATF's continuing ESAAMLG follow-up concern
Limited public transparency on ML investigation/prosecution and asset-recovery statistics, constraining independent verification of stated enforcement gains
Political contestation of anti-corruption enforcement narratives undermines credibility of PEP accountability measures

Recent developments (18m)

UN 1267 ISIL/Al-Qaida Sanctions Committee listed Ugandan national Abubakar Swalleh as an ISIL financial facilitator (16 June 2025)
European Commission delisted Uganda from the EU AML high-risk third-country list via Delegated Regulation (EU) 2025/1184 (10 June 2025)
ESAAMLG/FATF issued a further follow-up report analysing Uganda's progress against 2016 MER technical-compliance deficiencies (circa late 2025)
Continued political pressure for expanded US sanctions on President Museveni following his seventh-term inauguration (reported May 2026)
FATF's July 2025 Comprehensive Update on Terrorist Financing Risks lists Uganda among contributing jurisdictions amid regional ADF/ISIL financing concerns

Brief

Lead signal

Lead Signal

Uganda's AML/CTF architecture continued a pattern of incremental consolidation this cycle rather than structural disruption. The Financial Intelligence Authority issued Circular No. 13 on 14 February 2026, directing reporting entities to apply FATF Recommendation 19 measures for higher-risk countries, and a statutory instrument amending AML Schedule 2 was gazetted on 10 March 2026. Both developments are named and dated on FIA's own published feed, though the full instrument text for each was not independently retrieved this cycle, capping provision-level confidence at the probable tier rather than confirmed. Uganda remains off the FATF grey list, having exited at the February 2024 Paris plenary, and does not appear on FATF's June 2026 list of 22 jurisdictions under increased monitoring; the next mutual evaluation is scheduled for 2028.

Read full brief

Lead Signal

A separate judicial development bears on the Authority's operational powers. Reporting on a ruling in Silver Kayondo v Bank of Uganda clarifies that FIA account-freeze directives require prompt post-freeze judicial sanction, though no prior notice to the account holder is required before the freeze itself. This due-process boundary was reported in trade press on 13 April 2026, relying on a single secondary summary of the judgment rather than the primary court text, which has not been independently retrieved.

Other Developments

Virtual-asset framework remains at the announcement stage. Bank of Uganda, together with the Financial Intelligence Authority and the Capital Markets Authority, has signalled a forthcoming six-pillar virtual-asset framework covering licensing, AML/CFT, custody, and cybersecurity, first announced in a Bank of Uganda Governor keynote on 25 November 2025. No draft legislation implementing this framework has been published as of this cycle, leaving Uganda's digital-asset sector without a dedicated supervisory regime despite the stated regulatory intent.

Regional crypto-laundering nexus flagged. A joint Cambodia-United States operation seized approximately seven million US dollars in cryptocurrency linked to Sinaloa-cartel laundering activity routed through Cambodian networks, reported in August 2026. This is a Tier-D watch-jurisdiction finding rather than a Uganda-specific development, but it illustrates the kind of cross-border typology that regional virtual-asset supervisory gaps can enable.

Cross-Monitor Connections

The absence of a finalised Ugandan virtual-asset licensing regime is a structural gap relevant to the world-payments monitor's tracking of Uganda's fintech and digital-money landscape; any future product launch in the virtual-asset space would need to navigate a six-pillar framework that currently exists only as an announced intention. The Silver Kayondo ruling on account-freeze due process is relevant to institutions' governance and legal functions handling FIA directives, and connects to broader questions of how enabler-jurisdiction account-freeze powers are judicially constrained across the region.

Outlook

The near-term question for Uganda's AML/CTF regime is whether the February and March 2026 instruments (Circular No. 13 and the AML Schedule 2 amendment) will be followed by primary-text publication that would allow confidence in their provisions to move from probable to confirmed. On the virtual-asset side, the test is whether the six-pillar framework announced in November 2025 progresses to draft legislation; until it does, Uganda's digital-asset sector remains in a supervisory gap relative to regional peers such as Kenya. Uganda's standing outside FATF's grey list and increased-monitoring list continues to hold ahead of the 2028 mutual evaluation, with no indication this cycle of a change to that status.

Earlier periodic briefs (3)

25 Oct 2026 · fim-2026-10-25

Lead Signal

Uganda's AML/CTF architecture continued a pattern of incremental consolidation rather than structural disruption. The Financial Intelligence Authority issued Circular No. 13 on 14 February 2026, directing reporting entities to apply FATF Recommendation 19 measures for higher-risk countries, and a statutory instrument amending AML Schedule 2 was gazetted on 10 March 2026. Both developments are named and dated on FIA's own published feed, though the full instrument text for each was not independently retrieved, capping provision-level confidence at the probable tier rather than confirmed. Uganda remains off the FATF grey list, having exited at the February 2024 Paris plenary, and does not appear on FATF's June 2026 list of 22 jurisdictions under increased monitoring; the next mutual evaluation is scheduled for 2028.

Other Developments

Virtual-asset framework remains at the announcement stage. Bank of Uganda, together with the Financial Intelligence Authority and the Capital Markets Authority, has signalled a forthcoming six-pillar virtual-asset framework covering licensing, AML/CFT, custody, and cybersecurity, first announced in a Bank of Uganda Governor keynote on 25 November 2025. No draft legislation implementing this framework has been published, leaving Uganda's digital-asset sector without a dedicated supervisory regime despite the stated regulatory intent.

Cross-Monitor Connections

Outlook

4 Oct 2026 · fim-2026-10-04

Lead Signal

Uganda's virtual-asset ecosystem has produced its clearest quantification yet of an oversight gap that has existed largely in the abstract. The Financial Intelligence Authority's first national money-laundering and terrorist-financing risk assessment on virtual assets, completed in September 2025, found roughly $564 million in virtual-asset inflows and roughly $546 million in outflows between July 2020 and June 2024, with stablecoins the largest component and the great majority of this activity sitting outside regulatory oversight. This is not a new phenomenon; it is the first time it has been measured and named as a national risk by the country's own financial-intelligence body. That combination of scale and structural gap is the lead signal this cycle.

The assessment lands alongside two other developments that, together, describe a jurisdiction in transition rather than one standing still. The Bank of Uganda has announced a six-pillar virtual-asset regulatory framework, covering licensing and fit-and-proper standards, client-asset protection, AML/CFT controls including the Travel Rule, cybersecurity, market integrity and transparency, but this framework remains at the announced-pillars stage with no published draft bill. And Uganda's High Court has upheld a central-bank circular barring payment-system-licensed entities from converting cryptocurrency into official currency or mobile money, confirming a restriction that has been operative since April 2022 but had not previously been tested judicially.

Other Developments

FATF standing confirmed. Uganda remains off the Financial Action Task Force's increased-monitoring list, having been removed in February 2024, with the June 2026 plenary listing continuing to exclude the country from that list. ESAAMLG follow-up rates Uganda Compliant or Largely Compliant on 25 of the FATF's 40 Recommendations, a stable baseline position rather than a change this cycle, though it is worth restating because it frames the jurisdiction's overall AML architecture as functioning credibly at the level the mutual-evaluation process measures.

Gambling-sector AML perimeter widened. The National Lotteries and Gaming Regulatory Board has tied casino licence renewal in the 2026 cycle to registration with the Financial Intelligence Authority as accountable persons, with an accompanying requirement to file annual AML/CFT compliance reports. This is a sector-specific tightening that extends the accountable-person perimeter into gambling, a sector that in many enabler-adjacent jurisdictions has historically sat outside effective AML supervision even where formally covered.

Judicial confirmation of the conversion prohibition. The High Court ruling in Silver Kayondo v Bank of Uganda confirms that BOU Circular NPSD 306, issued 29 April 2022, validly bars National Payment Systems-licensed entities from converting virtual assets into official currency or mobile money. The practical effect is that licensed payment rails in Uganda remain closed to direct crypto-to-fiat conversion, pushing volume toward channels the FIA's own risk assessment describes as largely unsupervised.

Cross-Monitor Connections

The scale of unsupervised virtual-asset flow quantified by the FIA assessment is directly relevant to payments-monitor analysis of Uganda's mobile-money and account-to-account rails, since the same underlying consumer base and cash-out points are implicated whether the transaction is framed as a payments-compliance matter or an AML-typology matter. The judicially confirmed conversion prohibition on payment-system-licensed entities is itself a payments-architecture fact with a financial-integrity reading: it closes one enforcement-adjacent channel while leaving the FIA-quantified unsupervised volume to move through channels the assessment did not fully characterise. The gambling-sector AML tightening likewise intersects with gambling-monitor coverage of the same 2026 licence-renewal cycle, where the accountable-person registration condition is a licensing fact as much as an AML fact.

Outlook

The near-term marker to watch is whether Bank of Uganda's six-pillar framework progresses from announced pillars to a published draft bill; the framework's own timeline points toward 2027, and the gap between neighbouring East African jurisdictions that have already enacted dedicated VASP statutes and Uganda's earlier-stage design process is a a structural feature the interpreter's gap assessment flags explicitly. Whether the FIA's full national risk-assessment document is published in a form that allows independent verification of the $564 million/$546 million flow estimates, currently known only through secondary press reporting, would materially strengthen or qualify the picture this cycle's lead signal presents. Absent enactment of the six-pillar framework, the structural gap the FIA has now quantified is likely to persist as a standing feature of Uganda's financial-integrity exposure rather than resolve on its own.

14 Sep 2026 · fim-2026-09-14

Lead Signal

Uganda's financial-integrity profile this cycle is defined by a widening divergence between a stable, FATF-validated traditional AML/CTF regime and a materially under-governed crypto sector where informal flows substantially outpace the licensing perimeter. Uganda was removed from the FATF grey list in February 2024 after completing its action plan, and remains absent from the 2026 list of jurisdictions under increased monitoring, a status confirmed directly by Uganda's Ministry of Finance, Planning and Economic Development and corroborated by press reporting of the FATF plenary statement. This stability in the traditional regime sits in sharp contrast to the virtual-asset space, where a Financial Intelligence Authority risk assessment reportedly found $564m in virtual-asset inflows and $546m in outflows between July 2020 and June 2024, even as Bank of Uganda bars licensed payment entities from converting cryptocurrency into official currency.

This bifurcation is the single most important structural fact for this cycle: Uganda has successfully built and maintained conventional AML/CTF architecture sufficient to satisfy FATF, while a parallel informal virtual-asset economy of material scale operates almost entirely outside any licensing perimeter, constrained only by a conversion ban that appears not to have suppressed underlying demand.

Other Developments

MER follow-up compliance picture. A 2024 mutual evaluation follow-up assessment reportedly found Uganda rated Compliant or Largely Compliant on 25 of the FATF's 40 Recommendations. This finding is sourced from a commercial compliance database at a lower evidentiary tier this cycle and has not been independently corroborated against a primary FATF or national publication, so it should be read as an indicative rather than fully confirmed compliance picture.

Sanctions list administration without autonomous listing. Uganda's Financial Intelligence Authority applies the OFAC-SDN List, UN Security Council Resolution 1267, and UN Security Council Resolution 1373 lists administratively, but maintains no autonomous sanctions list of its own. This reflects a common architecture among jurisdictions that rely on incorporation of externally maintained lists rather than independent designation authority.

Six-pillar VASP framework announced, not drafted. Bank of Uganda's Governor announced, in a BIS-hosted keynote delivered in November 2025 and published in February 2026, a forthcoming six-pillar VASP regulatory framework spanning licensing, client-asset protection, AML/CFT including the FATF Travel Rule, cybersecurity, market integrity, and transparency and data reporting. This remains at announcement stage only, with no draft legislation published as of this cycle.

Cross-Monitor Connections

The crypto monitor's own coverage of Uganda's conversion ban and VASP registration-only perimeter draws on largely the same underlying facts documented here; readers seeking the crypto-licensing-specific framing of the conversion ban and the announced six-pillar framework should consult that brief directly. The world-payments monitor's coverage of Bank of Uganda's parallel CBDC pilot development is a related but analytically distinct thread: the CBDC pilot is a sovereign payments-infrastructure initiative, whereas the informal virtual-asset flow finding documented here concerns private, unlicensed virtual-asset activity occurring despite the conversion ban.

Outlook

The central open question for coming cycles is whether the announced six-pillar VASP framework progresses to draft legislation, and if so, whether it closes the gap between the current AML-registration-only perimeter and a genuine licensing regime capable of bringing the substantial informal virtual-asset flows documented by FIA's risk assessment within regulatory visibility. Independent retrieval of that underlying FIA National ML/TF Risk Assessment on Virtual Assets, referenced only via secondary press coverage this cycle, would materially strengthen confidence in the scale finding and should be prioritised in subsequent research.

Domain intelligence (D1–D8)

D1 Sanctions

no_changeno_changestanding position

Sanctions Architecture and Evasion

Uganda D1 file this cycle is defined by the completion of a list-status normalisation across three separate regimes, layered against two developments that reintroduce sanctions-architecture risk into a jurisdiction that had appeared to be exiting the high-risk bracket entirely. The Financial Action Task Force removed Uganda from increased monitoring on 23 February 2024, crediting completion of the 2020 action plan, and the United Kingdom removed Uganda from the Money Laundering Regulations Schedule 3ZA high-risk third country list in step with that decision, a near-automatic mirroring pattern consistent with the UK general approach to FATF grey-list movements. The EU parallel process under Article 9 of the fourth Anti-Money Laundering Directive moved on an entirely separate timeline: Uganda was not delisted from the EU high-risk third-country list until Delegated Regulation (EU) 2025/1184 took effect on 10 June 2025, roughly sixteen months after the FATF and UK removals. This gap is not evidence of a substantive risk disagreement between regimes; it reflects the EU delegated-act procedural cycle running independently of the FATF plenary calendar, a pacing divergence that should be expected to recur on any future re-listing.

Two developments this cycle complicate a reading of Uganda sanctions file as resolved. First, the UN Security Council 1267 ISIL/Al-Qaida Sanctions Committee listed Ugandan national Abubakar Swalleh, also known as Tom Kiyurige, on 16 June 2025, for acting since 2018 as a financial and logistical facilitator supporting ISIL recruitment across East and Southern Africa, a designation that subjects him to an asset freeze, travel ban and arms embargo, and that stands as an active terrorism-financing node distinct from, and additional to, Uganda now-normalised country-level list status. Second, the OFAC designation of the African Gold Refinery in Entebbe and its owner Alain Goetz, imposed 17 March 2022 under the DRC-related sanctions program, remains the primary enforcement anchor for the conflict-gold transit architecture running through Uganda; the refinery has since ceased operating under that designation, but the underlying consolidation-and-re-export channel it served has not been demonstrated to have closed.

A further, still-uncorroborated signal concerns the presidency itself. Reporting from 14 May 2026 describes Ugandan opposition figures, led by Robert Kyagulanyi, lobbying the US Congress and Senate for Magnitsky-style sanctions against President Museveni following his seventh-term inauguration. This is a single, early-stage political signal with no corroborating US Treasury or State Department action, but it is pattern-consistent with a broader sanctions-regime divergence: the UK April 2024 Global Anti-Corruption Sanctions on three Ugandan officials targeted individual politically-exposed persons rather than the presidency, and neither the UK nor the EU has signalled any intention to extend action to Museveni himself. Should the US lobbying translate into an actual designation, Uganda would present a case of individual-PEP and country-risk tracks moving independently across three separate sanctions regimes simultaneously.

Also within this cycle D1 signal, the United Kingdom own high-risk-country architecture has shifted structurally rather than in response to Uganda specifically: the Money Laundering and Terrorist Financing (Amendment) Regulations 2026 narrow the MLR Regulation 33 high-risk third-country definition to FATF call for action jurisdictions only, effective 30 June 2026, moving away from the broader increased monitoring trigger that previously applied. Uganda sits on neither list currently, so this change carries no immediate consequence for Ugandan counterparties, but it widens the structural gap between the UK narrower enhanced-due-diligence trigger and the EU broader Article 9 approach, a divergence with latent relevance should Uganda ever be re-flagged by FATF. The Allied Democratic Forces cross-border financing footprint, sustained despite joint Uganda-DRC military operations, sits alongside the Swalleh designation as a second active D1 signal that country-level delisting does not by itself extinguish the terrorism-financing exposure that runs through Uganda porous eastern border.

Outlook

The near-term D1 trajectory for Uganda is governed less by fresh instrument-level change than by whether the two live threads identified this cycle mature into concrete action. The UN 1267 listing of Abubakar Swalleh establishes an active facilitation node that regulated entities screening East African counterparties should treat as a standing reference point independent of Uganda's own list status. The US opposition lobbying push, if it develops into an actual Treasury or State designation against President Museveni, would create the clearest instance yet of the individual-sanctions and country-risk-list tracks moving on entirely separate calendars across the US, UK and EU regimes, a structural pattern this file has already demonstrated once via the EU sixteen-month delisting lag. Absent a genuinely new designation, the most likely near-term development remains procedural: continued EU list churn that does not re-add Uganda, and a UK regime increasingly narrowed to FATF call-for-action jurisdictions that leaves Uganda outside its scope for the foreseeable future.

Judgment: No Uganda-specific sanctions-architecture development this cycle. Uncertain

D2 Beneficial Ownership

no_changeno_change

Beneficial Ownership

Uganda carried no distinct beneficial-ownership development this cycle; the applicable signal for D2 this period is structural and global rather than jurisdiction-specific. The EU AML Package continues to take shape as the structural backdrop against which beneficial-ownership and corporate-transparency developments worldwide are now read. The package comprises three distinct instruments: the AML Regulation (AMLR, Regulation (EU) 2024/1624), which applies directly across Member States; the sixth AML Directive (6AMLD), transposed individually by each Member State; and the AMLA Regulation (Regulation (EU) 2024/1620), establishing the Anti-Money Laundering Authority. Within this architecture, the Anti-Money Laundering Authority published its first three final draft Regulatory Technical Standards on 1 October 2026, including customer due diligence standards under AMLR Article 28(1). This is a probable-confidence finding resting on secondary reporting rather than AMLA's own primary publication, which was not independently retrieved this cycle.

The AMLA direct and indirect supervision perimeter is shifting beneficial-ownership and corporate-transparency supervision from a purely national model toward a hybrid EU-level regime, with cross-border obliged entities increasingly falling under AMLA's own supervisory reach rather than that of national authorities alone. This is a durable structural fact rather than a single-cycle development, and it forms the backdrop against which any future Uganda-specific beneficial-ownership finding would need to be read, given Uganda's position outside the EU AML Package's direct perimeter. No Uganda-specific corporate-transparency or beneficial-ownership-register development was identified in the available evidence this cycle.

Outlook

The near-term development to watch is whether AMLA's newly published draft RTS move from draft to adopted status, and whether further drafts addressing beneficial-ownership register interoperability follow. For Uganda specifically, no beneficial-ownership-register development is in train based on the evidence available this cycle; any future finding would need to be assessed against Uganda's standing Anti-Money Laundering Act framework rather than against the EU architecture, which remains contextual background rather than directly applicable.

Judgment: No new Uganda BO-registry development located this cycle. Uncertain

D3 Enabler Jurisdictions

no_changeno_changestanding position

Enabler Jurisdictions and Professional Facilitators

Judgment: No Uganda enabler-jurisdiction development this cycle. Uncertain

D4 Conflict Finance

no_changeno_change

Uganda continues to function as a reported downstream gold-export conduit amid OFAC's June 2026 sanctions on the Rwanda-linked M23 conflict-mineral network; no Ugandan entity designated this cycle.

Judgment: No Uganda conflict-finance development this cycle. Uncertain

D5 Crypto / Digital Assets / Financial Innovation

no_changewatch

Crypto / Digital Assets / Financial Innovation

Uganda's virtual-asset regulatory posture remains at the announcement stage. Bank of Uganda, jointly with the Financial Intelligence Authority and the Capital Markets Authority, signalled a forthcoming six-pillar framework covering virtual-asset licensing, AML/CFT, custody, and cybersecurity in a Bank of Uganda Governor keynote delivered 25 November 2025. As of this cycle, no draft legislation implementing that framework has been published, leaving Uganda's digital-asset sector without a dedicated supervisory regime notwithstanding the stated regulatory intent. This is a probable-confidence finding sourced to Bank of Uganda's own published material, though the forward-looking nature of the announcement means no legislative text yet exists to assess against.

This gap is read against a regional backdrop in which virtual-asset channels are demonstrably exploitable for large-scale illicit finance: a joint Cambodia-United States operation reported in August 2026 seized approximately seven million US dollars in cryptocurrency linked to Sinaloa-cartel laundering activity routed through Cambodian networks. While this is a Cambodia-specific finding and not a Uganda event, it is the kind of typology that a persistent supervisory gap for virtual-asset activity can leave unaddressed, and it sharpens the significance of Uganda's own framework remaining at the pre-legislative stage. Uganda's crypto-asset regulatory posture, assessed against regional peers such as Kenya which have moved further on virtual-asset supervision, leaves a comparative AML/CTF gap for virtual-asset activity specifically.

Outlook

The key development to watch is whether Uganda's six-pillar virtual-asset framework progresses from announcement to draft legislation. Until a legislative text is published, Uganda's digital-asset sector sits outside any dedicated AML/CFT, custody, or cybersecurity supervisory architecture, a gap that the Cambodia nexus finding illustrates is not merely theoretical for the region. No timeline for draft legislation has been identified in the evidence available this cycle.

Judgment: Six-pillar virtual-asset framework remains announced but undrafted; VASPs remain AML-accountable persons under the 2020 amendment. Probable

D6 Compliance Technology & Active Defence

no_changeno_change

Judgment: No Uganda-specific RegTech/compliance-technology development this cycle. Uncertain

D7 AML/CTF Regime

no_changeactive

AML/CTF Regime

Uganda's AML/CTF architecture moved incrementally this cycle through targeted circular issuance and schedule amendment rather than through wholesale reform, consistent with a post-grey-list-exit consolidation phase. The Financial Intelligence Authority issued Circular No. 13 on 14 February 2026, directing reporting entities to apply FATF Recommendation 19 measures concerning higher-risk countries. A statutory instrument amending AML Schedule 2 followed, gazetted 10 March 2026. Both instruments are named and dated on FIA's own published feed; the full instrument text for each was not independently retrieved this cycle, which caps provision-level confidence at the probable tier rather than confirmed for both developments.

A judicial development this cycle bears directly on the Authority's operational powers. Reporting on a ruling in Silver Kayondo v Bank of Uganda indicates that FIA account-freeze directives require prompt post-freeze judicial sanction, though no prior notice to the account holder is required before the freeze itself takes effect. This finding relies on a single secondary law-firm summary of the judgment; the primary court text was not independently retrieved this cycle, and confidence is accordingly probable rather than confirmed.

Uganda's standing FATF status is unchanged and confirmed: the jurisdiction remains off the FATF grey list, having exited at the February 2024 Paris plenary, and does not appear on FATF's June 2026 list of 22 jurisdictions subject to increased monitoring. The next mutual evaluation is scheduled for 2028. This combination of incremental instrument issuance, a clarified judicial due-process boundary on account freezes, and a stable grey-list-exit position characterises Uganda's AML/CTF regime this cycle as one of consolidation rather than disruption.

Outlook

The principal matter to watch is whether primary-text publication of Circular No. 13 and the AML Schedule 2 amendment becomes available, which would allow confidence in both instruments' specific provisions to move from probable to confirmed. On the judicial side, whether further case law tests or extends the account-freeze due-process boundary established in Silver Kayondo v Bank of Uganda is a live question for the Authority's operational powers. Ahead of the 2028 mutual evaluation, no indication has surfaced this cycle of any change to Uganda's stable position outside both the FATF grey list and the increased-monitoring list.

Judgment: Standing AML/CTF regime (AML Act 2013 as amended, FIA supervision) unchanged; FIA pursues funding ahead of 2028 mutual evaluation. Probable

D8 Commercial Activity

no_changeno_change

Judgment: No commercial transactions in the financial-integrity vendor/services space touching Uganda this cycle. Uncertain

Regulatory horizon

Proposed2027 · ±multi_year

Bank of Uganda six-pillar VASP regulatory framework

A licensing/fit-and-proper regime, client-asset protection rules, AML/CFT compliance including FATF Travel Rule, cybersecurity, market-integrity and transparency/data-reporting pillars are proposed but not yet drafted into legislation.

Bank of Uganda Source

Proposed2027 · ±year

Bank of Uganda six-pillar virtual-asset regulatory framework

A licensing/fit-and-proper, AML/CFT, cybersecurity, market-integrity and transparency framework for virtual assets was announced; no draft bill text located.

Bank of Uganda Source

Proposed2027 · ±multi_year

Uganda six-pillar virtual-asset regulatory framework

Bank of Uganda Source

Proposed2028 · ±multi_year

ESAAMLG follow-up technical review of Uganda's AML/CFT compliance

A scheduled 2028 technical review will reassess remediation of 11 identified reporting-area weaknesses.

Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) Source

In Force Pending2028 · ±multi_year

Uganda's next FATF Mutual Evaluation (following 2024 grey-list exit)

A re-assessment of Uganda's AML/CFT/CPF framework against FATF's 40 Recommendations under an effectiveness-weighted methodology.

FATF / ESAAMLG Source

5 dated · 2 pending date · baseline financial-integrity-2026-07-05

Role action cards

MLRO

FIA issued Circular No. 13 on FATF Recommendation 19 and amended AML Schedule 2 this period.

Reporting entities subject to Ugandan AML obligations should be aware that FIA has formally circularised enhanced due diligence expectations for higher-risk countries and amended the AML Schedule 2 list; the underlying instrument text has not been independently confirmed, so provision-level detail remains probable rather than confirmed.

2 evidence refs

Compliance

FIA issued Circular No. 13 and an AML Schedule 2 amendment; Uganda's FATF-clean status continues unchanged.

Compliance functions overseeing Ugandan obligations should track these two instruments for eventual primary-text confirmation, and can continue to rely on Uganda's confirmed status outside both the FATF grey list and the June 2026 increased-monitoring list ahead of the 2028 mutual evaluation.

3 evidence refs

Legal

A Ugandan High Court ruling clarified judicial-sanction requirements for FIA account-freeze directives.

Reporting on Silver Kayondo v Bank of Uganda indicates FIA account freezes require prompt post-freeze judicial sanction without a prior-notice requirement; legal counsel advising on FIA directive challenges should note this due-process boundary, though it rests on a single secondary summary rather than the primary judgment text.

1 evidence refs

Board

Uganda's AML/CTF regime is consolidating incrementally, with a persistent virtual-asset supervisory gap.

The Board should note that Uganda's AML/CTF framework is maturing in a stable, post-grey-list-exit manner rather than undergoing disruptive reform, while its virtual-asset sector remains at the pre-legislative announcement stage, a gap relevant to any institution with Uganda-linked digital-asset exposure.

4 evidence refs

CTO

Uganda's six-pillar virtual-asset framework remains announced but not drafted; a regional crypto-cartel laundering nexus was reported.

Technology leadership supporting virtual-asset products with Uganda exposure should note that no licensing, custody, or cybersecurity regime yet exists in draft legislative form, and that a Cambodia-US operation seized cryptocurrency linked to cartel laundering via Cambodian networks, illustrating a regional typology relevant to digital-asset infrastructure risk assessment.

2 evidence refs

Risk

Uganda's virtual-asset supervisory gap persists alongside a regional crypto-laundering nexus finding.

Risk functions should weight Uganda-linked virtual-asset exposure against the continued absence of a dedicated licensing/AML-CFT/custody/cybersecurity regime, informed by the Cambodia cartel-laundering nexus as an illustration of what unaddressed virtual-asset supervisory gaps can enable regionally.

2 evidence refs

Operations

No material change for this persona this cycle.

No material change for this persona this cycle

Audit

FIA's Circular No. 13 and AML Schedule 2 amendment lack independently retrieved primary text this period.

Audit functions should note that both newly issued instruments rest on FIA's own feed description rather than independently verified primary-source text, which caps the confidence basis for any control-testing scope built against their specific provisions at the probable tier.

2 evidence refs

Scenario sketches

AMLA direct-supervision transition and cross-border obliged entities

Illustrative scenario: as the Anti-Money Laundering Authority moves from standing-up its Regulatory Technical Standards toward exercising direct and indirect supervision of cross-border obliged entities under the AMLA Regulation, alongside the directly-applicable AML Regulation and per-state sixth AML Directive transposition, the supervisory landscape for pan-European financial groups could shift materially from a purely national model toward a hybrid EU-level one. This could, illustratively, alter where evasion typologies cluster, as entities historically supervised at purely national level adjust to a layered EU/national supervisory structure. This is illustrative orientation only, not an observed development or a prediction of how AMLA's supervisory perimeter will in fact be exercised.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	no_change
T2 · EU AML Package / AMLA	no_change
T3 · FATF Grey List	no_change
T4 · Beneficial-Ownership Register Status	no_change
T5 · Crypto & Digital-Asset Integrity	watch
T6 · Sanctions Regime Divergence	no_change

Registers

Enforcement actions

16 Jun 2025
30 Apr 2024
1 Dec 2025
13 Apr 2026
The Committee added Ugandan national Abubakar Swalleh to the ISIL/Al-Qaida Sanctions List, subjecting him to asset freeze, travel ban and arms embargo for acting since 2018 as an ISIL financial and logistical facilitator supporting recruitment in East and Southern Africa. 16 Jun 2025
The UK imposed its first Global Anti-Corruption Sanctions on Uganda-linked individuals, designating the Speaker of Parliament and two former Karamoja-affairs ministers charged with corruption at Uganda's Anti-Corruption Court over diversion of iron-sheet aid intended for Uganda's poorest region. 30 Apr 2024
ESAAMLG issued a further follow-up report analysing Uganda's continued progress addressing technical-compliance deficiencies identified in its 2016 mutual evaluation, maintaining Uganda in enhanced follow-up while it embeds beneficial-ownership access and risk-based DNFBP supervision reforms. 1 Dec 2025

Sanctions changes

10 Jun 2025
30 Apr 2024
25 Jun 2026
The European Commission adopted Delegated Regulation (EU) 2025/1184, removing Uganda (alongside Barbados, Gibraltar, Jamaica, Panama, Philippines, Senegal and UAE) from the EU's Article 9 AMLD4 list of high-risk third countries with AML/CFT strategic deficiencies, aligning the EU list with Uganda's February 2024 FATF delisting. 10 Jun 2025
HM Treasury laid the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, narrowing the UK MLR Regulation 33 definition of 'high-risk third country' to jurisdictions on the FATF 'call for action' list only, rather than also automatically including the broader 'increased monitoring' list — a materially narrower EDD trigger than the EU's Article 9 approach. 30 Jun 2026

Regulatory horizon (register)

UK Economic Crime and Corporate Transparency Act 2023 — failure-to-prevent-fraud offence
Bank of Uganda six-pillar VASP regulatory framework
Uganda's next FATF Mutual Evaluation (following 2024 grey-list exit)
ESAAMLG follow-up technical review of Uganda's AML/CFT compliance
Bank of Uganda six-pillar virtual-asset regulatory framework
Uganda six-pillar virtual-asset regulatory framework
UK MLR amendment narrows high-risk third country EDD trigger
UK Anti-Money Laundering and Asset Recovery Strategy publication
Uganda's next ESAAMLG follow-up on NPO supervision and BO access

Active schemes

[HIGH] DRC conflict-gold consolidation and re-export via Uganda
EACOP oil-pipeline financing amid civic-space suppression
[HIGH] ISIL/ADF East African financial-facilitation network

Sources

Coverage gaps

fim-int-2026-07-07-G001: Ugandan customs authorities' gold i…

fim-int-2026-07-07-G001: Ugandan customs authorities' gold import/export due-diligence records are not independently accessible, preventing verification of the scale of conflict-gold consolidation beyond aggregate export-value statistics. [resolved]

fim-int-2026-07-07-G002: Uganda's NPO-sector risk assessment…

fim-int-2026-07-07-G002: Uganda's NPO-sector risk assessment methodology has not been independently published, limiting verification of progress toward FATF's risk-based supervision condition. [resolved]

fim-int-2026-07-07-G003: No independent, non-governmental so…

fim-int-2026-07-07-G003: No independent, non-governmental source corroborates or disputes the Ugandan Parliament's characterisation of UK sanctions on the Speaker as politically motivated, leaving the credibility question unresolved. [resolved]

fim-int-2026-07-07-G004: Uganda's Financial Intelligence Aut…

fim-int-2026-07-07-G004: Uganda's Financial Intelligence Authority has not published granular, dated ML investigation, prosecution, conviction, or asset-recovery statistics that would allow independent verification of FATF's stated enforcement-improvement finding. [resolved]

fim-int-2026-07-14-G001: No primary High Court judgment text…

fim-int-2026-07-14-G001: No primary High Court judgment text was retrieved for the FIA account-freezing ruling; sourced only via a single Tier-3 law-firm summary, capping confidence at Assessed. [resolved]

fim-int-2026-07-14-G002: FIA's underlying September 2025 Nat…

fim-int-2026-07-14-G002: FIA's underlying September 2025 National ML/TF Risk Assessment on Virtual Assets report was not directly retrieved this cycle; findings are sourced via secondary press quotation of the primary report. [resolved]

fim-int-2026-07-14-G003: Tier D jurisdictions (Cambodia, Lao…

fim-int-2026-07-14-G003: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not researched this cycle as the pass was jurisdiction-locked to Uganda; D1 and D4 domains remain thinly covered. [resolved]

fim-int-2026-07-14-G004: No independent second source corrob…

fim-int-2026-07-14-G004: No independent second source corroborates the report of FIA-ordered NGO account closures ahead of the 2026 elections; confidence capped at Assessed pending corroboration. [resolved]

fim-int-2026-08-04-G001: No Tier 1/2 primary URSB statement …

fim-int-2026-08-04-G001: No Tier 1/2 primary URSB statement confirming beneficial-ownership register non-publication status. [resolved]

fim-int-2026-08-04-G002: Uganda's direct conflict-finance ne…

fim-int-2026-08-04-G002: Uganda's direct conflict-finance nexus is thin; no Uganda-domiciled OFAC/EU designation located this cycle, only an incidental Kampala-born individual in a DRC/Rwanda designation round. [resolved]

fim-int-2026-08-04-G003: No primary NLGRB PDF located confir…

fim-int-2026-08-04-G003: No primary NLGRB PDF located confirming the full scope of the 3 March 2026 casino AML compliance session. [resolved]

fim-int-2026-08-04-G004: Tier D (KH/LA/MX/CO) mandatory chec…

fim-int-2026-08-04-G004: Tier D (KH/LA/MX/CO) mandatory checks were not actively re-searched this UG-bound dispatch pass. [resolved]

fim-int-2026-09-14-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-14-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2 Beneficial Ownership registry status for Uganda not substantiated at any tier this cycle. [resolved]

fim-int-2026-09-14-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-14-G002 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 Enabler Jurisdictions and D4 Conflict Finance domains could not be populated for Uganda this cycle pending primary-source escalation. [resolved]

fim-int-2026-09-14-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-09-14-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): FIA's National ML/TF Risk Assessment on Virtual Assets (Sept 2025) not independently retrieved; only secondary press coverage available this cycle. [resolved]

fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No T1 FIA statistics on DNFBP suspicious-transaction-report volumes were located to substantiate or quantify the enabler-sector reporting gap flagged by The Independent (Uganda). [resolved]

fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): No Uganda-specific beneficial-ownership register milestone was identified this cycle; D2 coverage remains thin. [resolved]

fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Uganda-specific conflict-finance, compliance-technology, or crypto/digital-asset development beyond the standing six-pillar/CBDC background was identified this cycle. [resolved]

fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Primary instrument text for FIA Circular No.13 and the March 2026 AML Schedule 2 amendment was not independently retrieved; provision-level confidence capped at Probable. [resolved]

fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary court judgment text retrieved for Silver Kayondo v Bank of Uganda; relies on single T3 law-firm summary. [resolved]

fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2, D3, D4 and D6 domains carried thin or no coverage for Uganda this cycle within the available search budget. [resolved]

fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary FIA, Bank of Uganda AML circular, or ESAAMLG mutual-evaluation-follow-up document was independently retrieved this cycle; findings rest on T1 OFAC designation plus T2/T3 secondary reporting. [open]

fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '…

fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No draft bill text or published statutory instrument exists for Bank of Uganda's six-pillar virtual-asset framework; cannot assess implementation timeline with confidence beyond Speculative. [open]

fim-int-2026-10-25-G001: No Uganda-specific beneficial-owner…

fim-int-2026-10-25-G001: No Uganda-specific beneficial-ownership registry development was located this cycle; standing BO-registry status is uncertain. [open]

fim-int-2026-10-25-G002: No Uganda-specific enabler-jurisdic…

fim-int-2026-10-25-G002: No Uganda-specific enabler-jurisdiction, conflict-finance, or compliance-technology development was located this cycle. [open]

FIM-GAP-001 (D4): Ugandan customs authorities have repeatedl…

FIM-GAP-001 (D4): Ugandan customs authorities have repeatedly been found not to complete due diligence on gold import/export documentation, or to ignore suspect documentation, allowing declared gold export volumes to vastly exceed plausible domestic production and enabling DRC conflict-gold to enter formal Ugandan export channels.

FIM-GAP-002 (D3): FATF's February 2024 statement urged Ugand…

FIM-GAP-002 (D3): FATF's February 2024 statement urged Uganda to move toward genuinely risk-based NPO supervision rather than classifying all NPOs as obliged entities, a deficiency that had persisted since at least the 2016 mutual evaluation.

FIM-GAP-003 (D2): Uganda's Parliament publicly characterised…

FIM-GAP-003 (D2): Uganda's Parliament publicly characterised the UK's 2024 corruption sanctions on the Speaker and two former ministers as retaliation for Uganda's anti-LGBTQ legislation rather than a genuine accountability measure, illustrating contested domestic narratives around PEP sanctions that can blunt their deterrent and reputational effect.

FIM-GAP-004 (D3): Uganda's Financial Intelligence Authority …

FIM-GAP-004 (D3): Uganda's Financial Intelligence Authority does not appear to publish granular, regularly updated public statistics on money-laundering investigations, prosecutions, convictions or asset-recovery outcomes, limiting independent verification of FATF's 2024 finding that Uganda demonstrated 'an increase in ML investigations and prosecutions'.

Evidence

Confidence-tiered claims

limited suspicious-transaction reporting despite formal accountable-person designation [Source 1]

Probable · 1 source

FIA is Uganda's designated FIU under the Anti-Money Laundering Act, Cap 118 [Source 1]

Probable · 1 source

Section 9 of the AML Act mandates suspicious-transaction reporting by accountable persons [Source 1]

Probable · 1 source

off the FATF grey list since February 2024 exit; next mutual evaluation expected 2028 [Source 1]

Probable · 1 source

Regulation 45(1) requires annual compliance reports from accountable persons [Source 1]

Probable · 1 source

Circular No.13 on FATF Recommendation 19 (measures for higher-risk countries), 14 February 2026 [Source 1]

Probable · 1 source

AML Schedule 2 amended by statutory instrument gazetted 10 March 2026 [Source 1]

Probable · 1 source

FIA account-freeze directives require prompt post-freeze judicial sanction though no prior notice is required (Silver Kayondo v Bank of Uganda, Misc. Cause No. 109 of 2022, judgment 24 April 2023 reported 13 April 2026) [Source 1]

Probable · 1 source

Off FATF grey list since February 2024 Paris plenary; not on FATF June 2026 list of 22 increased-monitoring jurisdictions [Source 1]

Probable · 1 source

Six-pillar virtual-asset licensing/AML-CFT/custody/cybersecurity framework announced by BOU Governor keynote (25 Nov 2025); no draft legislation published as of this cycle [Source 1]

Probable · 1 source

First three final draft Regulatory Technical Standards, including CDD standards under AMLR Art.28(1), published 1 October 2026 [Source 1]

Probable · 1 source

Cambodia-US joint operation seized approximately $7M in cryptocurrency linked to Sinaloa-cartel laundering via Cambodian networks [Source 1]

Probable · 1 source

Remains on FATF June 2026 increased-monitoring list; follow-up report dated 22 May 2026 [Source 1]

Probable · 1 source

Uganda reported as a downstream export/refining conduit for conflict gold smuggled from DRC's Ituri province, amid OFAC's June 2026 sanctions on Rwanda-linked mining/refining network; no Ugandan entity designated. [Source 1]

Probable · 1 source

OFAC designated Gasabo Gold Refinery LTD and three Rwandan mining companies on 25 June 2026 for smuggling conflict minerals from eastern DRC to Rwanda. [Source 1]

Probable · 1 source

Casinos must register as accountable persons with the Financial Intelligence Authority and submit annual AML/CFT compliance reports under NLGRB's 2026 licence-renewal notice, restating a standing DNFBP obligation. [Source 1]

Probable · 1 source

Uganda was removed from the FATF grey list in February 2024; ESAAMLG follow-up technical review on 11 identified reporting-area weaknesses scheduled for 2028. [Source 1]

Probable · 1 source

Bank of Uganda announced a six-pillar virtual-asset regulatory framework (licensing, client-asset protection, AML/CFT including Travel Rule, cybersecurity, market integrity, transparency) in a November 2025 keynote; no draft legislation located. [Source 1]

Uncertain · 1 source

FIA seeking approximately UGX4.5 billion in additional funding to address 11 of 40 FATF compliance areas flagged as deficient ahead of the 2028 FATF/ESAAMLG mutual evaluation. [Source 1]

Probable · 1 source

Removed from the FATF grey list in February 2024; next full mutual evaluation scheduled for 2028. [Source 1]

Probable · 1 source

VASPs are designated as 'accountable persons' under the Anti-Money Laundering (Amendment) Act, 2020, supervised by the Financial Intelligence Authority (FIA). [Source 1]

Probable · 1 source

Six-pillar virtual-asset regulatory framework (licensing, client-asset protection, AML/CFT including Travel Rule, cybersecurity, market integrity, transparency) announced by Governor 25 November 2025 keynote; no draft legislation published as of this cycle. [Source 1]

Probable · 1 source

VASPs are registered as accountable persons under the AML Act 2013 as amended, supervised by the FIA for AML/CFT purposes (a registration perimeter, not a licensing regime). [Source 1]

Probable · 1 source

Reporting Institutions are required under the Anti-Money Laundering Act to register with the Financial Intelligence Authority. [Source 1]

Probable · 1 source

Beneficial-ownership disclosure is administered via the Companies (Amendment) Act 2022 and the 2023 Beneficial Owners Regulations; commentary this year continues to flag BO/AML compliance as a 2026 enforcement priority, but no concrete amending instrument or enforcement action was located this cycle. [Source 1]

Probable · 1 source