Ponzi Schemes Pose Threats to Uganda’s Journey Off the Grey List

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Uganda’s Anti-Money Laundering and Countering of Terrorism Financing Measures

Measure Implementation Status
National AML/CFT Strategy Adopted
Risk-Based Supervision for Financial Institutions Implemented
Beneficial Ownership Declaration Obligations Enforced
Timely Access to Ownership Information Ensured
Policies for Identifying and Tracing Criminal Proceeds Established and Implemented
Targeted Financial Sanctions for Proliferation Financing Implemented


The Minister of State for Finance, Planning, and Economic Development, Henry Musasizi, affirmed the government’s commitment to supporting Uganda’s Anti Money Laundering and Countering of Terrorism Financing Framework. The Financial Intelligence Authority (FIA) is optimistic about a positive outcome in the upcoming FATF assessment.

The FATF Plenary recently approved an onsite visit to verify the sustained implementation of recommended reforms. FIA Executive Director, Samuel Were Wandera, expressed confidence in Uganda’s political commitment during a Technical Assistance Workshop organized by the East and Southern African Anti-money Laundering Group (ESAAMLG).

The government, since February 2020, has collaborated with FATF’s ICRG ESAAMLG to address strategic deficiencies, implementing various policy and operational measures. Wandera highlighted the adoption of a national AML/CFT strategy, risk-based supervision for financial institutions, and enforcement of beneficial ownership obligations, among others.

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Despite the positive outlook, concerns have been raised about new risks, particularly Ponzi schemes. Financial consulting firm PwC acknowledged Uganda’s efforts but cautioned against the vulnerability of such schemes to money laundering due to limited Know Your Customer (KYC) procedures. PwC urged the government to regulate multi-level marketing companies to prevent illicit use and enhance Uganda’s position in FATF’s evaluation.

The fate of Uganda’s grey list status will be determined by the forthcoming FATF assessment, with experts assessing the progress made and potential risks.

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