Anti -Money laundering is governed by the Anti-money laundering Act of 2013 as amended together with its regulations. The act lays down strategies that must be employed by organizations to combat money laundering and terrorism financing which

include the following:

• Employing know your clients, customers system by doing due diligence;
• Identification of clients, customers, other persons and other anti-money laundering measures;
• Ensuring that proper Maintenance of records,among others

Accountable persons are required to register and to annually file a report with the Financial Intelligence Authority (FIA). Accountable persons are listed under the Second Schedule to the Anti Money Laundering Act, 2013. Notably among these are:

• Non-Government Organisations,
• Advocates,
• Casinos,
• Financial Institutions,
• Registrars of Land and Companies,
• licensing Authorities, among others.

Every accountable person is required under Regulation 45(1) of the Anti-Money Laundering Regulations 2015 to submit to the (FIA), a compliance report setting out the level of compliance with the FIA Act, Regulations and the Internal Anti-Money Laundering and Combating Terrorist Financing Policy by the 31st of January 2023.

The FIA developed a compliance report template to streamline and standardize the reports submitted by Accountable persons.

The amendments have a significant impact on the lives of individuals and the business environment in Uganda. TASLAF is pleased to present a summary of the major changes brought about by the above amendments and what the changes mean for you and your business.

Requirements

1. Annual Compliance Report. (A hard copy delivered to the FIA offices)
2. Anti-Money Laundering and Counter- Terrorism Financing (AML/CTF) attachments;
   • Copy of the AML policy and procedures
   • Copies of AML risk assessment of customers, products, methods of delivery and geographical location of customers.
   • Copy of the independent audit report of the compliance program (2019) Suspicious transaction reports.

Sanctions

The Anti Money Laundering (AML)sanctions regime consists of both criminal and administrative sanctions. Section 21 of Anti- Money Laundering Act, 2013 gives powers to the Financial Intelligence Authority to impose administrative sanctions on an accountable person who fails to comply with directives, guidelines or requests issued by the Authority.

Conclusion

All accountable persons are thus urged to file the Annual Compliance Report with the FIA by the 31st January in order to avoid any non-compliance sanctions.

Our Legal and Regulatory Compliance Team: