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Sydney Asubo, the ED FIA

By Isaac Wandubile 

Sydney Asubo, the founding Executive Director for Finance Intelligence Authority (UIA), has shared on the progress Uganda has made regarding compliance with international standards and requirements when it comes to combating money laundering and terrorism financing-related activities which in most cases are categorized as cross border crimes whose commission involves more than one country or geographical jurisdiction.

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Speaking to media reporters at FIA Kampala offices during a Thursday afternoon engagement, Asubo revealed that Uganda is working with the international community through something called Financial Action Task Force (FATF) to ensure that the country is totally compliant and able to effectively participate in global efforts aumed at combating illegal transfers of illicit money aimed at facilitating terrorism financing and money laundering.

FATF is a watchdog of sorts that is charged with setting, harmonizing and enforcing standards reflected in steps and interventions countries undertake to mitigate against terrorism financing and money laundering operations. Through FATF, countries of the world are categorized as blacklisted and grey-listed. Blacklist is for countries that are considered to be irredeemably non-compliant and currently the pariah list has Iran and North Korea. Uganda is on the grey list which comprises of countries that exhibit the political will to cooperate with the rest of the world but still face or suffer some constraints in their efforts to comply.

L-R Michael Olupot-Tukei, the Deputy ED FIA, Lazarus Mukasa the Director Analysis and Monitoring FIA, Samuel Naako the Manager Internal Audit FIA, James Ssaka the Senior Analyst FIA.

Assessments like these (grey or blacklist) matter and are important because they are some of the indicators credible investors of repute consider or reference upon when deciding to invest in a country or not. Naturally, countries on the blacklist will be perceived as pariah making it hard for them to attract credible investors. Asubo told journalists that Uganda is doing very well on all the compliance indicators and will soon be off the grey list which has a total of 22 countries from Africa, Latin America and Middle East including UAE, Senegal, Pakistan, Haiti and others.

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That to be removed from the grey list, Uganda was given 22 action areas to improve upon and so far, 6 areas have been addressed to the satisfaction of the Task Force members- meaning 16 others remain. Asubo explained that because EU and Britain apply the same standards, satisfying the FATF requirements will be such a major breakthrough for Uganda whose standards will be acceptable as good everywhere including in UK and the entire European Union.

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Optimistic as always, Asubo is looking at September this year as the time when Uganda will be through with many of these requirements which include amending a number of related laws which are already in place. These include the Company Act, Anti-Terrorism Act (to cover threats relating to weapons of mass destruction), Partnership Act, Insolvency Act, Trustees Act and Proceeds of Crime Act.

Asubo revealed that, to ensure inclusiveness and expedite compliance to the standards requirements set by FATF, the Finance Minister Matia Kasaija put in place a task force to advise government on the necessary steps to take and the same is housed at FIA headquarters or Secretariat. The task force has representatives from Ministries of Finance, Internal Affairs, Justice Foreign Affairs and Presidency.

L-R: James Ssaka the Senior Analyst FIA, James Ssaka the Senior Analyst FIA.

The other represented MDAs include CMA, IRA, IGG, ODPP, URSB, Uganda Bankers Association, BoU, NGO Bureau and others. Asubo said that in the last 2 years, the task force has done a lot of work resulting into 6 of the 22 FATF requirements being satisfied or complied with. That much more would have been accomplished by now if it hadn’t been the COVID19 lockdown which constrained operations of government MDAs, prevented frequent meetings and slowed down progress.

Asubo explained that the 40% budget cuts across government, in order to focus resources on anti-COVID operations, had negatively impacted on progress of the task force. Equally true, the necessary amendments to the laws couldn’t be promptly delivered upon because 2020 and 2021 were lost in campaigning as MPs and Ministers went to the population to seek reelection. Some of the action plan items (under the delivered 6) related to things like enacting the necessary strategies into place, deepening private sector involvement, risk assessment and training of law enforcement agencies which is inevitable: Money Laundering being generally a new crime in the Ugandan jurisdiction.

Asubo says that Uganda is generally well rated among its peers because, as was disclosed under the earlier FATF assessment during the 2014-2017 assessment phase, the necessary legal and institutional framework is already firmly in place. The same is respectively exemplified by the existence of the Anti-Money Laundering Act that was enacted in 2013 and the establishment of institutions like FIA itself.

Samuel Were Wandera the Director Compliance and Training FIA

What is now being examined, under the ongoing assessment, is the extent to which the provisions of the law are being implemented and effectively applied to combat the targeted crimes. The political commitment of the Ugandan leadership is equally being inquired into to establish the extent to which the country’s practices aimed at combating the targeted crimes can be sustained in the long term.

Responding to one of the questions from journalists, Asubo said they have done so much work that Uganda can’t be considered a safe haven for perpetrators of money laundering or even terrorism financing by any measure. He said the laws that are in place and collaboration between concerned government of Uganda enforcement agencies all combine to make money laundering and terrorism financing one of the riskiest ventures for anyone to engage into on the Ugandan territory. He said that through refresher trainings, capacity continues to be built for officers working under ODPP, Uganda Police Force, IGG, Judiciary and others to deepen appreciation of all the offences created under the Anti-Money Laundering Act.

The FIA ED was also prompted to discuss the areas or activities through which money laundering proceeds are mostly derived in contemporary Uganda, areas where much of the money laundering proceeds is invested and why criminal prosecutions/convictions haven’t been many or why they have rarely attracted media coverage, if at all.

Samuel Naako the Manager Internal Audit FIA.

Asubo enumerated wildlife trafficking, human trafficking, minerals trafficking, corruption and smuggling as some of the areas or activities from which much of the money laundering proceeds result. And when it comes to investing the money, much of it (as was disclosed in FIA’s 2018 National Risk Assessment Report) goes into real estate investments- basically the purchase or acquisition of land and houses.

And Asubo explained what makes such real estate deals attractive to owners of such illicit money. “It’s easy to hide the money there because 80% of land ownership in Uganda remains untitled and even the 20% which is titled, the records aren’t adequately computerized making it possible to safely hide huge money that way.”

He said that such beneficiaries proceed to easily hide behind the names of their spouses, girlfriends, boyfriends or even children as transfer forms and sales agreements relating to such land are being signed. Asubo also said that, as FIA, they remain intrigued that much of the money stolen from the GoU is kept and invested here in the country as opposed to being taken or hidden abroad.

“They buy houses and land here because they feel very comfortable doing that. They are sure they can’t be caught and even when caught, they are sure they can bribe their way out,” Asubo said adding this state of affairs must frighten everyone because it’s not good for the reputation of Uganda as a country. (For comments on this story, get back to us on 0705579994 [whatsapp line], 0779411734 & 0200900416 or email us at

James Ssaka, Senior Analyst FIA

Samuel Naako the Manager Internal Audit FIA.

Michael Olupot-Tukei the Deputy ED FIA.

Lazarus Mukasa the Director Analysis and Monitoring FIA.

Cyrus Barigye the Director ICT Systems and Security FIA.




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