Large Cash Transaction Reports in Uganda: The UGX 20 Million Threshold, Form A and goAML (2026)
Short answer: Ugandan accountable persons must record every cash or monetary transaction, in any currency, of 1,000 currency points (UGX 20 million) or more on Form A on the day it happens. One person's transactions in a day are added together, and records are kept for 10 years. The reports go to the Financial Intelligence Authority (FIA) on goAML as large cash transaction reports (LCTRs), or aggregated LCTRs for a day's smaller transactions. No Minister has set a filing period; the FIA's guidance sets a weekly cycle, by 5pm every Tuesday for the previous week.
This guide is for money laundering control officers (MLCOs), operations and compliance teams at Ugandan banks, microfinance institutions, forex bureaus, insurers, money remitters and other accountable persons. It is a practical guide, not legal advice: the Anti-Money Laundering Act, the Regulations and the FIA's guidance are the authoritative texts.
The rule
Section 8 of the Anti-Money Laundering Act, 2013 (now Cap. 118) sets the cash-reporting duty:
| Element | What the Act says |
|---|---|
| What | Every "cash and monetary transaction involving a domestic or foreign currency" above 1,000 currency points |
| How | Recorded on Form A, "accurately and completely", on the day the transaction occurs |
| Aggregation | Several transactions by or for one person in one day that together exceed the threshold are treated as one |
| Records | Form A kept for 10 years from the date of the transaction |
| Exemption | Transactions on their own account between accountable persons supervised by Ugandan authorities |
| Filing | Form A filed with the FIA "within such time as is prescribed by the Minister" |
A currency point is UGX 20,000, so 1,000 currency points is UGX 20 million.
"Exceeding" or "equivalent to or exceeding"? The Act says "exceeding" 1,000 currency points. Regulation 39(3) of the 2015 Regulations says "equivalent to or exceeding", and the FIA's training describes the line as UGX 20 million "or more". Treat transactions of UGX 20 million and above as reportable.
Not only cash. The section covers "cash and monetary transactions", and the FIA's Form A has a column for the instrument type, so non-cash instruments are in scope. Foreign currency is converted into shillings at the rate when the transaction is concluded.
When to file
The Act leaves the filing period to the Minister, and no period has been prescribed. The FIA's own guidance fills the gap. Its 2015 guidelines on large cash and monetary transactions say reports are filed "on weekly basis, by 5:00pm every Tuesday for the transactions of the preceding week". It repeated the Tuesday cycle in its 2020 goAML training, and uses the same cycle for international wire transfer reports.
The 2015 guidelines also told reporters to file in Excel, which goAML has since replaced. Confirm the current cycle with the FIA, and treat the weekly Tuesday deadline as the baseline.
Filing on goAML
| goAML report | Use it for |
|---|---|
| LCTR, large cash transaction report | A single transaction at or above UGX 20 million |
| ALCTR, aggregated large cash transaction report | "the series of transactions made by a person or entity within a day summing up to 20 million Ugandan shillings or more", where each payment is below that |
The MLCO, or their alternate, files the reports. Accepted reports receive an automatic acknowledgement. Reports are confidential: "Under no circumstances should the customer of the reporting entity or any unauthorized person be aware that a report about them has been filed with the FIA."
What Form A records. The customer, nationality, ID type and number, account or policy number, date, debit or credit, instrument type, currency, foreign amount, shilling amount, purpose, and the originator or beneficiary.
If you are not yet registered on goAML, see our FIA goAML registration guide.
Related reports and thresholds
| Report or rule | What applies |
|---|---|
| International wire transfer reports (IWTRs) | Since 1 April 2021, banks, credit institutions, microfinance deposit-taking institutions, money remitters and mobile money providers report international wire transfers weekly, by 5pm every Tuesday, on goAML. Transfers between financial institutions on their own account are excluded, and the guidelines set no value threshold |
| Incomplete wire transfers | Report to the FIA any electronic funds transfer that lacks complete originator and beneficiary information (regulation 34(5)) |
| Cross-border declarations | Cash and bearer instruments carried into or out of Uganda are declared on Form C against a threshold of 1,500 currency points (UGX 30 million); customs send the forms to the FIA within 24 hours |
| Customer due diligence | Occasional transactions of 5,000 currency points (UGX 100 million) or more, single or linked, trigger due diligence |
If goAML is down, IWTRs go by e-mail to iwtr@fia.go.ug and must be uploaded to goAML once it is back.
Structuring
Splitting cash to stay under UGX 20 million does not avoid the duty: same-day transactions are aggregated. Acting "to avoid the transaction reporting requirements" is also one of the acts that make up the money laundering offence (section 3(d) of the 2013 Act). The FIA lists, among its suspicion indicators, a client who "consistently makes cash transactions that are just under the reporting threshold amount". That calls for a suspicious transaction report, not just a cash report: see our guide to STRs in Uganda.
Penalties
| Failure | Penalty (2013 Act and Regulations) |
|---|---|
| Intentionally failing to report cash transactions (section 124) | Individual: up to 5 years' imprisonment, a fine of up to 33,000 currency points (UGX 660 million), or both. Legal person: up to 70,000 currency points (UGX 1.4 billion) |
| Breaching the cash-reporting regulation after an FIA directive (regulation 39) | Administrative fine of up to 37,500 currency points (UGX 750 million) for a corporate body, or 12,500 currency points (UGX 250 million) for a natural person |
How much the FIA receives
In FY2021/22 the FIA received 4,079 LCTRs from 61 accountable persons through goAML. They covered 3,427,986 transactions worth UGX 550.35 trillion, and commercial banks filed 2,352 of the reports.
Cash reporting checklist
- Flag every cash or monetary transaction of UGX 20 million or more, in any currency, converted at the rate when it is concluded.
- Aggregate each customer's same-day transactions across branches and channels, and file an ALCTR when they reach the threshold.
- Complete Form A on the day of the transaction, and keep it for 10 years.
- File LCTRs and ALCTRs on goAML on the FIA's weekly cycle, and confirm the cycle with the FIA.
- Report international wire transfers on the same weekly cycle if you are a bank, remitter, MDI, credit institution or mobile money provider.
- Watch for amounts just under the threshold, and file an STR when the pattern is suspicious.
- Keep reports confidential from the customer.
Frequently asked questions
What is the cash transaction threshold in Uganda?
1,000 currency points, which is UGX 20 million. The Act says "exceeding" and the Regulations say "equivalent to or exceeding", so treat UGX 20 million and above as reportable.
When must large cash transaction reports be filed in Uganda?
The Minister has not prescribed a period. The FIA's guidance sets a weekly cycle: by 5pm every Tuesday for the previous week's transactions. Confirm the current cycle with the FIA.
Are foreign-currency transactions included?
Yes. The duty covers transactions "involving a domestic or foreign currency"; convert to shillings at the rate when the transaction is concluded.
What is an ALCTR?
An aggregated large cash transaction report: a goAML report for a series of transactions by one person or entity in a day that together reach UGX 20 million, even though each one is below it.
Are transactions between banks reportable?
Transactions on their own account between accountable persons supervised by Ugandan authorities are not recorded on Form A (section 8(4)). Transactions you carry out for customers are.
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More guides for Uganda
- Uganda FIA goAML Reporting: A Practical Guide for Banks
- FIA goAML Registration in Uganda: Step by Step for Accountable Persons (2026)
- Suspicious Transaction Reports in Uganda: The Two-Working-Day Rule, the FIA's Timelines and goAML Filing (2026)
- Uganda's Anti-Money Laundering Act (Cap. 118) Explained: Offences, Accountable Persons, the FIA and Penalties (2026)
- AML Compliance Software in Uganda: A Buyer's Guide for Banks, SACCOs and Fintechs (2026)