Uganda's Anti-Money Laundering Act (Cap. 118) Explained: Offences, Accountable Persons, the FIA and Penalties (2026)
A plain-English guide to Uganda's Anti-Money Laundering Act, 2013 (now Cap. 118) and its Regulations: the money laundering offence and penalties, who is an accountable person, due diligence, reporting and record-keeping, the FIA's powers, supervision and administrative fines, and the 2017, 2022, 2023 and 2025 changes.
Short answer: Uganda's Anti-Money Laundering Act, 2013 (Act 12 of 2013), cited as Cap. 118 since the 7th Revised Edition of Uganda's laws took effect on 1 July 2024, makes money laundering a crime punishable by up to 15 years' imprisonment. It creates the Financial Intelligence Authority (FIA). Accountable persons must:
- apply customer due diligence;
- report suspicious transactions within two working days;
- report cash transactions of UGX 20 million and above;
- keep records for 10 years;
- run a compliance programme with a money laundering control officer.
The Anti-Money Laundering Regulations, 2015, amended in 2022 and 2023, fill in the detail.
This guide is for compliance officers, boards and legal teams at Ugandan banks, microfinance institutions, insurers, forex bureaus, payment providers, accountants, lawyers and other accountable persons. It is a practical guide, not legal advice: the Act, the Regulations and the FIA's guidance are the authoritative texts.
A note on section numbers
The 7th Revised Edition renumbered some sections, and the Cap. 118 text is not freely available: the public consolidation is dated 27 November 2020 and omits the 2022 and 2025 changes. The FIA has confirmed a few Cap. 118 numbers, for example section 10 for suspicious transaction reports (section 9 of the 2013 Act). This guide therefore uses the 2013 numbers, "as amended", and gives the Cap. 118 number only where the FIA has confirmed it.
The law in force
| Instrument | What it does |
|---|---|
| Anti-Money Laundering Act, 2013 (now Cap. 118) | The core law: commenced 1 November 2013 |
| Anti-Money Laundering (Amendment) Act, 2017 | Rewrote due diligence, record-keeping and STR duties; added risk assessment, reporter confidentiality and supervisors' enforcement role |
| Anti-Money Laundering (Amendment) Act, 2022 | Added proliferation financing to risk assessment; set administrative fines of up to 37,500 currency points |
| Anti-Money Laundering Regulations, 2015 | Registration, the money laundering control officer, reporting forms, records and compliance reports |
| Amendment Regulations, 2022 and 2023 | Politically exposed persons' family and associates (2022); fines for breaches, 10-year records and risk assessments (2023) |
| Second Schedule amendments, 2020 and 2025 | Added virtual asset service providers (2020); removed NGOs, churches and charities (2025) |
The Act at a glance
| Part | Subject |
|---|---|
| I | Preliminary, including definitions |
| II | Criminalisation of money laundering |
| III | Prevention measures: due diligence, records, reporting |
| IV | The Financial Intelligence Authority |
| V | Seizure, freezing and forfeiture |
| VI | International cooperation |
| VII | Offences and penalties |
| VIII | Miscellaneous |
The First Schedule fixes the currency point at UGX 20,000, and the Second Schedule lists the accountable persons.
The money laundering offence
Money laundering covers converting, transferring, transporting or transmitting property known or suspected to be proceeds of crime, to conceal its origin or help someone evade the consequences. It also covers:
- concealing the true nature, source or ownership of proceeds;
- acquiring, possessing or using them;
- acting "to avoid the transaction reporting requirements" of the Act;
- assisting, or participating in or conspiring to commit, any of these (section 3).
Knowledge or intent "may be inferred from objective factual circumstances" (section 4), and a person can be charged without first being convicted of the crime that produced the proceeds (section 5).
| Offender | Maximum penalty (section 136(1)) |
|---|---|
| Natural person | 15 years' imprisonment, a fine of 100,000 currency points (UGX 2 billion), or both |
| Legal person | A fine of 200,000 currency points (UGX 4 billion) |
The High Court convicted on these provisions in June 2025, in a case hosted on the FIA's website.
Who the Act covers
An "accountable person" is anyone listed in the Second Schedule. The list covers:
- advocates, notaries and accountants, in practice rather than in-house;
- trustees and trust and company service providers;
- casinos, real estate agents, and dealers in precious metals and gems;
- financial institutions, capital markets brokers, dealers and advisers, and insurers;
- the Registrars of Companies and of Land, the Uganda Investment Authority and licensing authorities;
- a list of other financial businesses;
- virtual asset service providers (since 2020).
Paragraph 15, which covered NGOs, churches and charities, was repealed in February 2025.
What accountable persons must do
| Duty | What the law requires |
|---|---|
| Customer due diligence (section 6) | No anonymous or fictitious accounts; verify customers and beneficial owners; due diligence on occasional transactions of 5,000 currency points (UGX 100 million) or more; measures for politically exposed persons; no shell banks; enhanced measures for high risk. Where due diligence cannot be completed, refuse or end the relationship and file an STR |
| Risk assessment (section 6A) | Assess money laundering, terrorist financing and, since 2022, proliferation financing risk, including before new products or technologies. The Regulations require an institutional risk assessment at least every three years, with the results sent to the FIA within five working days |
| Compliance programme | Policies, compliance management, staff screening, training, independent audit and group information-sharing (section 6(17)); internal controls, periodic independent audits and an annual compliance report to the FIA by 31 January |
| Money laundering control officer | Appointed at senior management level; not the internal auditor, and not the chief executive except in a sole proprietorship or single-member company (regulation 6) |
| Records | Kept for at least 10 years |
| Registration | Register with the FIA, now only on goAML |
| Reporting | Suspicious transactions within two working days; cash and monetary transactions of UGX 20 million and above; international wire transfers for banks, remitters and mobile money providers |
See our guides to FIA goAML registration, suspicious transaction reports and large cash transaction reports.
The Financial Intelligence Authority
The Act establishes the FIA (section 18 of the 2013 Act), which says it was set up on 1 July 2014. It is independent: it "shall not be subjected to the direction, instruction or control of any person or Authority".
Functions:
- receiving and analysing reports, and disseminating intelligence;
- giving guidance to accountable persons;
- keeping information for at least 10 years.
Powers:
- obtaining information and inspecting premises;
- halting financial activity once a suspicion has been reported;
- registering accountable persons;
- imposing administrative sanctions;
- coordinating the national risk assessment;
- supervising compliance in consultation with the regulators.
The FIA cites its functions and powers as sections 22 and 23 of Cap. 118.
Supervision and administrative sanctions
Each accountable person's supervisory body enforces compliance, and the FIA does so where there is none (section 21A, 2013 numbering). Uganda's 2023 National Risk Assessment describes the allocation:
| Sector | Supervisor |
|---|---|
| Banks, credit institutions, microfinance deposit-taking institutions | Bank of Uganda |
| Tier 4 microfinance (including SACCOs) and money lenders | Uganda Microfinance Regulatory Authority |
| Insurers | Insurance Regulatory Authority |
| Capital markets | Capital Markets Authority |
| Casinos and gaming | National Lotteries and Gaming Regulatory Board |
| Accountants | Institute of Certified Public Accountants of Uganda |
| Real estate agents and virtual asset service providers | The FIA |
The sanctions. When an accountable person ignores a directive, the FIA or the supervisory body may impose a reprimand or a warning, or "a fine not exceeding thirty-seven thousand five hundred currency points" (UGX 750 million). The 2022 amendment allows the fine whether or not the person is also charged, and allows sanctions on the officers and directors who took part. Under the 2023 Regulations an administrative sanction must come before any fine, and the FIA publishes the action it takes.
Offences and penalties
| Offence (2013 numbering) | Maximum penalty |
|---|---|
| Money laundering (sections 3 and 116) | 15 years and/or UGX 2 billion (individual); UGX 4 billion (legal person) |
| Failing to report a suspicious transaction, intentionally or negligently (section 125) | 5 years and/or 33,000 currency points (UGX 660 million) for an individual; 70,000 currency points (UGX 1.4 billion) for a legal person; up to 5,000 currency points a day while it continues |
| Failing to report cash transactions (section 124) | As above |
| Tipping off (section 117) | As above |
Uganda and the FATF
The FATF monitored Uganda from February 2014 to November 2017, and kept it under increased monitoring ("the grey list") from February 2020 to 23 February 2024. In 2026 the FIA reported that Uganda is now rated compliant or largely compliant on 31 of the 40 FATF Recommendations.
What this means for your systems
| Duty | What a system has to do |
|---|---|
| Due diligence and PEPs | Verify customers and beneficial owners, apply the UGX 100 million occasional-transaction trigger, and flag politically exposed persons and their family and associates |
| Risk assessment | Hold a documented institutional assessment, refreshed at least every three years and sent to the FIA within five working days |
| Monitoring and STRs | Raise alerts, open them within 3 working days, decide within 10, and file STRs within 2 working days of suspicion |
| Cash reporting | Aggregate same-day transactions at UGX 20 million and file LCTRs and ALCTRs on goAML |
| Records | Keep 10 years of reconstructable records |
Frequently asked questions
What is Cap. 118 in Uganda?
The citation of the Anti-Money Laundering Act, 2013 in the 7th Revised Edition of the Principal Laws of Uganda, in force since 1 July 2024. The revision renumbered some sections, so section 9 of the 2013 Act (suspicious transaction reports) is cited by the FIA as section 10 of Cap. 118.
What is the penalty for money laundering in Uganda?
Up to 15 years' imprisonment, a fine of up to 100,000 currency points (UGX 2 billion), or both, for an individual; a fine of up to 200,000 currency points (UGX 4 billion) for a legal person.
Who is an accountable person in Uganda?
Anyone in the Second Schedule to the Act, including lawyers, notaries and accountants in practice, banks and other financial institutions, insurers, casinos, real estate agents, dealers in precious metals and gems, trust and company service providers, and virtual asset service providers.
How long must records be kept in Uganda?
At least 10 years. The 2023 Regulations raised the regulatory retention period from five to ten years, in line with the Act.
What administrative fines can the FIA impose?
After a directive is ignored, a fine of up to 37,500 currency points (UGX 750 million), alongside reprimands and warnings, and sanctions on the officers and directors involved.
See how Creodata's AML compliance software in Uganda maps each duty to a module: book a demo.
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)
- Large Cash Transaction Reports in Uganda: The UGX 20 Million Threshold, Form A and goAML (2026)
- AML Compliance Software in Uganda: A Buyer's Guide for Banks, SACCOs and Fintechs (2026)
