Uganda AML for Accountants: FIA Registration and Duties

Uganda's anti-money laundering (AML) framework treats accountants as "accountable persons" who must register with the Financial Intelligence Authority (FIA), appoint a compliance officer and report suspicious transactions. This guide draws on the FIA's online registration guidelines issued in January 2024 and on the text of the Anti-Money Laundering Act, 2013 as published by the Uganda Legal Information Institute (ULII). One point needs flagging at the start: the Act text we could read was the original 2013 version, not the version as amended since, so we label what comes from it and recommend that you check the current consolidated Act before relying on any figure.

Are accountants covered?

Yes. Section 1 of the Act defines an accountable person as any person listed in the Second Schedule. The FIA's registration guidelines say that the Second Schedule, as amended, includes "accountants as defined in the Accountants Act" and other independent legal professionals, alongside categories such as advocates, notaries, casinos, real estate agents, dealers in precious metals and gems, trust and company service providers, financial institutions and virtual asset service providers. The guidelines name Section 21(A) and the Second Schedule as the legal basis for the list, and Section 21(pb) of the Act as amended as the basis for registration.

Registering with the FIA

The FIA's January 2024 guidelines require accountable persons to register with the Authority on its goAML system. According to the guidelines:

• the compliance officer, called the Money Laundering Control Officer (MLCO), registers the entity as an organisation, choosing "Reporting Entity" even for sole proprietorships;
• four tabs are completed: Reporting Entity, Administrator (MLCO), Attachments, and Preview and Submit;
• documents are uploaded as PDF, JPEG or PNG files, and an electronic certificate of registration is issued on approval;
• other users register as "User (Reporting Entity)" with an authorisation letter signed by the chief executive or managing director;
• the FIA says it will decide on a registration request within 72 hours of receiving it.

For accountants, the guidelines list in section 11.5 the documents needed: Forms 1 and 3, a certificate of registration, a licence issued by the Institute of Certified Public Accountants of Uganda (ICPAU), practising certificates for partners and a copy of the MLCO's national ID or equivalent. Changes to registered particulars must be notified within 15 days, and a change of MLCO must be notified within 15 days using Form 3.

The compliance officer

The FIA's guidelines refer to appointing an MLCO under regulation 6(1) of the Anti-Money Laundering Regulations, 2015. The original Act, in section 6(m), required accountable persons that maintain client accounts to appoint a Money Laundering Control Officer to oversee their AML and counter-terrorist financing programmes. The guidelines say that sole proprietorships also register as a "Reporting Entity" on goAML.

Penalties the FIA guidelines set out

For failing to register, the FIA first issues a written directive to comply. If the person still does not comply, the guidelines state a fine not exceeding 500 currency points (UGX 10,000,000) for a corporate person, or not exceeding 250 currency points (UGX 5,000,000) for a natural person. Failing to appoint an MLCO carries, according to the guidelines, a fine of up to 1,250 currency points (UGX 25,000,000) for a corporate person. The guidelines cite regulations 4(4) and (5) and 6(8) and (9) of the Anti-Money Laundering Regulations, 2023 for the penalties. We have not read those regulations.

What the original 2013 Act required

These points come from the original 2013 Act as published by ULII. Treat them as a guide to the structure of the duties, and check the current figures.

• Customer due diligence (section 6): do not open an account, start a business relationship or carry out certain transactions without due diligence; verify identity using reliable, independent source documents; identify beneficial owners; monitor on an ongoing basis; apply enhanced measures to higher-risk categories; and, if due diligence cannot be completed, do not proceed and consider a suspicious transaction report.
• Record keeping (section 7): the original text sets identity information to be kept for at least ten years, and records needed to reconstruct reportable transactions for at least ten years after the transaction.
• Suspicious transaction reporting (section 9): the original text requires reports to the Authority as soon as practicable, "but not later than two working days".
• Cash transactions: cash transactions over one thousand currency points are caught by the original sections 6 and 8, with same-day multiple transactions aggregated.

For the general principles behind these duties, see our guides to customer due diligence in accountancy practices and politically exposed persons.

What we could not confirm

• The amended Act. The text we read was the original 2013 Act, and the penalties section (section 136) and tipping-off offence (section 117) were not included in what we could read.
• The Anti-Money Laundering Regulations, 2015 and 2023, which the FIA guidelines cite.
• The value of a currency point beyond the figures the FIA guidelines give in their penalty examples.
• Whether the reporting deadline and thresholds above have changed since 2013.

Practical steps: our suggestions

These are our suggestions, not requirements of the Act or the FIA.

1. Check that your firm is registered on goAML and that the certificate of registration is on file.
2. Name an MLCO and record the 15-day notification date for any change.
3. Obtain the current consolidated Act and regulations and check the reporting deadline and thresholds.
4. Write a reporting procedure that can meet a short deadline, and test it.
5. Keep identity and transaction records for at least the longer of the periods your supervisor confirms.

For comparison with other African regimes, see our guides to Kenya and Ghana.

Frequently asked questions

Do I need to register with the FIA?

The FIA's guidelines say accountable persons listed in the Second Schedule, which includes accountants, must register on goAML.

Who submits the registration?

The Money Laundering Control Officer registers the entity, and other users register against the organisation with an authorisation letter.

What is the penalty for not registering?

After a written directive to comply, the guidelines state fines of up to 500 currency points (UGX 10,000,000) for a corporate person and up to 250 currency points (UGX 5,000,000) for a natural person.

This guide is general information, not legal advice.