Financial Crime World

Financing the Future: Uganda’s Anti-Money Laundering Authority Cracks Down on Suspicious Transactions

The Financial Intelligence Authority (FIA) in Uganda is strengthening its stance against financial crime by introducing new reporting requirements for suspicious transactions. In accordance with Section 9 of the Anti-Money Laundering Act 2013, the FIA is responsible for acquiring Suspicious Transaction Reports (STRs) from accountable persons.

To aid accountable persons in fulfilling their reporting obligations, the FIA has issued a Suspicious Transaction Report template (Form B) and guidelines. These resources will ensure a uniform approach to reporting potential instances of financial misconduct.

Annex 2: Completing the Suspicious Transaction Report Form

The FIA’s template and instructions offer invaluable assistance for accountable persons as they identify and report suspicious transactions. The Annex 2 section outlines a detailed, user-friendly process for filling out the STR form:

  1. Identity of the Accountable Person

    • Full name
    • Position and organizational affiliation
    • Contact information

  2. Identity of the Customer

    • Full name
    • Date and place of birth
    • Nationality
    • Identification number
    • Contact information

  3. Description of the Reported Transaction

    • Date and time
    • Type of transaction
    • Amount (in Ugandan currency and equivalent in foreign currency, if applicable)
    • Currency

  4. Reasons for the Suspicion

    • Specific observations or circumstances that triggered the suspicion

  5. Evidence to Support the Suspicion

    • Narrative explanation of the evidence
    • Description of the source and destination of the funds
    • Copy of any relevant documents or communications

  6. Additional Information

    • Additional comments or remarks

Suspicious Transactions Guidelines on Indicators

The FIA’s guidelines provide insight into circumstances likely to raise suspicions. Some indicators include:

  1. Frequent Transactions

    • Multiple transactions occurring closely in time
    • Transactions surpassing the customer’s historical pattern

  2. Large Transactions

    • Individual transactions significantly exceeding the customer’s known financial situation

  3. Transactions Inconsistent with the Customer’s Known Business or Investment Patterns

    • Unusual nature, size, or complexity of transactions

  4. Transactions with No Apparent Economic or Lawful Purpose

    • Transactions lacking a clear economic or lawful explanation

  5. Complex or Poorly Explained Transactions

    • Transactions that are difficult to understand or that lack complete information

By recognizing these indicators, accountable persons are better positioned to report concerns promptly, safeguarding the financial system from illicit activities and preserving confidentiality.

Suspicious Transaction Report (STR) Form B

The STR form is a vital weapon in the battle against financial crime. Its clear, structured reporting format provides the FIA with actionable information that can be used in its investigations. The STR form consists of the following sections:

  1. Personal Information

    • Name and contact details of the reporter

  2. Reporting Institution Information

    • Name and registration number of the reporting institution
    • Contact details of the institution’s Money Laundering Reporting Officer (MLRO)

  3. Customer Information

    • Details about the suspicious customer

  4. Description of Reported Transaction

    • Details about the transaction that gave rise to suspicion

  5. Reason for Suspicion

    • The basis for the reporter’s suspicions

  6. Evidence Supporting Suspicion

    • Documentation or other evidence supporting the reporter’s suspicion

  7. Additional Information

    • Additional comments or remarks from the reporter

By reporting transactions that meet the suspected indicators, accountable persons play a crucial role in upholding the financial integrity of Uganda. The Financial Intelligence Authority’s provision of these essential resources and a transparent reporting process empowers Ugandans to contribute to a more open and secure financial environment for everyone.