Financial Crime World

Regulators Review Due Diligence Measures for Customer Identification

In an effort to strengthen measures against money laundering and terrorism financing, regulators are reviewing due diligence measures related to identification information, records, and documents of all existing customers.

Ensuring Commensurate Risk-Based Approach

The review aims to ensure that the extent of due diligence measures applied to individuals and entities is commensurate with the level of risk posed by their business relationships, products, or transactions. Accountable persons, such as financial institutions, must be able to demonstrate to regulatory authorities that their due diligence measures are appropriate in view of the risks.

Identification Requirements for Natural Persons


For natural persons who are citizens or lawfully resident in Uganda, accountable persons require:

  • Proof of identity through a national identification card or alien’s identification card
  • Additional information may be required, including:
    • Residential address
    • Telephone contact details
    • Employment verification
    • Tax identification number (in some cases)

Verification Process for Natural Persons


The verification process involves:

  • Confirming the identity of natural persons by requesting additional information from recognized sources, such as:
    • Utility bills
    • Income tax identification numbers
    • Written references
  • In certain situations, accountable persons may need to request confirmation from government agencies or third parties.

Identification Requirements for Foreign Nationals


For foreign nationals who are not resident in Uganda, accountable persons require:

  • Detailed information about their identity, including:
    • Name
    • Residential address
    • Passport details
  • The verification process involves independently confirming this information with:
    • Uganda Citizenship and Immigration Control Board
    • The individual’s bank in their country of origin

Establishing Identity of Local Entities and Bodies


For local entities and bodies, accountable persons require:

  • Proof of registration or incorporation
  • Information about the entity’s management structure, financial statements, and tax identification number
  • The verification process involves:
    • Comparing this information with that held by regulatory authorities
    • Independently verifying details through physical inspections or other reliable sources

Establishing Identity of Foreign Entities or Bodies


For foreign entities or bodies, accountable persons require:

  • Detailed information about their incorporation status, registered place of business, and management structure
  • The verification process involves confirming this information with:
    • Regulatory authorities in the entity’s country of origin or registration

Conclusion


The review of due diligence measures is aimed at ensuring that financial institutions have robust systems in place to prevent money laundering and terrorism financing. Regulators will closely monitor the implementation of these measures to ensure compliance with anti-money laundering regulations.