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Financial Sanctions Enforcement in Uganda: A Comprehensive Overview

Uganda’s financial sanctions regime is designed to implement and enforce United Nations Security Council (UNSC) sanctions, as well as maintain an autonomous system of administrative sanctions. As a member of the United Nations, Uganda is mandated to comply with all UN Charter obligations and sanctions conferred upon it by the UNSC.

Implementation of Sanctions

Uganda implements both UN sanctions and its own autonomous sanctions regime. The latter applies to accountable persons who are required to effectuate the country’s anti-money laundering machinery. Uganda has also seized assets from entities subject to international sanctions, such as in 2011 when the government took control of a 69 percent shareholding in Uganda Telecom from Lap Green, a subsidiary of a Libyan-owned company.

Sanctions Lists and Enforcement

The Ugandan Financial Intelligence Authority (FIA) is responsible for applying sanctions lists, including the Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals (SDN) List and UNSC Resolutions 1267 and 1373. However, there are no publicly available lists of sanctioned individuals or entities.

Licensing and Authorization System

Uganda has a licensing and authorization system in place, regulated by various government entities and ministries. These systems govern the activities of financial institutions, among others.

Enforcement and Recourse

While Uganda has laws in place to implement sanctions, there are currently no penalties or recourse for enforcement against Ugandan persons or entities that breach sanctions.

Key Government Entities Involved

  • Ministry of Foreign Affairs: responsible for implementing sanctions and ensuring national security
  • Financial Intelligence Authority: involved in the enforcement process

Useful Contacts

For those seeking more information on financial sanctions enforcement in Uganda, the following contacts may be useful:

  • Ministry of Foreign Affairs: P. O Box 7048, 2A- B Sir Apollo Kaggwa Road, Kampala, Uganda; Tel: +256 414 345 661; Email: info@mofa.go.ug
  • Financial Intelligence Authority: 4th Floor, Wing B, Rwenzori Towers, Kampala, Uganda; Tel: +256 417 892 600; Email: info@fia.go.ug

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