The Invisible Bankers: Uganda's Shadow Enablers
Uganda could be losing more than Shs2 trillion annually to illicit financial flows (IFFs), with trade misinvoicing alone creating a $6.6 billion gap between Uganda's reported trade and its partners' records between 2006 and 2015, according to a report by Global Financial Integrity (GFI). The study, The Enablers Gap: Assessment of the Shadowy Craftsmen of Illicit Wealth, released on September 22, 2026, underscores the role of professionals such as lawyers, accountants, real-estate agents, and trust and company-service providers in moving, hiding, or legitimizing illicit funds. These 'enablers' operate at the intersection of the formal and informal economies, raising urgent questions about regulatory oversight in Uganda's financial-crime enforcement system.
The GFI report, authored by Policy Director Africa Maxwell Kpebesaan Kuu-ire and West Africa Policy Analyst, focuses on Uganda, Kenya, and Ghana, highlighting how each country reflects a distinct facet of Africa's $50 billion annual IFFs. While Uganda's absolute exposure is smaller, the report emphasizes its structural significance. It notes that nearly every major illicit capital movement in the three countries involves professionals who structure transactions, certify accounts, or facilitate property deals. For Uganda, the concern is not just the potential misuse of these roles but the systemic gaps in monitoring and enforcing compliance among these sectors.
Uganda's anti-money-laundering (AML) framework classifies lawyers, accountants, real-estate agents, and trust and company-service providers as 'accountable persons,' requiring them to identify clients, conduct due diligence, and report suspicious transactions. However, the report points to limited suspicious-transaction reporting from these sectors and weaknesses in supervision. This creates a blind spot: enablers who encounter illicit activity may not generate the financial intelligence needed to expose the networks behind it. The report calls for stronger integration between company registries, financial intelligence, tax authorities, and law enforcement to close this gap.
Case studies in the report illustrate the risks. In Uganda v. Serwamba David Musoke & Others (2015), fraud at Equity Bank's Oasis Mall branch saw $1.45 million stolen through forged documents and biometric bypasses. Investigators traced part of the proceeds into land, vehicles, and businesses, involving external accomplices who helped conceal the money. Another case, Uganda v. Kamya Valentino & 3 Others, revealed an accountant at the Embassy of Sweden in Uganda diverting Shs8.4 billion between 2016 and 2019. The funds were funneled into his wife's and father-in-law's accounts, with properties registered under their names to obscure ownership. The case highlights how corporate structures can mask illicit wealth, with the Kamya family using nominees and shell companies to distance themselves from the assets.
The report criticizes Uganda's beneficial ownership registry, managed by the Uganda Registration Services Bureau (URSB), for incomplete or inaccurate data. While the registry requires companies to identify ultimate owners, GFI warns that anonymous entities can still conceal the true beneficiaries. In the Kamya case, the father-in-law was listed as a shareholder, while the real controller remained hidden. This opacity allows enablers to exploit gaps in transparency, undermining efforts to trace illicit proceeds. The report urges stronger verification mechanisms and cross-agency data sharing to ensure the registry reflects actual ownership.
Uganda's Financial Intelligence Authority (FIA) classifies enablers as accountable persons but has not disclosed key metrics on suspicious transaction reports, investigations, or sanctions. The Independent requested data on reports from lawyers, accountants, and others over the past three years, including enforcement actions, but the FIA did not respond. This lack of transparency raises concerns about the effectiveness of Uganda's AML framework. Experts argue that without robust oversight, professionals may inadvertently or deliberately facilitate money laundering, particularly when due diligence and beneficial-ownership checks are weak.
The real estate sector is another focal point. Uganda's property market, with rising prices and rapid development in areas like Buwaate and Bulindo, has drawn scrutiny. GFI notes that the absence of a public beneficial ownership register for real estate makes it difficult to trace the origins of funds used in property transactions. Cash-based systems in rural areas further complicate tracking, creating opportunities for illicit wealth to be disguised as legitimate investments. The report recommends stricter regulation of cash transactions and greater transparency in property dealings.
Public procurement also presents risks. The Public Procurement and Disposal of Public Assets Authority (PPDA) maintains records of bidders and contracts, but it is unclear whether it routinely verifies the beneficial ownership of suppliers. GFI highlights that opaque corporate structures in government contracts can obscure the true controllers of companies accessing public funds. The report calls for enhanced scrutiny of suppliers' ownership and cross-referencing with beneficial ownership records to prevent misuse.
Uganda's use of special-purpose vehicles (SPVs) in public-private partnerships (PPPs) adds complexity. While SPVs are standard for isolating project risks, their multi-jurisdictional structures can obscure ownership. The Bujagali hydropower project and the East African Crude Oil Pipeline (EACOP) exemplify this challenge. Though legitimate, these structures complicate efforts to trace ultimate beneficiaries, raising questions about the effectiveness of Uganda's regulatory framework in monitoring cross-border financial flows.
GFI's recommendations include integrating financial intelligence, tax, and law enforcement data into a centralized platform to improve transparency. It also advocates for pre-emptive risk assessments before major government transactions involving offshore entities. Despite Uganda's removal from the FATF grey list in 2025, the report warns that legislative progress alone does not guarantee enforcement effectiveness. The current supervisory regime for designated non-financial businesses and professions (DNFBPs) remains underdeveloped compared to banks.
The cases documented by GFI reveal how illicit funds can vanish through layers of corporate and personal transactions. The accountability of systems that enable this remains unresolved. As Uganda grapples with these challenges, the need for systemic reforms to close regulatory gaps and enhance transparency becomes increasingly urgent. Without addressing these issues, the country risks continued losses to IFFs and a weakened financial system.
The report underscores the critical role of professionals in Uganda's financial ecosystem and the necessity of robust oversight to prevent their services from being exploited. With the right measures, Uganda can strengthen its AML framework and protect its economy from the corrosive effects of illicit financial flows.
Source Credit: The Independent Uganda, September 29, 2026, The Invisible Bankers
The findings of the GFI report serve as a stark reminder of the vulnerabilities within Uganda's financial infrastructure. As the nation continues to grow, the need for transparency, accountability, and coordinated regulatory efforts becomes more pressing than ever.