Appraisal of Anti-Money Laundering Legislation as A Control Against Terrorism Financing in Uganda
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Date
2026
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Abstract
This study critically appraises the effectiveness of Uganda’s Anti-Money Laundering legislation as a mechanism for controlling terrorism financing. Despite the enactment of the Anti-Money Laundering Act Cap 118 and the Anti-Terrorism Act Cap 120, Uganda continues to experience challenges associated with illicit financial flows that can be exploited by terrorist organizations such as the Allied Democratic Forces (ADF). Using a doctrinal research methodology, the study analyses the theoretical foundations of money laundering, international and domestic legal frameworks, and the institutional roles of enforcement bodies including the Financial Intelligence Authority, Bank of Uganda and Uganda Police Force. In addition, the study incorporates empirical qualitative methods, where primary data was collected through questionnaires administered to selected stakeholders, including officials from the Bank of Uganda, Uganda Police Force, commercial banks, forex bureaus, and mobile money operators, to complement the doctrinal analysis. The findings reveal that although Uganda has adopted global standards such as the FATF Recommendations, the legal regime remains fragmented, with overlapping mandates, limited prosecutions, low inter-agency coordination, and significant compliance gaps among accountable entities. Empirical illustrations highlight weaknesses in beneficial ownership transparency, cross-border supervision, and recovery of proceeds of crime, which undermine effective disruption of terrorist financing networks. The study recommends harmonization of AML/CTF legal frameworks, enhanced institutional capacity, improved intelligence-sharing mechanisms, and greater alignment with regional best practices in East Africa. Strengthening these reforms will promote national security, protect the integrity of Uganda’s financial system, and improve the country’s global AML/CTF compliance standing.