Section 1: INTRODUCTION The Anti- Money Laundering Act, 2013 (the "AMLA") lists Non-Government Organisations (NGOs)1 as accountable persons and therefore are

subject to the requirements under the AML/CFT legislation and regulations. This guidance is issued by the Financial Intelligence Authority (FIA) pursuant to S. 20(d) of the Anti-Money Laundering Act, The purpose of this Guidance is to provide industry specific guidance for NGO'S on their legal obligations on measures to deter and detect money laundering and the financing of terrorism activities. It provides clarity and interpretation of the issues arising out of the AMLA and the AML regulations. This guidance explains the most common situations under the specific laws and related regulations which impose AML/CFT requirements. It is provided as general information for 1 For the sake of convenience, the abbreviations NGOs and NPO will be used throughout the text of this Guidance to indicate the terms "nongovernment organisations" and "non-profit organisations", respectively. guidance. It is not legal advice, and is not intended to replace the Acts and Regulations. NPOs by their nature are vulnerable to crimes. An NPO may be set up as a sham business to bring illegally obtained funds into the financial system. Legitimately obtained funds can be channeled through NPOs and misused by terrorists to finance terrorist activities. For example, an NPO may organise fundraising activities where the contributors to the fundraising activities believe that the funds will go to relief efforts abroad, but, some or all the funds end up being transferred to a terrorist group. In light of the vulnerability of NPOs to ML/FT, Recommendation 8 of the FATF 40 Recommendations requires countries to review the adequacy of their laws and regulations that relate to NPOs identified as being at risk to terrorist financing abuse, and those countries should apply focused and proportionate measures in line with a risk based approach. In taking a risk based approach, countries should use all relevant sources of information in order to identify features and types of NPOs, which by virtue of their activities or characteristics are likely to be at risk for terrorist abuse. The objective of this Recommendation is to ensure that NPOs are not misused by terrorists or terrorist organisations to: i. Pose as legitimate entities; ii. Exploit legitimate entities as conduits for terrorist financing, including for the purpose of escaping asset freezing measures; To conceal or obscure the clandestine diversion of funds intended for legitimate purposes but diverted for terrorist purposes. With the aim of complying with Recommendation 8, the Parliament of Uganda enacted the Non-Government Organisation Act, 2016. It was made to provide for the registration of NGOs, the establishment and maintenance of a register of NGOs, the obligations of NGOs and for other related matters.