Global Financial Integrity

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Unmasking The Shadows: The Real Estate Sector Fueling Money Laundering in Uganda

It’s estimated value in 2025 is more than  US $356bn (Statista Uganda) with estimated annual growth of 6.95 percent from 2025 to 2029. Uganda’s real estate sector also presents some money laundering risks, despite being governed by several laws and principles.  Uganda has diverse land tenure systems that include Customary, Leasehold, Freehold, and Mailo. These systems govern how land can be acquired, owned, utilized, and disposed of in the country.

The real estate regulatory framework in Uganda is governed by several laws and principles. Compliance with these laws is crucial for anyone looking to buy, sell, or develop real estate in Uganda. Likewise, Uganda has a comprehensive anti-corruption institutional and regulatory framework aimed at combating corruption. These initiatives reflect Uganda’s commitment to combating corruption across various sectors and institutions.

Uganda has a legislative framework for anti-money laundering, governed by the Anti-Money Laundering Act of 2013, which aims to prohibit and prevent money laundering and establish the Financial Intelligence Authority.

In Uganda, land ownership interest is classified into four tenure systems; Free hold, Customary, private Mailo land and leasehold. These are recognized by Uganda’s 1998 Land Act that grants rights to property for  various occupancy arrangements on land. The ideal land transaction process in Uganda involves several key steps to ensure a legal and secure purchase.

The Uganda Registration Service Bureau is mandated to register all business in Uganda but currently, there is no publicly accessible register of Real Estates Beneficial Owners.

The enablers of IFFs in the Real estate’s sector include: Property Brokers (including lawyers); Facility Managers; Foreign Investors; Government / Public Workers and Politically Exposed Persons; Security Personnel; Financial Institutions (Forex Bureaus, Mobile Money Agents, Crypto currency, Banks); Corporate Bodies; and others to include churches and NGO.

Despite some existing challenges Uganda is implementing many measures to curb money laundering that include: amendment of the company’s act to create provisions for Beneficial Ownership Transparency; joining the Extractive Industry Transparency Initiative (EITI) to improve company transparency especially among mining and extractives companies; creation of the land information system under MLHUD to enhance transparency in lands sector; amendments to the Leadership code and institution of the leadership code tribunal to enhance declaration of assets by elected leaders; synchronizing national data with the National Identification System for seamless access to information by public authorities such as URA, Banking Institutions, Security Agencies and Immigration; domesticating a law on automatic exchange of information- the automatic exchange of information Act 2023; strengthening implementation of the AMLA causing more compliance among target bodies and agencies.

The study has provided the following recommendations:

  • Enhance transparency and access to information in land and real estate transactions.
  • Support relevant authorities in Uganda to implement their mandate
  • Promote compliance in financial systems
  • Enhance state party coordination in information sharing and mutual legal assistance
  • Enact and implement strong regulatory framework including regulating cash based transactions in real estates