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Money Laundering is the process of converting property derived from criminal sources into seemingly legitimate sources. Anti Money Laundering (AML) Compliance Risks stem from the global fight against organized crime, predicate offenses, and their impact on the global economic system. Anti Money Laundering also encompasses sanctions and terrorism financing as these have been known as beneficiaries or to catalyze money laundering as a whole. As a global and hence national priority, AML risk must be prioritized by all Accountable Persons irrespective of the size of the organization.
Our Anti Money Laundering Practitioners Team has over 15 years of experience, Designing and Setup of AML Programs and frameworks, Monitoring/Investigating breaches, AML Technology, AML Auditing, and AML Training
Since 1825, Trusts have been used to manage risk. In the broader sense of the term, relating to trust law, a trust is a centuries-old legal arrangement whereby one party conveys legal possession and title of certain property to a second party, called a trustee. While that trustee has ownership, s/he cannot use the property for herself but holds it ‘in trust’ for the well-being of a beneficiary. Corporate Trustees have played a key role in Risk Management.
Under the National Payment System framework, a trustee is required for an e-Money issuer, due to the risk of co-mingling of funds and the creation of “unauthorized” e-money.
Our Corporate Trustee team comprises leaders with over 25 years of banking experience, lawyers to draw up the appropriate documentation and understand the mind of the regulator including Operating Manuals, Process flows, and how to set up the appropriate controls as required of a Trustee.
The Uganda Financial Intelligence Authority (FIA) now has the mandate to regulate and control Cryptocurrencies under the AMLA (2020 amendment) by requiring registration with the FIA as VASP, for Money Laundering control purposes.
Our VASP Agent Team has over 5 years of experience understanding, investigating, identifying, and Researching the latest trends and Insights on Blockchain/DLT Technology.
A VASP is defined by the Financial Action Task Force (FATF) as a business that conducts one or more of the following actions on behalf of its clients:
- exchange between virtual assets and fiat currencies;
- exchange between one or more forms of virtual assets
- transfer of virtual assets,
- safekeeping and/or administration or virtual assets or instruments enabling control over virtual assets;
- participating in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset;
This definition encompasses a range of crypto businesses, including exchanges, ATM operators, wallet custodians, and hedge funds. FATF further recommends that VASPs be subject to the same stringent AML/CTF and KYC requirements as traditional financial institutions.