💡 Key Takeaway: Being part of the same corporate family creates efficiencies, but compliance responsibilities remain in place. Group-wide reliance works best when supported by oversight AML controls
📖 Legal Basis: Section 6(21) of the Anti-Money Laundering Act, Cap. 118
However, group membership alone is not enough.
⚠️ Lenders must assess and mitigate any heightened risks arising from the jurisdiction or country in which the affiliated entity operates.
If your gatekeepers aren't compliant, neither are you.
📖 Legal Basis: Section 6(20)(c) of the Anti-Money Laundering Act, Cap. 118 and the Data Protection and Privacy Act, Cap. 97.
📂 Customer records must be securely retained for 10 years, while the disposal and deletion of personal data must comply with Uganda's data protection and privacy laws.
⚠️ Key Takeaway: Ensure a provider meets both AML compliance standards and data privacy obligations.
🚀 Investment Advisory Series – Day 1
❓ Did you know that third-party KYC providers are legally required to provide customer verification records without delay?
⚖️ Why does this matter?
Delays in accessing customer records can expose lenders to regulatory risk and undermine AML compliance obligations.
✅ Key Takeaway: When partnering with a KYC provider, speed is not merely a service standard—it is a legal requirement.
Investment Advisory Series – Day 1
Can You Outsource Your KYC?
✅ The answer is YES.
Uganda's regulatory framework allows Supervised Financial Institutions (SFIs) to rely on third-party providers to conduct Customer Due Diligence (CDD).
⚠️ However, even where a third party conducts the KYC process, the lender retains ultimate responsibility for ensuring customer verification at all times.
Key Takeaway: Outsourcing KYC does not mean outsourcing accountability.
Buwembo & Co. Advocates is pleased to introduce the Investment Advisory Series, a thought leadership initiative by our Investment Advisory Department that will run for the next sixty days.
Join us as we explore the legal frameworks driving innovation and safeguarding consumers.
As Uganda’s digital economy continues to expand, digital lending platforms and technology-driven financial services are reshaping access to credit and financial inclusion.
@EyeZack13@thomsonreuters@htuhairwe Congratulations Counsel Isaac. This is such a significant achievement, being published in the Computer and Telecommunications Law Review is no small feat. Your insights on regulating social media in Uganda are timely and much needed.
Humbled to share that my article, “The Regulation of Social Media and Its Effects on Mainstream Media: Adequacy of the Uganda Communications Act”, will appear in the next issue (6th) of the Computer & Telecommunications Law Review (CTLR) by @thomsonreuters !
The program brings together global experts from USA, Kenya, Botswana, & Uganda to enhance courtroom advocacy through practical, skills-based training.
📍 Commercial Court, Kampala 📅 28 July – 1 August 2025
#LegalTraining#TrialAdvocacy#ProfessionalDevelopment#UgandaLawSociety
We are proud to have Counsel Catherine Katushabe representing us at the 2025 Trial Advocacy Skills Training organized by @UgandaLawSoc in partnership with Justice Advocacy Uganda.