Uganda's off the FATF’s greylist. What now?

Uganda’s removal from the Financial Action Task Force (FATF)’s greylist is a case study in the importance of national anti-money laundering (AML) frameworks, and of the economic exile that ensues if they’re faulty.

But Uganda is just one country of many that has been penalised and subsequently exonerated by the FATF in recent years. So, what does it mean to be blacklisted by the FATF? How do countries get delisted? And what hopes do previous offenders have of rebuilding their reputation in the global economy?

What is the FATF?

The FATF is an independent intergovernmental body that leads global action to tackle money laundering, terrorist, and proliferation financing – much of which is now conducted through cryptocurrencies. Part of the FATF’s work is to identify offending jurisdictions and set down plans for them to combat these issues.

The FATF’s public listings of countries with weak anti-money laundering (AML) and Countering the Financing of Terrorism (CFT) regimes is sometimes referred to as the grey and blacklists. The gradations reflect the extent to which the offending country is a concern to international security.

Thus far the FATF’s name-and-shame strategy seems to be working. As of February 2025, the FATF has reviewed 139 countries and publicly identified 114 of them as of concern. Of these, 86 have since made the necessary reforms to address their AML/CFT weaknesses and have been removed from the list.

Uganda, a low-income, landlocked agricultural country in East Africa, is an exemplar of this trajectory. So, how did Uganda get into the FATF’s bad books? And, more importantly, how did it find a way out?

The grey and black lists

With a fast-growing (albeit small) economy worth around $73 billion, Uganda has been off the FATF’s greylist for over two years. Also known as the Pearl of Africa, Uganda was set loose in February 2024, having wound up on the financial naughty step in February 2020 for deficiencies in its national AML framework, including inadequate measures to tackle terrorist financing.

Uganda is among a number of countries to have been branded a risk by the FATF. In Africa, the likes of Angola, Cameroon, Côte d'Ivoire, Kenya, the Democratic Republic of Congo, Namibia, and South Sudan sit on the greylist at the time of writing. This essentially means that these countries are actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.

The FATF says that when it places a jurisdiction on the greylist, “it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring.”

A far more serious indictment is landing on the blacklist, where three jurisdictions sit today: Iran, Myanmar, and the Democratic People's Republic of Korea. This list comprises countries with seriously deficient AML and CFT measures. For all those identified as high-risk, the FATF calls on all members and urges all jurisdictions “to apply enhanced due diligence, and in the most serious cases, countries are called upon to apply countermeasures to protect the international financial system…”

These countries will likely remain on the blacklist until willingness to cooperate with the FATF is demonstrated.

The Pearl of Africa: Economy, money laundering and terrorism

Uganda, for its part, is a classic case of penalisation and amelioration by the FATF. In early 2020 the Pearl of Africa got into hot water for leaning on inadequate regulatory and enforcement measures to track, prevent, and prosecute the financing of terrorist organisations.

Also alleged by the FATF was a severe lack of rules to identify and disclose the true "beneficial owners" of corporate entities, making it difficult to trace illicit money and combat corporate money laundering. And, even if illicit money could be traced, the FATF argued that the capacity within regulatory institutions to monitor, identify, and penalise financial institutions failing to adhere to international AML/CFT compliance standards, was too weak.

In landing on the greylist, Uganda's financial system was opened to increased international scrutiny, which raised transaction costs and caused delays for its businesses and financial institutions.

However, after four years of significant regulatory reform — including enhancing beneficial ownership transparency, strengthening legal frameworks, and improving financial surveillance — Uganda was jettisoned from the FATF’s greylist in February 2024. This act recognised the country’s concerted efforts to satisfy the FATF’s proposed action plan.

The African Century

Having been off the greylist for over two years, Uganda’s economy is now in from the cold. Though it is still small, it is growing rapidly — having been ranked the second fastest-growing economy in Sub-Saharan Africa by the International Monetary Fund (IMF).

In 2026, the Uganda Investment Authority estimates that Uganda’s economy will expand by up to 7%, buoyed by ramped-up oil production, greater political stability, and the normalisation of supply chains. This is a level of growth Western countries could only dream of today. Other prospects for Uganda include its powerful agricultural industry; rising tourism volumes; and a growing telecommunications sector.

What’s more, unlike Europe, demography is on Africa’s side. The United Nations (UN) projects that by 2050, Africa's population will reach close to 2.5 billion — more than 25% of the world’s population. This will give the continent, and Uganda, long-term momentum for economic scale, workforce expansion, innovation, and cultural vitality.

Where there’s contrition there’s forgiveness

The journey of Uganda from 2020 to 2024 is not unique. Many countries have gone through a similar process.

Having greylisted then delisted Uganda in the space of four years, the FATF not only underlined its own effectiveness in leading global action against money laundering, terrorist and proliferation financing — it proved the entire process can be conducive to a country’s long-term economic prosperity.

As the FATF continues to work with an arm-long list of greylisters, those ejected from it work to rebuild.