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Uganda

Retail_Trading_Status

Gray-Zone Unknown
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Analysis ID
#305
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Archived
Created
2025-06-26 09:18
Workflow Stage
Initial Research

Executive Summary

Retail cryptocurrency trading in Uganda exists in a 'Gray-Zone.' While not explicitly banned, the Bank of Uganda (BoU) does not recognize cryptocurrencies as legal tender and has prohibited licensed entities from facilitating crypto transactions. The High Court upheld this stance in 2023. However, individuals continue to engage in P2P trading, and there are discussions around future regulation, including a regulatory sandbox and potential virtual asset legislation.

Key Pillars

The key regulatory pillars in Uganda's crypto landscape include the Bank of Uganda's (BoU) stance against recognizing cryptocurrencies as legal tender and its prohibition on licensed entities facilitating crypto transactions. The Financial Intelligence Authority (FIA) includes Virtual Asset Service Providers (VASPs) as accountable persons under the Anti-Money Laundering Act, requiring registration, customer due diligence (CDD), and suspicious transaction reporting. There are no explicit licensing or registration requirements for individual crypto traders, but VASPs must register with the FIA.

Landmark Laws

National Payment Systems (NPS) Act, 2020: This act is the basis for the BoU's directive prohibiting licensed entities from facilitating cryptocurrency transactions, including converting cryptocurrencies to mobile money. Issued in April 2022. Anti-Money Laundering Act (amended December 2020): Amended to include Virtual Asset Service Providers (VASPs) as "accountable persons" subject to supervision and monitoring by the FIA, requiring registration, customer due diligence, and reporting of suspicious transactions. Foreign Exchange Act 2004 and the Electronic Transactions Act 2011: These existing laws could potentially be interpreted to cover some aspects of cryptocurrency transactions, but they were not specifically designed for cryptocurrencies.

Considerations

Cryptocurrencies are not recognized as legal tender in Uganda. The Bank of Uganda (BoU) and the Ministry of Finance have issued warnings about the risks associated with cryptocurrency trading. The BoU's directive restricts fiat access by prohibiting licensed payment service providers from facilitating crypto transactions. The Financial Intelligence Authority (FIA) has expressed concerns about low compliance among VASPs. Crypto is treated as a virtual asset but not legally classified as property.

Notes

A High Court ruling in April 2023 (Silver Kayondo v. Bank of Uganda) declared cryptocurrencies illegal under the current National Payment System Act. Despite restrictions, peer-to-peer exchanges and informal trading continue using methods like mobile money and bank transfers. Over Ush2.5 trillion (around $700 million) in crypto transactions reportedly occurred in Uganda in 2024. The BoU has reportedly invited cryptocurrency businesses to participate in its regulatory sandbox. A private member's bill is being considered by the Capital Markets Authority (CMA) to regulate cryptocurrencies as virtual assets.

Detailed Explanation

The retail cryptocurrency trading status in Uganda is a 'Gray-Zone'. While no explicit law bans individuals from buying, selling, or holding cryptocurrencies, the regulatory environment lacks a clear legal framework and is characterized by warnings from regulatory bodies. The Bank of Uganda (BoU) has stated that cryptocurrencies are not recognized as legal tender and has not licensed any institution to facilitate crypto trading. In October 2019, the Ministry of Finance, Planning and Economic Development affirmed this position. In April 2022, the BoU issued a circular under the National Payment Systems (NPS) Act, 2020, directing licensed entities to stop facilitating cryptocurrency transactions, including converting cryptocurrencies to mobile money. This directive was upheld by the High Court in April 2023 in the case of Silver Kayondo v. Bank of Uganda, which declared cryptocurrencies illegal under the current National Payment System Act because they are not recognized as legal tender by the BoU. Justice Ssekaana Musa noted that the current regulatory framework was not designed for cryptocurrencies. Despite these measures, crypto trading continues through peer-to-peer exchanges and informal trading, with Ugandans using mobile money and bank transfers. Uganda's State Minister for Planning, Amos Lugoloobi, reported over Ush2.5 trillion ($700 million) in crypto transactions occurred in Uganda in 2024. The Financial Intelligence Authority (FIA) amended the Anti-Money Laundering Act in December 2020 to include Virtual Asset Service Providers (VASPs) as "accountable persons," requiring registration, customer due diligence (CDD), and reporting suspicious transactions; however, the FIA has expressed concern over low compliance rates. The Capital Markets Authority (CMA) is considering a private member's bill to regulate cryptocurrencies as virtual assets. The BoU has also reportedly invited cryptocurrency businesses to participate in its regulatory sandbox. The existing Foreign Exchange Act 2004 and Electronic Transactions Act 2011 could potentially apply to cryptocurrency transactions, but they were not designed with cryptocurrencies in mind, leading to legal ambiguity. In summary, while not outrightly banned, retail cryptocurrency trading operates in a challenging and uncertain environment.

Summary Points

Uganda: Retail Cryptocurrency Trading Regulatory Status (2025-06-26)

Overall Status: Gray-Zone - No explicit ban on individuals buying, selling, or holding cryptocurrencies, but lacking a clear legal framework and facing warnings from regulatory bodies.

1. Key Regulatory Bodies & Roles:

  • Bank of Uganda (BoU):
    • Central bank; does not recognize cryptocurrencies as legal tender.
    • Has not licensed any institution to sell or facilitate crypto trading.
    • Directed licensed entities under the National Payment Systems Act to desist from facilitating cryptocurrency transactions (including conversion to/from mobile money).
    • Invited cryptocurrency businesses to participate in its regulatory sandbox.
  • Ministry of Finance, Planning and Economic Development:
    • Affirms that the government does not recognize any cryptocurrency as legal tender.
    • Has not licensed any organization to sell or facilitate crypto trading.
  • Financial Intelligence Authority (FIA):
    • Amended the Anti-Money Laundering Act to include Virtual Asset Service Providers (VASPs) as "accountable persons."
    • Supervises and monitors VASPs.
    • Has expressed concerns about low VASP compliance and called for more extensive crypto regulations.
  • Capital Markets Authority (CMA):
    • Potentially considering a private member's bill to regulate cryptocurrencies as virtual assets.

2. Key Legislation & Regulations:

  • National Payment Systems (NPS) Act, 2020:
    • Used by BoU to prohibit licensed entities from facilitating cryptocurrency transactions.
    • High Court ruling (Silver Kayondo v. Bank of Uganda) upheld BoU's directive, stating cryptocurrencies are illegal under this Act because they are not recognized as legal tender.
  • Anti-Money Laundering Act (Amended December 2020):
    • Includes Virtual Asset Service Providers (VASPs) as "accountable persons" subject to FIA supervision.
  • Foreign Exchange Act 2004 & Electronic Transactions Act 2011:
    • Potentially applicable to certain aspects of cryptocurrency transactions, but not specifically designed for them, leading to legal ambiguity.

3. Compliance Requirements for VASPs:

  • Registration with the FIA.
  • Conducting customer due diligence (CDD).
  • Reporting suspicious transactions.

4. Notable Restrictions & Limitations:

  • No Legal Tender Status: Cryptocurrencies are not recognized as legal tender in Uganda.
  • Prohibition on Licensed Entities: Licensed payment service providers are prohibited from facilitating cryptocurrency transactions (converting to/from mobile money, etc.).
  • Lack of Consumer Protection: Individuals trading cryptocurrencies do so at their own risk, without typical consumer protection.
  • High Court Ruling: Cryptocurrencies are illegal under the current National Payment System Act.

5. Recent Developments & Changes:

  • April 2023: High Court ruling (Silver Kayondo v. Bank of Uganda) declared cryptocurrencies illegal under the current National Payment System Act.
  • 2024: Estimated Ush2.5 trillion (around $700 million) in crypto transactions occurred in Uganda.
  • Ongoing: Peer-to-peer exchanges and informal trading continue despite restrictions.
  • Future: Potential for future regulation through:
    • Private member's bill under consideration by the Capital Markets Authority (CMA).
    • BoU's regulatory sandbox participation for cryptocurrency businesses.
    • FIA calling for more extensive crypto regulations.

Full Analysis Report

Report on the Current Status of Retail Cryptocurrency Trading in Uganda

Date: 2025-06-26

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

Retail_Trading_Status: Gray-Zone

Detailed Narrative Explanation:

The status of retail cryptocurrency trading in Uganda is best described as a "Gray-Zone." While there is no explicit law directly banning individual citizens from buying, selling, or holding cryptocurrencies, the regulatory environment is characterized by a lack of clear legal framework, strong warnings from regulatory bodies, and some contradictory stances. This creates a complex and ambiguous situation for retail crypto traders.

The Bank of Uganda (BoU), the country's central bank, has consistently stated that cryptocurrencies are not recognized as legal tender in Uganda. It has not licensed any institution to sell or facilitate the trade in cryptocurrencies. In October 2019, the Ministry of Finance, Planning and Economic Development issued a public statement affirming that the government does not recognize any cryptocurrency as legal tender and has not licensed any organization to sell or facilitate crypto trading. This position essentially means that individuals engaging in cryptocurrency trading do so at their own risk, without any consumer protection typically afforded in regulated financial markets.

Further complicating the matter, the BoU issued a circular in April 2022 directing all licensed entities under the National Payment Systems (NPS) Act, 2020, to desist from facilitating cryptocurrency transactions. This includes a prohibition on converting cryptocurrencies to mobile money and vice versa. A High Court ruling in April 2023 (Silver Kayondo v. Bank of Uganda) upheld the BoU's directive, declaring that cryptocurrencies are illegal under the current National Payment System Act because they are not recognized as legal tender by the BoU and therefore cannot be accepted as a general payment instrument in Uganda. The ruling stated that the current regulatory framework was not designed with cryptocurrencies in mind.

Despite these restrictive measures and warnings, crypto trading itself by individuals is not explicitly banned. Peer-to-peer exchanges and informal trading continue, with Ugandans reportedly able to buy and sell cryptocurrencies using methods like mobile money and bank transfers, although the BoU's directive aims to curb the formal integration of such. Reports indicate a significant volume of crypto transactions occurring in Uganda, suggesting a disconnect between the official stance and on-the-ground activity. For instance, Uganda's State Minister for Planning, Amos Lugoloobi, reportedly announced that over Ush2.5 trillion (around $700 million) in crypto transactions occurred in Uganda in 2024.

There are some indications of potential future regulation. The Financial Intelligence Authority (FIA) amended the Anti-Money Laundering Act in December 2020 to include Virtual Asset Service Providers (VASPs) as "accountable persons" subject to its supervision and monitoring. This implies that VASPs have obligations such as registration with the FIA, conducting customer due diligence (CDD), and reporting suspicious transactions. However, the FIA has expressed concerns about the low compliance rate among VASPs and has called for more extensive crypto regulations. There are also reports of a private member's bill being considered by the Capital Markets Authority (CMA) to regulate cryptocurrencies as virtual assets. The BoU has also reportedly invited cryptocurrency businesses to participate in its regulatory sandbox, which could be a step towards understanding and potentially regulating the sector.

The existing legal framework, such as the Foreign Exchange Act 2004 and the Electronic Transactions Act 2011, could potentially be interpreted to cover certain aspects of cryptocurrency transactions, but these were not designed with cryptocurrencies specifically in mind, leading to legal ambiguity.

In summary, while not outrightly banned for individuals, retail cryptocurrency trading in Uganda operates in a challenging and uncertain environment. The government and central bank do not recognize cryptocurrencies as legal tender, have warned the public about the risks, and have prohibited licensed payment service providers from facilitating crypto transactions. However, the existence of AML/CFT obligations for VASPs and discussions around future regulations suggest an evolving landscape. This lack of a clear, crypto-specific regulatory framework, coupled with restrictive measures and ongoing informal trading, firmly places the status in a "Gray-Zone."

Specific, Relevant Text Excerpts:

  • Bank of Uganda (BoU) & Ministry of Finance:

    • "This is to advise that Bank of Uganda has not licensed any institution to sell cryptocurrencies or to facilitate the trade in crypto-currencies. This is in line with the official government position as communicated by the Ministry of Finance, Planning and Economic Development in October 2019." (Bank of Uganda Circular, April 2022, as reported by Nile Post).
    • "The government of Uganda does not recognize any crypto-currency as legal tender in Uganda. The government of Uganda has not licensed any organization in Uganda to sell crypto-currencies or to facilitate the trade in crypto-currencies and so these organizations are not regulated by the Government or any of its agencies." (Ministry of Finance, Planning and Economic Development, October 2019, as reported by Nile Post and Nabasa & Company Advocates).
    • "The Central Bank has consequently warned all licenced entities under the National Payment Systems Act, 2020 to desist from facilitating cryptocurrency transactions." (Bank of Uganda, April 2022, as reported by Nile Post).
  • High Court Ruling (Silver Kayondo v. Bank of Uganda, 2023):

    • "On 24 April 2023, a landmark ruling was delivered by Hon. Justice Ssekaana Musa, a High Court Judge in Uganda, which declared cryptocurrencies illegal in the country. This ruling has far-reaching implications for the use of cryptocurrencies in Uganda, as it implies that they cannot be used as a legal means of payment." (Kakuru & Co. Advocates).
    • "Much as cryptocurrencies are digital assets, they are illegal under the current National Payment System because they are not recognized as legal tender/currency by the BOU and as such, they are not accepted as a general payment instrument in Uganda." (Summary of Justice Ssekaana Musa's ruling by Kakuru & Co. Advocates).
    • "...The current regulatory framework was not designed with cryptocurrencies in mind..." (Justice Ssekaana Musa, as quoted by CIPESA).
  • Financial Intelligence Authority (FIA) & AML/CFT:

    • "In December 2020, the Financial Intelligence Authority (FIA) published a letter amending the Anti-Money Laundering Act to include virtual asset service providers (VASPs) among the list of “accountable persons” subject to supervision and monitoring by the FIA." (Nabasa & Company Advocates & Freeman Law).
    • "As accountable persons, VSAPs (who in our view include cryptocurrency service providers) have obligations under the AML Act including, registration with the FIA, conducting customer due-diligence and reporting suspicious transactions among others." (AF Mpanga Advocates).
    • "Sydney Asubo, executive director of the FIA, made the call during a meeting with stakeholders over the weekend. According to Asubo, the need for crypto regulations in Uganda has become of paramount importance given the noncompliance of industry participants to the agency's licensing requirements." (Cointelegraph, reporting on FIA's call for regulations).
  • Ongoing Activity and Potential Future Regulation:

    • "Despite these restrictions, crypto trading is not explicitly banned. Peer-to-peer exchanges and informal trading continue, with Ugandans able to buy and sell cryptocurrencies using local payment methods such as mobile money and bank transfers." (Monitor).
    • "In January this year, ​​Uganda's State Minister for Planning Amos Lugoloobi announced that over Ush2.5 trillion ($700 million) in crypto transactions occurred in Uganda in 2024, highlighting a rapidly growing but unregulated market." (ZAWYA).
    • "Bank of Uganda (BoU) is finally open to the idea of cryptocurrency businesses participating in its Regulatory Sandbox." (CIO Africa).
    • “There's a private member's bill under consideration by the Capital Markets Authority to regulate cryptocurrencies as virtual assets,” (Larry Cooke, Binance Africa Legal Counsel, as reported by New Vision).

Direct, Accessible URL Links to Specific Sources:

Web Sources (20)

Sources discovered via web search grounding

Search queries used (9)
  • current status of retail cryptocurrency trading in Uganda 2024 2025
  • Uganda cryptocurrency regulation Bank of Uganda
  • Uganda Capital Markets Authority cryptocurrency policy
  • Uganda retail crypto trading laws and regulations
  • KYC/AML requirements for crypto platforms in Uganda
  • Uganda government statements on cryptocurrency trading
  • Is cryptocurrency trading legal for individuals in Uganda?
  • Bank of Uganda warnings on cryptocurrency
  • Financial Intelligence Authority Uganda cryptocurrency guidelines

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