Uganda

Alongside the conversion ban, a narrower registration perimeter already exists for AML purposes. The Financial Intelligence Authority requires virtual asset service providers operating in Uganda to register under the 2020 amendment to the Anti-Money Laundering Act 2013 (CLM-UG-001). This claim's evidentiary basis shifted this cycle: the primary statutory text on the Uganda Legal Information Institute's site returned an HTTP 403 and was never retrieved, so the claim was re-anchored to the FIA's own Virtual Assets Working Document, a first-party regulator source, with confidence stepped down from Confirmed to Probable to reflect that the underlying primary-law citation itself remains unverified even though the substance of the requirement is independently corroborated.

The more forward-looking development is the Bank of Uganda Governor's 25 November 2025 keynote announcing a forthcoming six-pillar regulatory framework covering licensing and fit-and-proper standards, client-asset protection, AML/CFT compliance, cybersecurity, market integrity and transparency (CLM-UG-003). No draft legislation accompanied the speech. The Governor also confirmed directly that Uganda has licensed no virtual asset service provider to date, explicitly contrasting this with Kenya's Virtual Asset Service Providers Act, whose implementation began 4 November 2025 (CLM-UG-004). Read together, these two claims establish that the announcement is a statement of regulatory intent and comparative positioning rather than a change to Uganda's current legal architecture.

Outlook

The determinative question for this module going forward is whether and when a draft bill or statutory instrument gives the six-pillar announcement legal force. Until that happens, the operative baseline for any entity considering crypto business activity in Uganda remains the narrow AML-only FIA registration requirement and the judicially-confirmed prohibition on crypto-to-mobile-money conversion -- neither of which constitutes a general licensing regime for virtual asset business. A further open item is whether the primary AML Act text can be retrieved directly in a future cycle to fully retire reliance on the FIA working document as the sole current anchor for the registration requirement, and whether the Kayondo judgment's full text can be parsed beyond the secondary summary currently corroborating it.

The only classification-adjacent signal in this cycle is thin. Secondary industry commentary suggests that the Capital Markets Authority's existing securities mandate could, in principle, extend to digital assets that function like securities -- so-called security tokens (CLM-UG-006). This is not formalised in Ugandan statute, and no CMA guidance, statement, or enforcement action was located to substantiate it; the claim rests entirely on a single T4 secondary source and should be read as an open possibility raised by outside commentators rather than a regulator position.

Outlook

This module remains structurally stable in its thinness: with no primary-source movement this cycle beyond the keynote's silence on classification, the module's trajectory is properly assessed as no_change. The item to monitor is whether any future six-pillar draft legislation introduces a formal asset-type taxonomy, and separately, whether the Capital Markets Authority ever issues a public statement addressing its jurisdiction over security-like tokens -- either development would move this module from an unregulated gap toward a resolved classification regime.

Beyond disclosure, the announced six-pillar framework's second pillar would introduce binding obligations that do not exist today: requiring virtual-asset providers to segregate client assets, maintain adequate capital, and refrain from using customer funds for proprietary trading (CLM-UG-008). As with the framework's other pillars, this is a proposed measure described in a keynote speech, not an enacted rule, and its regulatory_stage has deliberately been left unset in this record rather than being forced into a stage designation that would overstate its current legal status.

Outlook

The gap between an actively reiterated risk-warning posture and a still-unenacted custody and capital-adequacy regime is the defining feature of this module. Consumers currently have no statutory entitlement to asset segregation or capital protections from any Ugandan virtual-asset provider; they have only the Bank of Uganda's repeated caution that they act at their own risk. The item to watch is whether pillar two of the six-pillar framework survives into eventual draft legislation in the form described, and whether any interim guidance from BOU addresses custody practices before formal enactment.

A related and equally thin finding is that the URA has not enacted any formal crypto-specific reporting obligation, notwithstanding commentator concern that anonymous crypto transactions could erode the tax base over time (CLM-UG-010). This claim, too, is sourced only to secondary industry commentary rather than any URA statement or regulatory action.

Outlook

Tax treatment is the thinnest-evidenced module in this cycle's Uganda record, consistent with a pattern observed across the wider crypto monitor estate where tax modules tend to lag other regulatory domains in primary-source availability. The immediate research priority is retrieving the primary Income Tax Act text directly, since the current assessment cannot be verified against the actual statute this cycle. Beyond that, the item to watch is whether the URA issues any crypto-specific ruling, practice note, or reporting requirement -- until it does, taxpayers and providers are left inferring treatment from general disposal-of-assets provisions rather than dedicated guidance.

The more forward-looking item is the Governor's signal, in the same November 2025 keynote that announced the six-pillar framework, that its AML/CFT pillar will incorporate the FATF Travel Rule for cross-border virtual-asset flows (CLM-UG-011). Like the framework's other pillars, this is a stated policy intention rather than an enacted requirement, and no implementation timeline was given. This claim also overlaps with financial-integrity's subscribed AML/CFT surface, where any substantive Travel Rule implementation analysis is more properly routed.

Outlook

The module's trajectory is one to watch rather than one that has changed this cycle: the only currently in-force cross-border-relevant restriction remains the narrow mobile-money conversion ban, while the more comprehensive Travel Rule commitment exists only as an announced intention. The key development to track is whether draft six-pillar legislation formalises Travel Rule compliance obligations for cross-border virtual-asset transfers, and whether the Foreign Exchange Act's general application to crypto dealing is ever clarified by a specific regulatory instrument rather than left to inference.