After the Russian invasion of Ukraine and the wide-reaching sanctions which ensued, many Western financial institutions began to de-risk Russian clients. Dealing with Russian clients, in many cases, has become expensive from a compliance point of view and toxic from the reputational side.

However, the de-risking of unsanctioned Russian individuals may have a significant impact on the fight against financial crime by potentially causing:

In February 2020, Uganda made a high-level political commitment to work with the Financial Action Task Force (FATF) and Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) to strengthen the effectiveness of its anti-money laundering (AML) regime. Among other commitments, Uganda undertook to demonstrate that law enforcement agencies and judicial authorities apply the money laundering offence consistent with the identified risks.