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14 charged with insurance fraud in Ogemaw County



OGEMAW COUNTY – A joint investigation conducted by the Michigan Department of Insurance and Financial Services (DIFS) and the Ogemaw County Sheriff’s Office has led to insurance fraud and identity theft charges against 14 individuals for allegedly submitting nearly $3 million in false insurance claims.

The charges relate to an alleged scheme to defraud AFLAC where the accused individuals submitted fake claims of injury to AFLAC indicating that they had received treatment at the Ogemaw Chiropractic Clinic. Nearly $3 million in false claims were paid out by AFLAC for treatments that never occurred before the insurer filed an insurance fraud complaint with DIFS. In a joint investigation with the Ogemaw County Sheriff’s Office, the DIFS Fraud Investigation Unit (FIU) found sufficient evidence for the Ogemaw County Prosecutor’s Office to issue charges against the 14 individuals listed below. The investigation is ongoing and additional charges may be filed in the future.

“This case began because someone suspected foul play and filed a complaint with DIFS, and I am proud of the work being done to put an end to this scheme,” said DIFS Director Anita Fox. “These fraudulent claims make insurance more expensive for all of us, and I ask all Michiganders to support these efforts by reporting suspected insurance fraud online at or by calling 877-999-6442.”

The individuals charged are:

  • Katie Mae Quigley, 40, of West Branch;
  • Anthony Lee McArthur, 36, of Prescott;
  • Richard Lee McArthur, 38, of West Branch;
  • Christina Marie Tanner, 51, of Pinconning;
  • Jeffrey Scott Kimball, 48, of Standish;
  • Stephanie Marie Witte-Mason, 37, of Alger;
  • Carol Christine Smith, 49, of Rose City;
  • Tina Marie Friemark, 50, of West Branch;
  • Amanda Nichole Hebert, 28, of Rose City;
  • Samantha Marie Petty, 45, of West Branch;
  • Melissa Marie Spencer, 39, of West Branch;
  • Ashley Marie Ehinger, 30, of West Branch;
  • Patricia Ann Hebert, 50, of Rose City
  • Julie Marie Peter, 44, of West Branch.

All 14 individuals were charged with one count of Insurance – Fraudulent Acts, a felony that carries a maximum penalty of four years in prison, a $50,000 fine, and the payment of restitution. As a result of the investigation, two defendants, Friemark and Ehinger, were also each charged with two counts of Identity Theft, a felony that also carries a maximum penalty of four years in prison, a $50,000 fine, and the payment of restitution for each count. All 14 individuals were arraigned in 34th Circuit Court in Ogemaw County and are pending initial hearings in front of Judge Richard Noble.

The DIFS Fraud Investigation Unit investigates criminal and fraudulent activity related to the insurance and financial markets and works with the Attorney General and other law enforcement to prosecute these crimes. Suspected insurance fraud can be reported to DIFS safely, easily and, in most cases, anonymously by calling 877-999-6442or online by visiting DIFS’ website. 

The mission of the Michigan Department of Insurance and Financial Services is to ensure access to safe and secure insurance and financial services fundamental for the opportunity, security, and success of Michigan residents, while fostering economic growth and sustainability in both industries. In addition, the Department provides consumer protection, outreach, and financial literacy and education services to Michigan residents. For more information, visit or follow the Department on FacebookTwitter, or LinkedIn.

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Latest updates: Police arrest Karamjit Bains, brother of former MLA Simarjeet Bains from Ludhiana




THE TIMES OF INDIA | Jul 02, 2022, 16:29:20 IST

Daily City News Updates

Police arrested Karamjit Bains, brother of former MLA Simarjeet Bains from Ludhiana. Simarjeet along with his 6 brothers had been booked in an alleged rape case in July, 2021. Stay with us for all live updates from across India.Read Less

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F.B.I. Sees ‘Massive Fraud’ in Groups’ Food Programs for Needy Children




MINNEAPOLIS — Last year, with the federal government making available huge new sums of money for programs to feed needy children during the pandemic, a nonprofit organization called Advance Youth Athletic Development set up what it described as an enormous child care operation in northeast Minneapolis that could prepare 5,000 dinners each weeknight.

Based on the group’s claims, the State of Minnesota channeled $3.2 million of the federal food aid to the program.

But on a subzero morning in January, the F.B.I. carried out a series of predawn raids around the region. It revealed a sprawling investigation into Advance Youth Athletic Development and other groups like it — and the much larger nonprofit organization, Feeding Our Future, that was responsible for ensuring that the money provided to the smaller groups was spent properly.

In court filings, the F.B.I. said it had discovered a “massive fraud scheme” among groups that Feeding Our Future was supposed to oversee, saying they siphoned off tens of millions of dollars by charging taxpayers for nonexistent meals.

In affidavits filed in federal court, the Justice Department said it was investigating at least 15 different feeding operations. Together, the F.B.I. said, these groups — all of which were supposed to be overseen by Feeding Our Future — had received more than $65 million from federal food programs during the coronavirus pandemic.

“Almost none of this money was used to feed children,” the government wrote in one filing. “Instead, conspirators misappropriated the money and used it to purchase real estate, cars and other items.”

When a reporter recently visited the address listed for Advance Youth Athletic Development, there was no sign of a kitchen or a large child care facility. It was a second-story apartment.

“No. No. No,” said Lul Mohamoud, a neighbor in the apartment across the hall, when asked if she had ever seen 5,000 children there. “I have never seen any kids going in there.”

No one has yet been charged in the case, and the leaders of Feeding Our Future, Advance Youth Athletic Development and other nonprofit groups have denied wrongdoing.

But the case has highlighted how the government’s reliance on nonprofits to help carry out an array of programs can increase vulnerability to fraud — a problem that only increased over the past several years, as Washington pumped trillions of dollars into pandemic aid packages.

That aid has focused new attention on the role of nonprofits in particular in acting as conduits and overseers of federal money that flows through them via the states and then to smaller organizations that carry out programs. States and the federal government count on groups like Feeding Our Future to guard against corruption — even as the system incentivizes the organizations to push more money out the door by giving them a cut of it.

In his State of the Union address last week, President Biden said that “billions” in pandemic aid had been stolen, and that he would soon name a chief prosecutor for pandemic fraud.

In Minnesota, state regulators said that even after they grew suspicious of Feeding Our Future, they had been constrained by the courts from stopping the organization. In fact, the state paid the group more than $197 million after the first suspicions were raised.

“The scale of this, and the rapidity of it, is astonishing,” said State Senator Roger C. Chamberlain, a Minnesota Republican whose committee oversees the food programs. He said his goal was to understand “why this system failed and collapsed completely. Because it certainly did.”

In all, more than 200 investigators from the F.B.I. and other agencies raided 15 homes and offices around the Twin Cities.

The Minnesota case involves two multibillion-dollar federal food-aid programs, both funded by the Agriculture Department but administered by states. One pays for meals at preschools, emergency shelters and aftercare centers. The other pays for meals at summer activities.

In the 1970s, Congress created a role in both programs for nonprofits called sponsors, so that giant state bureaucracies and tiny day care centers did not have to talk to one another directly.

In theory, the nonprofit groups that fill the sponsor role make sure that feeding sites follow the rules, then hand out federal money to those that do.

The watchdogs can keep as an “administrative fee” up to 15 percent of the funds they pass along. Critics say that creates a perverse incentive: a reason for the watchdog not to bark. The structure, they say, rewards sponsors that pursue bigger networks and larger checks instead of those who crack down on fraud — a problem that has been evident for decades.

“Since the sponsor is essentially the internal control for this program, any disreputable sponsor could abuse the program with little or no chance of being detected,” the Agriculture Department’s inspector general wrote in 1998, after an investigation called Operation Kiddie Care found “fraud on a grand scale” in one of these programs. “In fact, the design of the program may encourage program abuse.”

The Agriculture Department declined a request to interview an official about the case. Instead, the department issued a statement saying that “it takes fraud and the protection of taxpayer dollars very seriously.”

Since the F.B.I. raids, news coverage by The Star-Tribune and Sahan Journal, a local nonprofit media outlet, has revealed that some of the operators of Feeding Our Future sites had criminal records, and that a former top aide to Mayor Jacob Frey of Minneapolis, a Democrat, was among those under investigation. The aide has denied wrongdoing.

Minnesota first approved Feeding Our Future as a sponsor in 2018. In its first years, the group oversaw only a few feeding sites — and, at times, seemed to struggle with overseeing itself.

In February 2020, for instance, the I.R.S. revoked the group’s nonprofit status after it failed to file an annual report for three years. (After this story was published, the I.R.S., which had earlier listed the group’s status as revoked, updated its website to reflect that it had reinstated Feeding Our Future’s tax-exempt status as of December.)

In other filings, Feeding Our Future said it had a three-member board to provide outside oversight of its finances. But the man listed as the board’s president from 2018 to 2020, Ben Stayberg, a bartender and electrician, said he had been tricked into taking the job and had “absolutely nothing” to do with overseeing the organization.

“I had a friend, she was like, ‘Will you just sign, put your name on there?’” he said in an interview. “I was like, ‘All right.’” Mr. Stayberg declined to give the friend’s name.

When the pandemic hit, Feeding Our Future’s world changed.

School was out. Children were hungry. Starting in 2020, Congress poured money into the feeding programs and allowed the Agriculture Department to waive rules that had been put in place after previous scandals to make sure states watched the watchdogs. For instance, state officials no longer had to visit feeding sites in person to see whether they were doing what the paperwork said.

After that, Feeding Our Future began to grow rapidly, adding dozens of new sites to its network. Some of them were start-up nonprofits that had sprung up during the pandemic and never served food before.

From 2019 to 2021, the number of children in Feeding Our Future’s network increased to about 400,000, from about 4,000, according to state records. The revenue flowing through its network increased to $197 million from $3.5 million.

Feeding Our Future’s share grew to about $19 million, which its founder and president, Aimee Bock, said she spent largely on salaries for her 80 employees and supplies for feeding sites. She said she paid herself $190,000.

But there were puzzling features at some of the group’s new sites. In Minneapolis, two Feeding Our Future locations claimed to be running large child care centers out of the same small building — one feeding 2,000 children a day, the other 500, according to state records. (Ms. Bock said the state records were wrong, and she had never claimed that food was served there.)

Another operation, housed in the nearby Safari Restaurant, claimed to be feeding 6,000 children a day on its own — more than the total number of children living in the restaurant’s ZIP code. Ms. Bock said the children came from surrounding areas, because the food was appropriate for East African immigrants, many of whom live in the area.

Advance Youth Athletic Development’s site — the location that turned out to be a second-story apartment — had obtained nonprofit status in June, using a fast-track I.R.S. process for groups that expect to have receipts of less than $50,000 per year. The F.B.I. said that after the nonprofit partnered with Feeding Our Future, it asked for $730,000 in reimbursements in its first month.

A lawyer for Feeding Our Future said the group never had an accountant on staff.

Then came the F.B.I. raids.

“My entire house shook,” Ms. Bock said. On the morning of Jan. 20, she said she heard banging and then saw F.B.I. agents at her front door. “All I could see were the spotlight and three guns, and they were just shouting, ‘Get down here! Get your hands up!’”

In an interview, Ms. Bock said she did not believe anyone in her network had cheated the system.

But if there was fraud, she added, “every test we have in place and every protection we have in place didn’t catch it. Is it possible? Absolutely. And if they got one over on us, I will help hold them accountable.”

Guhaad Said, the leader of Advance Youth Athletic Development, said the state’s numbers were wrong.

“I don’t know where that number came from,” he said in a phone interview. “I don’t know where the 5,000 children came from.”

That number appeared on the group’s application to enroll in one of the food-aid programs, which Feeding Our Future submitted to the state.

Mr. Said said his group had served meals at the site but declined to cite how many.

“There was not proper oversight” from Feeding Our Future, he said. “So people may have made some mistakes here and there. But there was no intention to go out there and waste government money.”

In Minnesota, state regulators had grown alarmed by Feeding Our Future’s growth and lack of financial controls by summer 2020, a spokeswoman for the state’s Department of Education said. It tried to stop payments for many of the group’s sites. But Feeding Our Future asked a judge to intervene, accusing the state of discrimination because of its work with African immigrants and saying the state had not proved any allegations of fraud.

If its payments were cut off, the organization told a judge, the results would be catastrophic, leading to bankruptcy, lost jobs and hungry children.

A judge ruled that the state had not taken the necessary steps to stop the payments. After that, Minnesota officials called in the F.B.I. and continued to channel aid through the group while federal agents conducted a nine-month investigation.

After the F.B.I. raids, Feeding Our Future was blocked from receiving state food aid. The group sought to formally dissolve in late February.

Minnesota’s attorney general, Keith Ellison, said on Thursday that he was conducting a separate investigation of the group to determine whether it had violated state nonprofit laws.

The state has also sought to cut ties with a second sponsor called Partners in Quality Care, which had supervised some of the nonprofits that worked with Feeding Our Future.

A lawyer for Partners in Quality Care said it was fighting the action and had no indication that it was under investigation. As of last year, Feeding Our Future and Partners in Quality Care together oversaw 53 percent of the money that Minnesota disbursed through these two federal aid programs.

But even after the F.B.I. raids, there are suggestions that some people are still trying to game the system.

Lily Crooks, who operates a small day care center in Minneapolis, said she had worked with Feeding Our Future and received about $30 per month for a year for the snacks she served her children. After Feeding Our Future was raided, she said, a new sponsor called to recruit her — and immediately offered a plan to fool the state.

What if, the woman suggested, Ms. Crooks told the government that her snack was actually a full meal instead? “We could call it breakfast” and make five times more, Ms. Crooks recalled the woman saying.

Ms. Crooks said she declined, and was disheartened by the offer. “They are watchdogs, right?”

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What next after dirty money keeps Uganda on grey list?




Government officials are heaving a sigh of relief after the Financial Action Task Force (FATF) opted against placing the country on a blacklist.

The Paris-based FATF is an intergovernmental organisation created in 1989 at the behest of the G7 political forum to combat money laundering.

On June 17, it communicated that Uganda will remain on a grey list that captures countries with deficiencies in their Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) controls.

While the FATF’s blacklist has only two countries; North Korea and Iran, the grey list has 23 countries. Along with Uganda, the grey-listed countries include Albania, Barbados, Burkina-Faso, Cambodia, the Cayman Islands, Gibraltar, Haiti, Jamaica, Jordan, Mali, Morocco, Myanmar, Nicaragua, Pakistan, Panama, Philippines, Senegal, South Sudan, Syria, Turkey, the United Arab Emirates (UAE), and Yemen.

Back in May, there were genuine fears that Uganda was destined to be blacklisted.

Mr Sydney Asubo, the executive director of the Financial Intelligence Authority (FIA)—a government body which is, among others, charged with enhancing and identifying proceeds of crime and combating of money laundering and terrorism financing—didn’t mince his words at a media briefing.

“We are not yet on the blacklist of the European Union. What happens is that if the European Union puts you on the grey list, the UK automatically puts you on its blacklist,” Mr Asubo explained back then, adding, “When Uganda was assessed in 2016, a number of issues were identified and a review in 2020 [found that] some issues were still not addressed. There were 22 particular action items. These were to be addressed by January, but the deadline was pushed by four months due to the Covid-19 pandemic disruptions.”

While Uganda fell short in its attempt to be hauled off the grey list, Malta was given the all-clear. The archipelago improved its AML/CFT regime by pushing through commitments that make it possible to know the owners of companies, their jurisdictions, and also putting in place sanctions on gatekeepers who fail to obtain accurate beneficial ownership information.

Malta is also no longer the subject of the FAFT’s Increased Monitoring lot because it has shown competence in using financial intelligence to pursue tax-based money laundering cases.

All of these action points continue to elude Uganda. In fact, the head of Uganda’s Anti-Corruption Court told Saturday Monitor that the FATF’s latest report still has the East African nation firmly in the crosshairs.

“The report to me is saying you are not demoted, but you are remaining in the same class,” said Justice Lawrence Gidudu of the body of work titled Jurisdictions Under Increased Monitoring, adding, “The FATF is using diplomatic language to raise their concerns, but the things we are supposed to do as a country to get off either the grey list or not to go into the blacklist are far from being possible because… they want an institutional response by all actors, which is not the case at the moment.”  

In its evaluation of Uganda’s efforts to combat money laundering, terrorist financing, and proliferation financing, the FAFT credited Uganda for its “high-level political commitment to work with [the FATF] to strengthen the effectiveness of its Anti-Money Laundering (AML)/Combating the Financing of Terrorism (CFT) regime.” Uganda, the FAFT added, demonstrated progress, such as conducting Terrorisms Financing (TF).

A number of strategic deficiencies were, nonetheless, pointed out. The first area where Uganda has continued to stumble—according to the FAFT—is seeking international cooperation in line with its risk profile. 

“This means we have a lot of risks of dirty money either emanating from Uganda or going outside or dirty money coming in,” Mr Tom Walugmbe, a former senior prosecutor at the Anti-Corruption Court, said, adding, “That means we should have cases where we can demonstrate that we have had engagements with other stakeholders in the anti-money laundering community.”

Mr Walugembe proceeded to note: “When you are talking about international channels, you are talking about formal and informal channels. So, can the law enforcement agencies in Uganda illustrate the cases they are working on, for example, to recover money from abroad? I’m not aware of such cases.”

In 2017, the paradise papers by the International Consortium of Investigative Journalists (ICIJ) revealed that then Foreign Affairs minister Sam Kutesa created offshore companies, which benefited him and his family.

Mr Kutesa, a former president of the United Nations General Assembly, was linked to the Obuyonza Discretionary Trust in Seychelles, a tax haven. Mr Kutesa’s daughter, Ishta Asiimwe Muganga, was listed as a beneficial proprietor, as well as a future beneficiary of money from the Trust.

Obunyonza, the papers further revealed, provided consulting and airport services in Uganda.

Mr Kutesa was also reported to provide ground-handling services at Uganda’s Entebbe airport through his other company—Entebbe Handling Services or Enhas. In a 2017 interview with the Daily Monitor, Mr Kutesa confirmed forming companies but he was also quick to deny any wrongdoing.

“I have never done anything with it at all. I told Appleby (an offshore legal services provider known for helping to set up shell companies, trusts, and other secretive financial products in tax havens) to close it many years ago, “ Mr Kutesa, who was censured by Parliament in the 1990s after engaging in what was deemed as corruption, said. 

Uganda was also captured in the Pandora Papers, albeit vaguely at first. One politician and eight companies—whose names were never disclosed—were cited.

Experts say one of the key issues dogging Uganda is its failure to cooperate with international security agencies even as many Ugandans open offshore accounts in tax havens. For instance, the ICIJ, in its leaks, revealed that Mr Jim Muhwezi owned and held shares in two shell companies. Mr Muhwezi—who, like Mr Kutesa, was censured by the House in the 1990s for engaging in corruption—was the Information and National Guidance minister when he became one of the shareholders of Audley Holdings Ltd domiciled in the tax haven of the British Virgin Islands. 

When it comes to international cooperation to fight dirty money, the FAFT says Financial Intelligence and evidence may be attained through formal and informal cooperation of countries. 

Informal channels include networks that connect Financial Intelligence Units (FIUs) such as the Egmont Group7, as well as police-to-police channels, Interpol, diplomatic channels, regional AML networks like Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), and the Asset Recovery Inter-Agency Network of Southern Africa (ARINSA). 

Although the FAFT says formal mutual legal assistance requests should be based upon substantial domestic investigation and used alongside informal communication networks, experts interviewed insist this remains on paper as countries seem to have different interests. 

“Governments want to attract people with money. They seem not to care where this money is coming from,” Justice Gidudu said, adding, “If you reject the money, these guys go to another country where they will be accepted. So, the country that rejected the money ends up losing.”  

Another area that has proven elusive for Ugandan authorities is addressing the opaqueness that surrounds the ownership of Ugandan companies. Uganda is supposed to amend the Companies Act so that it becomes easy to know the real owners of companies.

“Company registration is still a secret matter. I think they are indicating we should be able to go into the Uganda Registration Services Bureau website and insert the words of the company… and it should be able to tell us the history of all the owners and directors—their shareholding and directors from the time it was registered to the current time,” said Justice Gidudu, adding that Uganda doesn’t have that kind of facility yet.

The road to getting information about Ugandan companies, as things stand, is full of roadblocks. At least, as far as Justice Gidudu is concerned.

“Because, let say, you are not in Kampala, you will use the money on transport to come from wherever you are, then pay a fee to Uganda Revenue Authority for searching the register, then [the company registry] give[s] you the information,” he revealed, adding, “But they don’t hand you the file for you to peruse to know it was started by so and so, the directors were so and so, they changed to so and so. You don’t get those transactions because they don’t give you the entire file.”

Justice Gidudu as such believes the FAFT is trying to tell Uganda that the legal framework surrounding the registration of companies should change to allow more transparency.

The judge reasons thus: “They are saying when you register a company here, that information is uploaded on the URSB website so that when I’m, say, in London (UK) and I just insert words URSB, I’m able to look into various fields that are there and I’m able to see this company was formed in this year and these were the original shareholders and if they are still the shareholders. You are able to see the original directors and if they are still the directors.”

He, however, notes that “these fellows are not ready to [effect the changes] because politicians have a lot of companies that trade in government in which they hide and URSB is complicit.”

He adds that one on the outside looking in “will never get details even if you pay.” He further contends that “those companies are already in touch with URSB.”

Experts also say another reason why Uganda has remained on the grey list is because it has failed to implement what the FAFT has termed as “a risk-based approach for supervision of the non-profit organisation [NPO] sector—locally known as nongovernment organisations (NGOs)—to prevent terrorism financing.”

The FATF revealed in its latest report that it “continues to monitor Uganda’s oversight of the NPO sector. Uganda is strongly urged to align the Terrorist Financing Risk Assessment for NPOs with the FATF Standards. This is needed to apply the risk-based approach to supervision of NPOs in line with the FATF standards to mitigate unintended consequences.”

The National Anti-Money Laundering Taskforce’s 2021 report titled ‘Terrorism Financing Risk Assessment For The Non-Profit Organisations Sector In Uganda’ made clear the finding that faith-based organisations (FBO) which operate Islamic religious schools known in Arabic as Madrassas and non-profit organisations that are involved in the governance sector pose a high terrorism financing risk.  

“Terrorism Finance [TF] investigations have been conducted by law enforcement agencies in Uganda involving FBOs that operate Madrassas for recruitment of mainly the youth for terror-related activities.

Charity organisations with links to the Allied Democratic Forces (ADF) rebels (not disclosed for fear of jeopardising investigations) are currently being investigated for their alleged involvement in TF activities,” the report reads in part, adding, “The assessment has found that bank accounts of four NGOs—all in the governance sector—have been frozen on account of suspected TF. These NPOs have been categorised as high risk on the basis of suspicious transaction reports. Criminal investigations are ongoing and at the same time, there are interlocutory court proceedings ongoing in relation to the same investigations.” 

The Anti-Money Laundering Task Force, which was led by the deputy Secretary to the Treasury—Mr Patrick Ocailap, concluded that there was limited regulatory capacity, as well as few competent authorities, to provide oversight and enforce compliance. It added that NPOs use cash in their transactions, which limits accountability and transparency in the use of funds.

Also, inadequate inter-agency cooperation and information sharing to support investigation and prosecution was illuminated.

The NGOs whose niche is governance and human rights advocacy dismissed the findings, saying the government is playing politics.

“The problem is Uganda’s things are caught up in politics. So instead of working and addressing the real issues, they are working on things they think are the real issues, “Peter Magelah Gwayaka, the programme manager at Chapter Four told Saturday Monitor.

Chapter Four is one of the 53 organisations whose operations were indefinitely suspended last year by the National Bureau for Non-Governmental Organisations on account of failing to comply with the legislation covering their operations.  

Going forward, the Financial Action Task Force (FATF) has also urged Ugandan authorities to rapidly implement its action plan to address the strategic deficiencies. This includes developing and implementing risk-based supervision of financial institutions and Designated Non-Financial Businesses and Professions (DNFBP) such as churches and real estate.

“They want an institutional response by all actors that if you are on the same portal and money is deposited in the bank, then Financial Intelligence Authority, Bank of Uganda should know but we don’t have that,” Justice Lawrence Gidudu, the head of Uganda’s Anti-Corruption Court, said, adding, “Our law only requires them to report suspicious transactions. If banks are part of the schemes, which normally they are, they won’t report themselves.”

So, what needed to be done?

“We have to amend the Financial Institutions Act that sets up the Financial Intelligence Authority (FIA) such that it has powers to investigate and prosecute but right now, the FIA has no powers to investigate. It has no powers to prosecute a money launderer,” Justice Gidudu noted, adding, “The FIA can ask the police to investigate. It can only request the DPP (director of public prosecutions) to prosecute. It can order the police, but it can’t order the DPP.” 

Supervising DNFBP as FAFT requires could, however, prove difficult. 

“Lawyers are supposed to report suspicious transactions because they are accountable persons. But how many lawyers have reported such cases? Even churches are included as an accountable person, but how many churches can ask their believers who give them a lot of money for their sources of income? Who is supervising real estate because all the dirty money in Uganda is hidden in real estate,” a former senior prosecutor at the Anti-corruption Court, who has since gone into private practice, said on condition of anonymity.  

Officials from the FIA were not readily available to comment about the FATF’s latest findings.

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