If you are operating in the real estate sector today, you need to wake up to a hard truth: real estate is one of the most attractive sectors for money laundering. The Financial Intelligence Authority (FIA) has repeatedly warned that real estate is a major channel for illicit money flows in Uganda. IGG Beti Kamya herself pointed out that "most proceeds of corruption go into real estate." Are you doing enough to protect your business and your reputation?

The reality is that real estate agents are now expected to act as the first line of defense against financial crimes. AML (Anti-Money Laundering) and CFT (Combating the Financing of Terrorism) compliance is not optional. It's a legal obligation, and one that can either build your credibility or ruin your business if neglected.

AML/CFT compliance means having systems in place to prevent criminals from using your real estate business to launder money or finance terrorism. This isn't just a matter of filing a few reports here and there. It requires you to:

• Verify the identity of your clients (Know Your Customer . KYC)

• Understand the source of their funds

• Monitor transactions for suspicious activities

• Report any suspicious transactions to the FIA using the goAML platform

Failure to comply exposes you to heavy penalties, license revocation, and even prosecution. But beyond the legal risks, think about your reputation. Would you want your name associated with a scandal involving dirty money?

According to the FIA Deputy Executive Director, Michael Olupot Tukei, the real estate sector is extremely prone to money laundering because it allows large amounts of money to be moved in a single transaction, often with little scrutiny. Properties can be bought with cash, sold quickly, and flipped to hide the origin of illicit funds.

Shirley Kongai, President of the Association of Real Estate Agents (AREA) Uganda, highlighted another major issue: the sector is largely unregulated. "Anyone can start a real estate business and the choice to run it is upon them," Kongai says. This encourages fraud, land grabbing, and price speculation. When people can walk in and buy land without bargaining, it inflates property prices, making homes unaffordable for ordinary Ugandans.

Ask yourself:

• Are you comfortable being part of an industry that criminals find attractive?

• What will you do when regulators start cracking down harder on non-compliant agents?

Strengthen Your Capacity: How to Implement a Risk-Based Approach

The risk-based approach (RBA) is at the heart of AML/CFT compliance. It means focusing your attention and resources where the risks are highest.

Start by identifying the types of clients, transactions, or locations that present higher risks. For example, if a client is offering to pay in full cash for a high-value property and refuses to explain the source of funds, that's a red flag. Another example: clients from countries known for high levels of corruption or terrorism financing may warrant closer scrutiny.

Document your assessments. Set clear internal policies. Train your team regularly. This way, you are not just ticking boxes, you are actually reducing your exposure to criminal activities.

Wouldn't you rather spend a few hours setting up strong procedures now than spend years fighting a legal battle later?

The goAML system is the FIA's secure platform where you report suspicious transactions. Here's how you get registered:

1. Visit the FIA website: Locate the goAML portal.

2. Create an organization account: Provide your company's legal documents, Certificate of Incorporation, license, and details about your compliance officer.

3. Submit KYC documents: These include ID copies and contact information of the directors and beneficial owners.

4. Undergo verification: The FIA will review your application and approve or request for additional information.

5. Start reporting: Once registered, you are expected to submit Suspicious Transaction Reports (STRs) and Cash Transaction Reports (CTRs) as required.

Registration is not just a formality. It's a demonstration to the market, to your clients, and to regulators that you are a responsible, law-abiding professional.

When was the last time you checked if your business systems could even detect a suspicious transaction?

A few years ago, I spoke to a small real estate broker who lost her entire real estate business overnight because she unknowingly facilitated the sale of a property purchased with stolen government funds. She had no compliance systems, no KYC procedures, and no clue about the red flags she should have spotted.

When the scandal hit the news, she didn't just lose her business, she lost her livelihood and her good name. Compliance isn't just for big agencies. It's for everyone who values their business.

In a world where trust is everything, being a compliant real estate agent can actually set you apart. Clients, especially serious investors, want to deal with agents who operate with transparency and integrity. Are you ready to be that agent?