money transfers. However, a number of national and global efforts have stagnated primarily because there were insufficient resources to address deficiencies in a number of countries. There were inadequate systems for obtaining information on customer identity, reporting suspicious transactions, and confiscating terrorist assets. Uganda is no different, or perhaps worse.
If the government can fail to raise money to run its own organs like the judiciary, it is not farfetched to think that the FIA will suffer the same fate. The IMF and World Bank have helped countries to address these problems through an ambitious programme of technical assistance. But such acts of generosity lack sustainability in the long run.
The act raises another intriguing problem. As noted earlier, advocates are also accountable persons. They are obligated to report any suspicious transactions in which they engage. The problem is, as controls have been tightened in the formal financial system, the attorney-client privilege has made lawyers a particularly attractive means for disguising the money trail. After all, isn’t this privilege just another form of secrecy, which can cleverly substitute for bank secrecy to improp-
The challenge … has been the failure to move from reactive responses to past problems to proactive responses to meet future needs