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Mugisha: Fraud fight could save us from grey list

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Ronald Mugisha, Uganda Bankers Association’s senior cyber and risk officer explains how this anti-fraud consortium will work. PHOTO/ DOROTHY NAKAWEESI

What goals and objectives does the consortium aim to achieve in its inaugural year, and how will success be measured?
In 2025, our goal is to improve fraud information sharing using the Fraud Portal. This is important because it enables all supervised financial institutions and other key Anti-Financial Fraud Consortium (AFC) stakeholders to understand financial fraud trends and participants and design interventions to mitigate this threat. A hundred per cent of all banks, payment service provivers and payment service operators should be reporting fraud incidents on the portal.

The second goal is to design and implement impactful capacity building programmes based on the needs of key stakeholders such as the Criminal Investigations Department (CID) and the Office of the Director of Public Prosecution (ODPP).
The goal is to empower our stakeholders to better detect, prevent, investigate and prosecute financial fraud across. Details on the achievable targets will be available after further engagement with CID & ODPP.

We shall also initiate awareness campaigns for the consumer as the first line of defense against financial fraud. To achieve this, all AFC founder members are pulling resources to implement unified anti-fraud messaging. Our objective is to empower all citizens to understand and identify financial fraud to protect themselves from loss.


How will you engage with stakeholders across the financial sector, including banks, fintech companies, regulators, and law enforcement agencies?
The AFC has a steering committee composed of the regulators Bank of Uganda (BoU), Financial Intelligence Authority (FIA) and Uganda Communications Commission (UCC), Uganda Bankers’ Association and the Payment Service Providers Association, represented by MicroPay Uganda Limited, MTN Mobile Money, Airtel Mobile Commerce Uganda Limited (AMCUL), Yo Uganda Limited, Pegasus Technologies and Interswitch East Africa. The goal is to work together to engage key stakeholders in law enforcement, Legislature, Judiciary, MDAs, development and technical partners and industry associations such as the Association of Micro Finance Institutions of Uganda (AMFIU), the Information Systems Audit and Control Association (ISACA), the Association of Certified Fraud Examiners (ACFE), the Institute of Certified Public Accountants of Uganda (ICPAU), Consular Report of Birth Abroad (CRBAs) and the Financial Technologies Service Providers Association (FITSPA) among others. We need to leverage our different strengths in the fight against fraud.


What key areas of financial fraud will the consortium mainly focus on, such as cybercrime, identity theft, or money laundering?
The AFC will address cyber fraud, identity theft, mobile money fraud, and insider threats.
 We shall also target emerging fraud schemes involving payment systems and social engineering. Focus will be data-driven, targeting high-risk and high-impact cases.
 We shall adapt as threats evolve. Fraud such as cash theft and suppression, credit fraud and others, will also be handled by the AFC.


How will you facilitate collaboration and information sharing among the consortium members to prevent and detect financial fraud?
A central Fraud Portal will enable real-time reporting and intelligence sharing. This portal will be hosted by the Financial Intelligence Authority who have the legal mandate to operate this ref the FIA Act.

We are also cognizant of the Data Privacy & Protection Act and regulations, thus we shall operate within the confines of the law. We strongly believe the Institutions will use standardised formats to submit and track fraud cases. 
To check progress, we will hold monthly information exchange sessions and joint reviews. We must build transparency to enable rapid response.


What role does the consortium envision for new technologies, such as Artificial Intelligence (AI) and machine learning, in enhancing fraud detection and prevention capabilities?
Technology will be key to prevention and detection. Financial institutions are already deploying and using different fraud detection & prevention tools at different levels within their organisations from the AFC. We shall explore Artificial Intelligence (AI), machine learning, and data analytics to identify fraud patterns industry-wide and design solutions to mitigate fraud. These tools enhance accuracy, reduce delays, and predict emerging threats. They complement human expertise and speed up intervention. The AFC’s Infrastructure Technical working group chaired by Pegasus Technologies Limited will drive this initiative.


Are there plans for capacity-building initiatives, to enhance the skills of professionals in the financial sector in combating fraud?
Training is a core part of the AFC’s work plan. We are starting a capacity building needs assessment for different stakeholders in the AFC. This initiative speaks to human resources and other technical resources that we need to build and scale up to mitigate fraud. Our training will be targeted and focused on addressing the challenges identified. The objective is to build capacity at all levels across the country.

How will the forum address the challenges of cross-border financial fraud and cooperation with international partners?
Today, some mechanisms support the investigation and prosecution of cross-border fraud, where we (Uganda) have Memoranda of Understanding in place. We intend to strengthen these mechanisms through engagement with regional regulators and international partners. 

We also reviewed the existing legal and regulatory frameworks that enable fraud detection, prevention, deterrence, investigation and prosecution, the AFC intends to lobby for regulatory reforms based on this study and work with the different key stakeholders such as the Ministry of Justice and Constitutional Affairs and the Parliament of Uganda to enact laws that, among other things, will address the challenges of cross border financial fraud. The legal, research and advocacy technical working group chaired by the FIA, will drive regulatory reforms under the AFC. 


What mechanisms will be put in place to ensure the consortium's activities are aligned with regulatory requirements and industry best practices?
All AFC activities are aligned with existing financial laws and policies. Amongst our founder member are Bank of Uganda, FIA, and UCC who provide oversight to ensure regulatory compliance.
 We’ll also benchmark against global anti-fraud standards like Financial Action Task Force (FATF) which leads global action to tackle money laundering, terrorist and proliferation financing and also carry out regular reviews to ensure continued alignment and integrity.

How will the forum measure its impact on reducing financial fraud in Uganda, and what metrics will be used to assess its effectiveness?
There is no silver bullet to fix the fraud problem. However, in the medium to long term, we shall be able to experience the benefits accrued from the AFC’s work. 

Mitigating fraud will result in keeping Uganda off the FATF grey list, increased financial inclusion, and lowered costs of access to finance as credit risk is mitigated. We shall also work with law enforcement and ODPP to track financial fraud incidents reported, their prosecution and conviction and these statistics will be accessible in the Uganda Police Annual Crime Report.


Are there plans for public awareness campaigns or educational initiatives to inform consumers about financial fraud risks and protection measures?
Yes, the AFC had a communication and stakeholder engagement technical working group chaired by the Uganda Communications Commission. This group has been tasked to design and roll out targeted and comprehensive public awareness campaigns to drive fraud awareness and ensure consumer protection.