Uganda General Money-Laundering 2000-2006


Uganda Minister Of Microfinance - General Salem Saleh (aka) Caleb Akandwanaho
Uganda Minister Of Microfinance - General Salem Saleh (aka) Caleb Akandwanaho

On February 25, 2006 Uganda President Museveni officially approved the Lake Victoria Free Trade Zone (LVFTZ) and appointed his brother, General Salim Saleh (aka) Caleb Afande Akandwanaho, as Uganda Microfinance Minister who knew LVFTZ was a money-laundering operation from 2000-2006.

Uganda General Money-Laundering 2000-2006
By, The Offshore Informant

August 7, 2006


The step-brother of Uganda government President Yoweri Kaguta Museveni known as the now-retired M.P. UPDF General Salim Saleh (aka) Caleb Afande Akandwanaho, who owned 25% of SARACEN KAMPALA LTD. (Kampala, Uganda) with 45% owned by BRANCH ENERGY, maintained a very close personal financial business relationship from 1999-2004 with an American named Van Arthur Brink (formerly known until 1998, as Gilbert Allen Ziegler) who lived in Uganda until May 28, 2004 when one of General Saleh SARACEN security force guards was shot to death by Kampala, Uganda police while the SARACEN guard was trying to protect Brink at home (Luzira, Uganda). Ugandan police stormed the walls of Brink's multi-million dollar luxury home to arrest Brink based on an INTERPOL warrant issued by the United States Department Of Justice Federal Bureau Of Investigation (FBI).

Brink was taken by Ugandan forces to Entebbe Airport and flown with five (5) F.B.I. agent escorts to Johannesburg, South Africa and later flown to America to answer criminal charges filed in a Portland, Oregon federal case citing wire fraud and mail fraud - involving international money-laundering of at least $105,000,000.00 (USD) - from 1996-2000 but for 4-years, from 2000-2004, General Saleh had become very close to Van Brink and his financial business affairs, and although Brink paid General Saleh plenty of money for 'special security protection' he also did the General favors such as writing a presentation for Saleh to present before a United Nations Security Council Committee investigating General Saleh for a multitude of crimes that dealt with diamonds and precious metals smuggling operations, money-laundering in foreign bank accounts, associations with al-Qaeda terrorists in Non-Governmental Organizations (NGOs), and more.

After presenting Brink's paper and testifying before the United Nations Security Council Committee, General Saleh mysteriously no longer faced being charged with those crimes, which is odd since General Saleh introduced Van Brink - during an April 2003 meeting in Africa with an NGO export manager who the U.S. knew had ties to al-Qaeda and had asked Brink to assist him in arranging financing for that NGO.

Within 2-years of Brink's arrest in 2004, General Saleh was appointed by his step-brother Uganda President Museveni in 2006 to become the Uganda government Minister of Microfinance.


On December 19, 2005 KAGERA ECO-CITIES LTD. (Kampala, Uganda) directors Mr. Beenunula Eyenunula ("Ben") Nunumisa and Ms. Gertrude N. Njuba, lead developers and promoters of the LAKE VICTORIA FREE TRADE ZONE (LVFTZ), wrote to Uganda President Yoweri Kaguta Museveni accusing Uganda government officials of failing to understand complexities of a "special economic zone" being mixed with an "export processing zone." Beenunula Eyenunula Nunumisa and Gertrude N. Njuba bitterly complained that relevant Uganda government officials were dragging their feet over the matter presented.

On December 28, 2005 the principal private secretary of Uganda President Yoweri Kaguta Museveni, Uganda Prime Minister, Uganda Minister of Justice, Uganda Attorney General, Uganda Minister of State for Finance (Investments), and Uganda Minister of Trade, Tourism, and Industry saw a letter 'written on that date' by LAKE VICTORIA FREE TRADE ZONE Governor Beenunula Eyenunula Nunumisa, which indicated firms registered in the LAKE VICTORIA FREE TRADE ZONE had attracted several international firms, including an online 'financial markets brokerage' company named CAPITAL MARKETS GROUP and FLINTLOCK MARKETS LLC to 'invest' in what the LAKE VICTORIA FREE TRADE ZONE had to offer, but the Uganda government delayed signing a "Memorandum Of Understanding" (MOU) for the Sseesamirembe city charter, which saw local Uganda companies like STANBIC and ROKO CONSTRUCTION reluctant to do "serious business" with companies registered in the LAKE VICTORIA FREE TRADE ZONE.

On January 22, 2006 controversy had strangled the proposed multi-million dollar LAKE VICTORIA FREE TRADE ZONE in Sseesamirembe, Rakai, Uganda despite a Uganda Presidential directive that various government Ministries should finalize a "Memorandum Of Understanding" (MOU) for the establishment of the LAKE VICTORIA FREE TRADE ZONE.

On February 25, 2006 Uganda government President Yoweri Kaguta Museveni "officially approved" the establishment of the LAKE VICTORIA FREE TRADE ZONE (LVFTZ) for KAGERA ECO-CITIES LTD.


KAGERA ECO-CITIES LTD. Beenunula Eyenunula Nunumisa and Gertrude N. Njuba requested the Uganda government give them permission to turn her Uganda government granted 200 square miles of land in Uganda's Rakai District adjacent to Uganda's great lake named Lake Victoria, into a special Free Trade Zone to be run as an 'autonomous territory'.


The Sseesamirembe city charter proposes the Uganda government give them the authority to administer the 200 square miles under a 'separate governmental structure' empowering them to enact their own laws, ordinances, by-laws, and procedures.

According to the Sseesamirembe city charter, they want their own government, led by a Governor, to decide on official language(s), "establish courts within the Free Trade Zone in consultation and in conjunction with the Government of Uganda, and provide and maintain a 'security force' for the protection and safety of the inhabitants of the Free Trade Zone."

The Sseesamirembe city charter would see their judicial system led by a High Chancellor, and only permanent residents of the LAKE VICTORIA FREE TRADE ZONE be eligible to hold office of a Governing councilor.

Among other powers, the Governor would have powers to "pardon, forgive, or excuse any violations of rule, regulation, or ordinance by any resident, except that such pardon could not be given to anyone convicted of premeditated murder or any other major crime."


The LAKE VICTORIA FREE TRADE ZONE Registrar would have powers to register land titles, claims, and grants as well as all official documents, wills, deeds, securities, and endowments.

The charter indicates whereas there would be no official religion or administration-approved religion of the Free Trade Zone, the zone "may enact such rules ... or regulations which provide reasonable accommodation or indulgence to the free expression or exercise of any religion."

Though not specified in the current Sseesamirembe city charter, Ms. Gertrude N. Njuba and Mr. Beenunula Eyenunula Nunumisa mentioned another role of the LAKE VICTORIA FREE TRADE ZONE as mentioned in their December 19, 2005 letter to Uganda President Museveni, which was to have an Immigration Department, "offering work permits, tourist visas, transit visas but not authorized to issue passports or citizenships."

On April 27, 2000 SSERULANDA DEVELOPMENT ASSOCIATION filed with the Registrar of Companies that it's directors, were:

- Gertrude N. Njuba, president;

- Nkwine Barigye (aka) Nkwine Bhuka Bijumiro Jummiro (aka) Princess Nkwine Kobuhamizo, who claims to be the sister to Prince John Barigye (Crown Prince of Ankole), and wife of Bhuka Bijumiro Jummiro, the disciple and biographer of Jozzewafe Mugonza (aka) Bambi Baaba Mugonza (aka) His Imperishable Glory Bambi Baaba; and,

Kasiimwe Ssemyanjo, resident leader of the SSERULANDA SPIRITUAL FOUNDATION.

On April 27, 2000 SSERULANDA DEVELOPMENT ASSOCIATION filed with the Registrar of Companies that the owners of LAKE VICTORIA FREE TRADE ZONE LTD. are selected members, high-ranking officials, and the founders of the SSERULANDA SPIRITUAL FOUNDATION (Sseesamirembe, Rakai, Uganda).

On May 24, 2000 VICTORIA CORPORATE SERVICES LTD. filed with the Register of Companies a "Memorandum of Association" indicating SSERULANDA SPIRITUAL FOUNDATION owners, included:

- VICTORIA CORPORATE SERVICES LTD. (VCS), a 40% shareholder with directors Achille Karuletwa, Joseph Masiko (lawyer), and Ms. Jadwiga Nowak, a Polish national;

- Beenunula Eyenunula Nunumisa (director of FOREXAFRICA.COM LTD.)

- Gertrude N. Njuba

- Jozzewafe Mugonza (aka) Bambi Baaba Mugonza (aka) His Imperishable Glory Bambi Baaba - 15% shareholder; and,

- Muyondo Ssensubulo.

On October 29, 2003 VICTORIA CORPORATE SERVICES LTD. filed with the Registrar of Companies a "Memorandum Of Association" (MOA) incorporating LAKE VICTORIA FREE TRADE ZONE LTD. as a company limited by shares with the objective of building, owning, managing, and developing "free zones and special economic zones at strategic geo-political locations in Africa and elsewhere in the world."


From 2000-2004 the vast majority of $125,000,000.00 (USD) lost by depositor victims before the collapse of the now-defunct FIRST INTERNATIONAL BANK OF GRENADA LTD. financial business system network were sent through ANZ BANK SAMOA LIMITED in Apia, Samoa (below), and ORIENT BANK LIMITED in Kampala, Uganda (further below).

VICTORIA CORPORATE SERVICES LTD. bank wire transfers 'greater than' $1,000,000.00 (USD), was sent to:

Main Beach Road
BSB: 039

Account Number: 2104383
Account Name: WILD ROSE SAM LTD.

WILD ROSE SAM LTD. ( WRSL ) was an international business company (IBC) controlled by Van A. Brink who was named as one of it's "Representative Agents" operating through the offices, of:

Diamond Trust Building - 3rd Floor
Kampala Road
P.O. Box 8711
TEL: + 256 41 348-548
MOBILE: + 256 77 700-074
FAX: + 256 41 348-286
CONTACT: Phyllis Karuletwa, Archille Karuletwa, and Olukayode Osunsan (aka) "Olu".

On August 17, 2000 WILD ROSE SAM LTD. ( WRSL ) - controlled by Van A. Brink - entered a joint venture agreement contract with his brother, James Gregory Ziegler (aka) Zig Ziegler, who controlled an international business (IBC) known as GOLDEN AGE SERVICES LTD., which he had his foreign attorney, Dr. Epifanio Vasquez Santos (El Batey, Sousa, Dominican Republic), create foreign Trusts with foreign bank accounts to launder monies Ziegler took from his financial business fraud victims through another international business company (IBC) named OFIRA LTD. (registered in Charlestown, Nevis and St. George’s, Grenada) that another Ziegler foreign attorney named Rhonda Collymore (San Fernando, Trinidad) wire transferred monies into and out of multiple foreign banks, of which several were located in Kampala, Uganda.

Another bank used ostensibly to launder these financial crime victim funds, was:

Main Street
TEL: (869) 469-5564
TEL: (869) 469-5796
FAX: (869) 469-5798

And, 3-weeks ‘before’ FIRST INTERNATIONAL BANK OF GRENADA LTD. was seized by the Grenada government on August 11, 2000 James G. Ziegler (aka) Zig Ziegler was laundering financial business crime victim monies on July 20, 2000 that was:

Sent To:

100 S.E. 2nd Floor
Miami, Florida 33131
ABA: 066007681

For Further Credit To:

Main Street
Account Number: 01901577412

For Final Credit To:

Account Number: 294705

Ziegler, had hired another foreign attorney named Herman Weston Liburd (aka) Bobby Liburd (aka) Herman Liburd to register Ziegler’s international business companies (IBCs), amongst several, which included:

c/o William A. Hull Business Centre
Spencer H. Howell Building - Suite 201
Main Street
TEL: (869) 469-0756
TEL: (869) 469-0995
TEL: (869) 469-0743
TEL: (869) 469-5222
TEL: (869) 469-7308
FAX: (869) 469-0756
FAX: (869) 469-0793
CONTACT Tessa Howell and Elridge E. (“Sekou”) Glasford.
WWW: and [NOTE: Use to view that old website]

In 2000, CORPORATE MANAGEMENT & CONSULTING SERVICES LTD. ( CMCS ) was a money-laundering ‘data processing center’ established by James Gregory Ziegler (aka) Zig Ziegler and his wife Jean (“Maggie”) Wahls Ziegler set-up a woman named Tessa Howell who they defrauded out of $70,000.00 in earnings by January 11, 2001.

Ziegler and Wahls groomed Tessa Howell and then turned her over to FIRST INTERNATIONAL BANK OF GRENADA LTD. bank CEO Mark Kennedy to work for him after Ziegler established an international business company for Howell under the name GIFT TRUSTEE LTD.

After FIRST INTERNATIONAL BANK OF GRENADA LTD. was seized by the Grenada government on August 11, 2000 Ziegler hired Howell to do business for him, which consisted of answering phones, collecting mail, plus little did she realize at the time was also perform money-laundering activities such as collecting and sending bank wire transfers for them.

By January 11, 2001 it became evident to Tessa Howell that Ziegler’s promises to pay her earnings of $70,000.00 dollars to that date was another fraud of Ziegler’s so, she threatened to sue James Gregory Ziegler in a Nevis court of law, the outcome of which was never made clear.

In 2000, as James Gregory Ziegler had Howell working from Charlestown, Nevis for FIRST INTERNATIONAL BANK OF GRENADA LTD. bank CEO Mark Kennedy, Ziegler had gotten his own sister Irene (“Iris”) Koch (nee Ziegler) to operate FIRST ACCEPTANCE CORPORATION (FAC) from 1998-2000 out of a home whereby she facilitated bank wire transfer money laundering of nearly $105,000,000.00 (USD) from the FIRST INTERNATIONAL BANK OF GRENADA LTD. financial business system network.

According to Ziegler, FIRST ACCEPTANCE CORPORATION (FAC) became involved with an international business company (IBC) named GGA INVESTMENT LTD. S.A. and VKG TRADE AND INVESTMENT LTD. S.A., both of which were registered in Panama.

On August 7, 2000 international business companies (IBCs) named GGA INVESTMENT LTD. S.A. and VKG TRADE AND INVESTMENT LTD. S.A. appeared engaged with others to take over AMALGAMATED TRADE AND COMMERCE BANK AD (c/o Mr. Nonad Pavlicic at Trg. I, Milutinovica 14/1, Podgorica, Montenegro) that Van Brink saw to later naming INTERNATIONAL TRADE AND DEVELOPMENT BANK. Others, named in that contract, were:

- Achille Karuletwa (Citizen of Uganda) Chairman of the Board, and SSERULANDA SPIRITUAL FOUNDATION owner and shareholder VICTORIA CORPORATE SERVICES LTD. (VCS) director;

- Phyllis Karuletwa (Citizen of Uganda) Treasurer;

- Jadwiga Nowak (Citizen of Poland) Director, and SSERULANDA SPIRITUAL FOUNDATION owner and shareholder VICTORIA CORPORATE SERVICES LTD. (VCS) director;

- Olukayode Osunsan (aka) "Olu" (Citizen of Nigeria) Secretary, and VICTORIA CORPORATE SERVICES LTD. (VCS) Information Technology bookkeeper for James Gregory Ziegler financial business fraud victim money-laundering;

- Van Arthur Brink (Citizen of Grenada), founder and first CEO of the now-defunct FIRST INTERNATIONAL BANK OF GRENADA LTD.;

c/o COMNET SERVICES LTD. (Republic of Uganda), Diamond Trust Building - 3rd Floor, Kampala Road, P.O. Box 8711, Kampala, Uganda, TEL: + 256 41 348-548, TEL: + 256 77 200-074 (Van A. Brink mobile phone number in Kampala, Uganda);

- Bibic Predrag (attorney in Belgrade, Serbia for Van Brink introduced by James Gregory Ziegler);

- Alexander Gurevich [ Russia passport: 50-0057639 ], director of AMALGAMATED TRADE AND COMMERCE BANK A.D. (aka) AMALGAMATED TRADE AND COMMERCE BANK S.C. [ Montenegro Minister of Finance Registrar of Companies number: 683 ], c/o Mr. Nonad Pavlicic at Trg. I, Milutinovica 14/1, Podgorica, Montenegro;

- Robert John Skirving (Citizen of USA), Vice Chairman of the Board of Directors for the now-defunct FIRST INTERNATIONAL BANK OF GRENADA LTD.; and,

- Robert Osborne (Citizen of USA) Director.

From 2000-2001, Ziegler operated his financial business frauds over his home computer internet under the business names at his home address:

Costumbar Principal #5,
Puerto Plata,
TEL/FAX: (809) 571-3301

In 2000, Ziegler had made contact with his next foreign attorney, at:

El Batey
CONTACT: Dr. Epifanio Vasquez Santos

By September 2000, Ziegler was buying up Montenegro independent offshore bank licenses, fourteen (14) in all, through his foreign attornies in Montenegro and Serbia that he coordinated through his foreign attorney Dr. Epifanio Vasquez Santos in the Dominican Republic.

One of Ziegler’s 14 Montenegro banks included, LIBERTY ONE SAVINGS BANK A.D. (aka) LIBERTY ONE SAVINGS BANK S.C., which saw Roger D. Pearson invest monies in it through Thereon J. Marrs using his company named INTER WORLD ASSOCIATES INC.

Ziegler then sold ‘paper bank debentures’ he tied to his Montenegro banks that he used to defraud financial business fraud crime victims into phony investments he designed based on phony audits from TEAM & CO. (Kampala, Uganda) stating his bank assets were worth $1,000,000,000.00 billion (USD) and more, which was an outright lie.

After Ziegler defrauded his victims by not paying the huge rates of returns he promised them and by keeping their monies, he then sold his Montenegro banks to yet other financial criminals, who used those same banks to defraud even more victims, by doing the same thing.

Herman Liburd has a nephew named Mr. Jan Alex Dash, who is an attorney partner of his, at:

946 Fulton Street
Brooklyn, New York 11238
TEL: (718) 857-4181
FAX: (718) 638-1587
CONTACT: Mr. Jan A. Dash Esq.

With Herman W. Liburd as his uncle, Jan Dash claimed to practice law in the State of New York and in Charlestown, St. Kitts Nevis with their website sees Dash claim affiliations with organizations and firms in the British Virgin Islands as well as in Bermuda.

As far back as August 2000, James Gregory Ziegler (aka) Zig Ziegler issued 'paper debentures' promising his financial business fraud victims they would receive interest on their monies from 60% to 240% per year on monies he walked away with.

Ziegler’s financial business fraud victim monies were also held in the name of an international business company named OFIRA LTD. Ziegler saw registered not just in St. George’s, Grenada but also in Charlestown, Nevis through Ziegler’s additional foreign attorney named Herman W. Liburd, and OFIRA LTD. had Ziegler’s financial business fraud victim monies wire transfer records kept by VICTORIA CORPORATE SERVICES LTD., which saw bank wire transfers of 'less than' $1,000,000.00 (USD) that were:

Sent To:

111 Wall Street - 19th Floor
New York, New York 10043
ABA: 021 000 089

Account Number: 3608-6264

For Further Credit To:

Uganda House
Plot 10, Kampala Road
P.O. Box 3072
TEL: + 256 41 255-596 International Division
TEL: + 256 41 236-012
TEL: + 256 41 236-013
TEL: + 256 41 236-014
TEL: + 256 41 236-015
FAX: + 256 41 236-066

Account Number: 010-10693-51

Ziegler laundered his financial business crime victim monies through several banks in Uganda, amongst many, which also included:

Plot 22, Jinja Road
P.O. Box 2834
TEL: + 256 41 345-571
TEL: + 256 41 345-572
TEL: + 256 41 349-104
TEL: + 256 41 349-117
TEL: + 256 41 344-070
TEL: + 256 41 344-187
FAX: + 256 41 257-779

P.O. Box 21514 Kampala
TEL: 0485-21358
TEL: 0485-21359
FAX: 0485-21363

NILE BANK LIMITED major shareholders, were:

Gordon Wavamuno
Richard Kaijuka (FCIBO)
Ephraim R Kamuntu

NILE BANK LIMITED main executives, were:

Samwiri H.K. Njuki - Ag Chairman and Managing Director
S. Kanakulya Lubinga - Deputy General Manager
Mrs. Margaret Iga - Head of International Division

NILE BANK LIMITED auditors, were:


In September 2003, James Gregory Ziegler (aka) Zig Ziegler and Van Brink saw financial business fraud victim monies laundered, as follows:

111 Wall Street
New York, New York 10043
ABA: 021 000 089

Account Number: 36060881

For Final Credit To:

Plot 22, Jinja Road
P.O. Box 2834
TEL: + 256 41 345-571
TEL: + 256 41 345-572
TEL: + 256 41 349-104
TEL: + 256 41 349-117
TEL: + 256 41 344-070
TEL: + 256 41 344-187
FAX: + 256 41 257-779

Account Number: 433815

Monies laundered from these financial business fraud victims were sent in and out of many foreign bank accounts upon instructions from Van Brink and his brother James Gregory Ziegler (aka) Zig Ziegler via several foreign attornies using Trust bank accounts established for their international money-laundering operation network.

How Ziegler managed those laundered funds was simply via his e-mail communications with VICTORIA CORPORATE SERVICES LTD., an very small example of which is seen immediately below:

- - - -

By January 21, 2001 James Gregory Ziegler (aka) Zig Ziegler was still taking money from his financial business fraud client victims by laundering their funds monthly as was depicted in an e-mail he sent to VICTORIA CORPORATE SERVICES LTD. (immediately below).

-----Begin Original Message-----

Subject: Debentures Requested
Date: January 21, 2001


I requested that you not send money in January 2001, two things happened:

1.) you sent $16,000.00+ (USD) on January 8, 2001 that wasn't posted to me until January 15, 2001 due to an error on the bank wire regarding final beneficiary (it must be Rhonda Collymore, Attorney); and,

2.) you sent an additional $6,371.00 (USD) for some reason.

I re-calculated the debenture you owed me for January 1, 2001 deducting the $16,000.00 (USD). The $6,000.00 (USD) came subsequent to that calculation so, I am deducting it from what you owe for February 1, 2001.

I am again requesting that you NOT send $ due February 1, 2001.

If you have had time to read my correspondence previously e-mailed and sent DHL, you will note that I have caught you up by having you issue debentures instead of sending cash.

I am trying to hold back sufficient deposits to cover what you should send me.

The consequence to me is less earnings by the amount of days I sat on the monies, the big guy [Van A. Brink] and I will have to figure out a new strategy.

I must meet payments on the first of the month. If you send by the 10th of the month, I'm lucky to have payments out by the 18th of the month considering multiple wire transfer stops in the process between you and the ultimate recipient.

You owe GOLDEN AGE SERVICES LTD. $74,545.92 (USD) as regular payment for February 2001.

I am deducting the $6,371.00 received, which brings a new total of $68,174.92 (USD) herein requested as debenture to be effective February 1, 2001 with the first payment March 1, 2001 of $9203.61 (USD).

I acknowledge receipt of your notice that the 5-year rate applies instead of the 10-year rate.

I got an extension on the 10-year rate due to not having the joint venture apparatus in place yet.

We have rumors of some good deposits coming soon from which I can hold back some funds for March 1, 2001 however here is your heads up for March 2001: $93,469.53 (USD), as we stand today.

My Microsoft Excel master spreadsheet has been included for your reference.

New Debenture Request

This package:

Effective date Amount % Yrs. 1st Pmt. Reg Pmt.

February 1, 2001 $68,174.92 13.5 10 9,203.61 9,203.61

Requested January 9, 2001:

Effective date Amount % Yrs. 1st Pmt. Reg Pmt.

August 26, 2001 $49,954.00 15 15 1,997.80 7,491.95

November 3, 2001 $19,515.00 20 15 3,642.80 3,903.00

December 22, 2001 $119,470.00 20 15 7,704.74 23,894.00

November 17, 2001 $9,252.84 20 15 740.00 1,850.57

December 1, 2001 $26,000.95 20 15 5,200.19 5,200.19

January 1, 2002 $16,377.72 15 15 2,456.66 2,456.66

January 9, 2002 $216,000.00 15 15 22,680.00 32,400.00

I cannot get through on your FAX number.

Hard paper request coming your way by DHL.


-----End Original Message-----

- - - -

From 2000-2004, Ziegler saw over $41,000,000.00 (USD) laundered into multiple accounts handled by VICTORIA CORPORATE SERVICES LTD. through it’s recordkeeping for OFIRA LIMITED and other accounts it managed for James Gregory Ziegler (aka) Zig Ziegler and Van Brink (formerly known until 1998 as, Gilbert Allen Ziegler).

Today, VICTORIA CORPORATE SERVICES LTD. bank wire transfer records are held by a few individuals and agencies, details of which were obtained by the Offshore Informant [E-MAIL: ] after completing 4-years of investigations.

On October 16, 2000 e-mails between Mr. Olukayode Osunsan (aka) "Olu" of VICTORIA CORPORATE SERVICES LTD. - Information Technology with James Gregory Ziegler (aka) Zig Ziegler, brother of Van Brink, describing their collective ORIENT BANK LIMITED financial business relationship regarding wire transfers to facilitate money-laundering victim funds (see immediately below).

- - - -

-----Begin Original Message-----

From: "James Gregory Ziegler" (aka) Zig Ziegler"
Sent: October 16, 2000
To: "Olukayode Osunsan" (aka) "VICTORIA CORPORATE SERVICES LYD. - Information Technology"
Subject: Re: Wire Update

Sorry, bank clerk error, We did supply all of the information.

It may help in the future if we could supply the Uganda bank phone number also. If you supply it I'll get it on our standard form.

I have standardized forms for all wire requests that are handed to the bank clerk so that (he/she) has a no-brainer in front of them. Guess that still requires too much mental energy.

God Bless


-----End Original Message-----

-----Begin Original Message-----

From: "Olukayode Osunsan" (aka) "VICTORIA CORPORATE SERVICES LTD. - Information Technology"
Sent: October 16, 2000, 12:27 PM
To: "James Gregory Ziegler" (aka) Zig Ziegler"
Subject: Re: Wire Update

Hi Zig,

Thanks for you quick response, I talked to our local bank and they still need the missing detail.

To phone ORIENT BANK LIMITED in Uganda, dial:

TEL: + 256 41 236-012

Our local Bank here in Kampala, Uganda also confirms there is $10,000.00 (USD) in a suspense account, but cannot give it to us until you contact them and give them the following information where those funds are to be directed:

Beneficiary Acct No.: 010 10693 51

Please kindly coordinate this with your bank so it can be sorted out as soon as possible.



-----End Original Message-----

- - - -


The LAKE VICTORIA FREE TRADE ZONE is promoted by KAGERA ECO-CITIES LTD. owned by Gertrude N. Njuba and Beenunula Eyenunula Nunumisa.

The SSERULANDA DEVELOPMENT ASSOCIATION states objectives within it's Memorandum Of Association" (MOA), which amongst several plans, was to "pool financial, economic, human resources, and material by members of the company for the purpose of fostering financial, material, social, and spiritual growth and development of the members and their families."

According to their "Memorandum Of Association" (MOA), members must have a 'vegetarian diet', 'never cut down trees', or 'clear thickets' in the 'company area of operation', 'estates', and 'purposes', 'without permission from the company management', which is in keeping with the teachings of Jozzewafe Mugonza (aka) Bambi Baaba Mugonza (aka) His Imperishable Glory Bambi Baaba who combines Hindu, Buddhist, Sikh, and Bachwezi traditional practices in his version of spirituality.

Other practices mentioned in the "Memorandum Of Association" (MOA) include, common ownership of some assets for the "common good" such as land, kitchen, cattle corral, reference library, and burial grounds.

Though members are allowed to own some personal private property like houses, cars, radios, or television sets, they are all required to contribute to the events of the common good.

Anyone who fails to contribute will have his or her membership cancelled and forfeits his or her privileges without being allowed to seek legal action against the organization.

Who is Jozzewafe Mugonza (aka) Bambi Baaba Mugonza (aka) His Imperishable Glory Bambi Baaba?

Jozzewafe Mugonza wields unimaginable power among his followers who respect him and worship him as a God in the form of a man who is known as their "Living Master and Redeemer."

He was born on July 15, 1937 as the second child of Lozio Kulazikulabe and Flazia Nakanwagi of Lubumba village, Kabuwoko, Buddu County of then Masaka District.

According to his official biography "Bambi Baaba: Redeemer of the New Age," by Bhuka Bijumiro Jummiro, "Two big serpents appeared on the scene just as the baby (Mugonza) dropped from the mother’s womb, one of them resting under the delivering mother’s legs while the other on-looked on just beside."

Bijumiro-jjumiro writes that the presence of the serpents meant that the child would have great wisdom and divine healing powers.

Mugonza, whose formal education was only up to P-2, grew up to be a celebrated herbalist, diviner and healer, operating in Kyotera and Kalisizo in Rakai and later at Nateete, a suburb of Kampala in the 1960s.

He linked up with some Indian businessmen in Kyotera who sponsored him to travel to India in 1969 where he "went through the 12 stages of initiation and became a disciple" of what his followers call "a divine living Master of Ancient Wisdom."


In 1949, at the age of 12, Bambi Baaba Mugonza claimed he had received a vision of a cave on which to build a shrine as the centerpiece of a "Spiritual City of the New Age of Truth." On December 25, 1975 Mugonza found the cave in Sseesamirembe in Kabira sub-County Rakai District, and settled there with Ssentongo Dedembessa.

Bambi Baaba Mugonza then formed the SSERULANDA NSULO Y'OBULAMU SPIRITUAL FOUNDATION (aka) SSERULANDA FOUNTAIN OF LIFE SPIRITUAL FOUNDATION. The beginning was not easy. He faced a lot of opposition, especially from the established religious leaders, says Ssemyanjo, a founder member of SSERULANDA SPIRITUAL FOUNDATION.

With members who join, being required to hand over their earthly possessions, Bambi Baaba quickly gathered enough money to start buying land in the villages surrounding the cave.

In 1980, his lucky break came when he was joined by Ambrosio Mazinga, an astute businessman and Bjorn Simensen, a skilled steel processing manager to form ASTRAL ALANDA STEEL PRODUCTS which bought the shares of CAMAPAIGNIA, an Italian construction company that was closing operations in Kampala, Uganda. Bambi Baaba Mugonza persuaded the other directors to move the steel works industry to Sseesamirembe.

"The steel fabrication workshops, industrial carpentry and joinery, and grinding mills set up in Kabira Sub-county, attracted many workers and disciples and contributed to a thriving economy for the people in the surrounding villages," says Enos Mugisha, the LC3 Chairman of Kabira Sub-county.

Bambi Baaba Mugonza became well known as a New Age guru, and seekers from near and far started frequenting his mini-city.

During the mid to late 1980s, with more people settling in, the economic collapse of Uganda saw the Bambi Baaba Mugonza Empire collapse too.

In 1993, Beenunula Eyenunula Nunumisa (Governor of the LAKE VICTORIA FREE TRADE ZONE) and Bambi Baaba Mugonza both went to Fairfax, Virginia, USA. They attended the WORLD RELIGIOUS ASSEMBLY in New York, visited India, and then both returned to Fairfax, Virginia, USA where Jozzewafe Mugonza (aka) Bambi Baaba Mugonza (aka) His Imperishable Glory Bambi Baaba continued to live.

In his biography, Bambi Baaba Mugonza invited the BBC, VOA, Radio Canada, and other world media to come to Uganda saying, "It is certain that they will find a place where a very big Universal Spiritual City is to be built. Tell the Pope that a place for the generation of a spiritual consciousness has been discovered on the shores of Lake Victoria. I know of a very old monument, which is buried deep in Lake Victoria. It will be discovered by famous scientists when they come to discover a lost city, which I also know to be buried there. I think it is time for me to reveal this information to you so that the world may know that there is certainly a lost city below Lake Victoria. There is an area in southwestern Uganda called Sseesamirembe.

In October 1995, New York radio station WLIB host Imhotep Gary Byrd's live telephone call-in program "Global Black Experience" saw guest speaker Mr. Beenunula Eyenunula Nunumisa (later named, Governor of the LAKE VICTORIA FREE TRADE ZONE) address listeners, with:

"Since 1975, His Imperishable Glory (H.I.G.) [referring to, Bambi Baaba Mugonza] has developed this area from a small cave. His Imperishable Glory (H.I.G.) - with a few pioneers - started buying land. Today we have 30 square miles of land. And, it is this 30 square miles that His Imperishable Glory (H.I.G.) is inviting all planetary citizens to converge on Lake Victoria to build a new city, a peace city. We want to create a city where all the people of the World will not have to look for land on where to build their projects. But more importantly, the area around Lake Victoria - that 'cradle' of man - is a high cosmic 'vortex' so, His Imperishable Glory Bambi Baaba has explained that the process of building the Spiritual City will activate the cosmic energy that has been locked up in Africa and thus bring about a shift in the consciousness of the planet."


In 2004, Beenunula Eyenunula ("Ben") Nunumisa was managing director of a foreign currency exchange firm named FOREXAFRICA.COM Managing Director (E-MAIL: where he was responsible for the strategic planning of the company and lent his considerable expertise in making FOREXAFRICA.COM a primary conduit for foreign exchange trading in central and eastern Africa.

Beenunula Eyenunula ("Ben") Nunumisa was also a partner in SDC CAPITAL PARTNERS, a boutique investment bank that dealt in project and corporate finance, and structured derivative products.

Beenunula Eyenunula Nunumisa is the Chief Executive Officer (CEO), President, and founding board member of the LAKE VICTORIA FREE TRADE ZONE.

Beenunula Eyenunula Nunumisa holds a Bachelors of Science degree in Agriculture with honors from Makerere University (Kampala, Uganda), and a Masters degree in Finance from George Washington University (Washington D.C.).

Beenunula Eyenunula Nunumisa is the LAKE VICTORIA FREE TRADE ZONE Governor who oversees all registrations of companies, incorporations, entities, property, land, businesses, and vehicles handled through what are termed Registered Agent Companies (RACs) and Company and Trust Managements (CTMs) that are registered with the LAKE VICTORIA FREE TRADE ZONE.

On August 6, 2006 a Company and Trust Management (CTM) registered by LAKE VICTORIA FREE TRADE ZONE Governor Beenunula Eyenunula Nunumisa, was BRISK CONSULTANTS LTD.

Capital Building
Plot 16, Enterprise Road
Sseesamirembe City
TEL: +256 752 480098

In April 2004, a Company and Trust Management (CTM) registered by LAKE VICTORIA FREE TRADE ZONE Governor Beenunula Eyenunula Nunumisa named EURO TRUSTEE LTD. LVFTZ (c/o SOUTHPAC TRUST NEVIS LIMITED, Hunkins Plaza, Charlestown, Nevis, West Indies) for James Gregory Ziegler (aka) Zig Ziegler, brother of Uganda's most infamous American Van Brink, named as Trustee.

In April 2004, Ziegler had his wife named Ivanka Milanovic (nee Lekic) Ziegler (Smederevska Palanka, Serbia) and 'her daughter' (from a previous marriage) named Dragica Milanovic (Belgrade, Serbia) as directors of a Serbian company named CORPORATE TRUST AND MANAGEMENT SERVICES D.O.O. (Serbia) that saw LAKE VICTORIA FREE TRADE ZONE Governor Beenunula Eyenunula Nunumisa registered several LAKE VICTORIA FREE TRADE ZONE Company and Trust Managements (CTMs) for Ziegler's EURO TRUSTEE LTD. LVFTZ in the names, of:

CTM Building
Plot 1 Mweyanjale Lane
Rakai District

From 1997 through April 16, 2004 James Gregory Ziegler (aka) Zig Ziegler had seen thousands of financial fraud victims lose over $125,000,000.00 with over $41,000,000.00 in victim monies laundered through foreign attornies he and others hired to establish international business companies (IBCs), foreign Trusts, and foreign Trust bank accounts that sent money into bank accounts established by VICTORIA CORPORATE SERVICES LTD. (c/o COMNET SERVICES LTD., Diamond Trust Building, Kampala, Uganda), which pumped over $41,000,000.00 into multiple foreign currency exchange accounts handled by Mr. Beenunula Eyenunula Nunumisa in FOREXAFRICA.COM LTD., GCI CAPITAL LTD. [ TEL: (441) 296-2630 ], GLOBAL CAPITAL INVESTMENT LLC (aka) GCI LLC. [ Blair Baker, et al. at: 67 Wall Street, 22nd Floor, New York, New York 10005-3198, USA, TEL: (212) 248-3700, and at: 18 Thunder Lake Road, Wilton, Connecticut 06897, USA, using CITIBANK FSB (Greenwich, Connecticut) Account Number 47513014 ], et al., Beenunula Eyenunula Nunumisa business partners and their relatives, amongst several, named:



Stella N. Njuba (see immediately below).

On April 16, 2004 Stella N. Njuba (above) sent James Gregory Ziegler (aka) Zig Ziegler (Smederevska Palanka, Serbia) e-mailed Ziegler confirming funds, sent earlier on Ziegler's instructions to his foreign attorney Dr. Epifanio Vasquez Santos (El Batey, Sousa, Dominican Republic) out of a foreign Trust named GOLDEN AGE SERVICES LTD. from it's bank account at THE BANK OF NEVIS INTERNATIONAL LTD. (Charlestown, Nevis), and claimed as "Registration Fees" on behalf of the LAKE VICTORIA FREE TRADE ZONE for Ziegler's LAKE VICTORIA FREE TRADE ZONE CTM named EURO TRUSTEE LTD. LVFTZ whereby she facilitated Ziegler to launder victim funds into her own personally named bank account at BARCLAYS BANK OF UGANDA LTD., as follows:

- - - -


From: Stella N. Njuba
To: James Gregory Ziegler
Date: April 16, 2004


Please note that all fees charged by remitting bank are to be met by yourself, the sender.

Here please find the account on which to send your monies:

Send To:


For Further Credit To:


Bank Account Name: Stella N. Njuba
Bank Account No: 1397510

To add to the information I sent you yesterday, the Swift code is BARC UG KX and the clearing bank is Barclays PLC London. The Telephone number is 256 41 267207.

I am currently working on the training for the answering techniques as per your advice.

And below, is your new physical address in the LAKE VICTORIA FREE TRADE ZONE (LVFTZ):

CTM Building
Plot 1 Mweyanjale Lane
Rakai District



- - - -

At least five (5) days 'before' Van A. Brink - founder of the now defunct FIRST INTERNATIONAL BANK OF GRENADA LTD. international financial business system that saw 6,000 depositors lose over $125,000,000.00 (USD) - was arrested in Luzira, Uganda on May 28, 2004 his brother James Gregory Ziegler (aka) Zig Ziegler had already been instructed by Van Brink to carry on his existing business relationships with Beenunula Eyenunula Nunumisa in FOREXAFRICA.COM LTD., a foreign currency exchange business.

On May 23, 2004 Beenunula Eyenunula Nunumisa of FOREXAFRICA.COM LTD. began his indoctrination for James Gregory Ziegler (aka) Zig Ziegler at the behest of his brother Van Brink.

Ziegler sought to expand his then-current financial business frauds with Beenunula Eyenunula Nunumisa in many SEAGOLD.NET secure e-mail communications they continued to have, which sees an early depiction of such (immediately below).

- - - -

---------begin original message---------

From: "James Gregory Ziegler" (aka) "Zig Ziegler"
To: "Beenunula Eyenunula Nunumisa"
From: Beenunula
Subject: (no subject)
Date: May 23, 2003 wrote:

Hi Beenunula, or do you prefer Nunumisa? Or Mr. ??

I am Zig [James Gregory Ziegler (aka) Zig Ziegler], one of Van's [Van Arthur Brink, formerly Gilbert Allen Ziegler) two brothers.

I have worked with Van [Van Brink] off and on several times through life, and constantly since 1997.

I have developed a short list of potential investors, over and above the long list that Van works with.

Currently I am also assisting Van with some on his list.

Yes, I am very interested in learning from you and working with you.

Please bring me up to speed on how and what you offer, and how we could work together regarding referral fees.

I am currently establishing Trusts for people, include a free e-gold account, and an anonymous ATM debit card [ CASH CARDS INTERNATIONAL (Minneapolis, Minnesota) ] in the Trust price. Your product would make a very good addition to these Trusts.

If I could add the free frill of establishing an account with your firm for free to the Trust I think we could stir-up some excitement.

A few of the people on our combined lists have funds they could immediately invest. Who knows!

How could we work together on referral fees?

Thanks much


P.S. Just type in 'Platinum', when using your SEAGOLD.NET account, there is no need to type in the ''.

---------end original message---------

---------begin original message---------

From: "Beenunula Eyenunula Nunumisa"
To: "James Gregory Ziegler" (aka) "Zig Ziegler"
From: Beenunula
Subject: (no subject)
Date: May 23, 2003 wrote:

Dear Zig,

Just call me Beenunula.

Thank you for the opportunity of working together.

Responses to your inquiries follow below:

1.What we offer: In-house fund management services for clients. Smallest account: $10,000 no limit to size.

2. Trade following securities online 24-hours a day: FOREX, CFD (Contracts For Difference) on: stocks, stock indices, interest rate futures (Japanese 10-year-JGB, 10-year United States Note, 30-year United States Bond), gold, silver, wheat, sugar, cotton, coffee and cocoa.

3. We Offer clients a 60:50 (FOREXAFRICA.COM LTD. (FXA): 60%, Client: 40%) sharing on all new capital created every 3-months and in some cases on a monthly basis for larger accounts as the agreement may stipulate. There are no upfront account opening fees (save normal costs of wire transfers). All management, incentive, and other costs are covered in the FOREXAFRICA.COM LTD. (FXA) profit sharing portion of 50%.

4. Referral fees: 5% of the 60% received by FOREXAFRICA.COM LTD. FXA is paid to you (person that introduces the investor).

5. Accounts may be established in the strictest of confidence under a distinct new FOREXAFRICA.COM LTD. FXA account without the need for client to divulge sensitive personal info.

Please let me know if the above is clear and adequate.



---------end original message---------

- - - -

Contained in correspondences with the LAKE VICTORIA FREE TRADE ZONE LTD., the following information was discovered:

LVFTZ Authority Building
Plot 22, Enterprise Lane
Sseesamirembe, Rakai District
TEL: +256 41 501 269

AND, at:

Registrar Entities & Lands
Office Of The Deputy Governor
Plot 1467, Muyenga Road
Tank Hill
CONTACT: Gjuno Basensa Ssensulazza - Deputy Governor
TEL: +256 41 501 269
TEL: +256 71 712 271
FAX: +256 41 510 541

It is highly doubtful that General Salim Saleh (aka) Caleb Akandwanaho - with Van Brink as his very close personal financial business friend - did not know what the LAKE VICTORIA FREE TRADE ZONE money-laundering group was doing from 2000-2004, and until 2006 when he was appointed as the Uganda government Minister Of Microfinance by his step-brother who is Uganda President Museveni.

On December 10, 2005 Van Brink died in Wilsonville, Oregon but according to Brink before he died, General Saleh was actually charging him incredibly great monthly payments as extortion for Brink to receive the 'special security protection' General Saleh had afforded him since 2000, and when Brink could pay no more, 45-days thereafter Brink was arrested by Kampala, Uganda police forces and removed by the F.B.I.

When Brink died, his brother James Gregory Ziegler (aka) Zig Ziegler took over the financial business affairs of his brother's network, and now controls it with his iron fist today.

- - - -

References (below)'77IN2)%5E4%40%40%20%20%0A&Iz=%22)%22%5C%20%0A

Submitted by,

The Offshore Informant



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Free Trade Zone Money-Laundering Group 2000-2006

ECONIC 07.Aug.2006 14:10

Interesting overview (below), shows 'why' Uganda is a prime haven for money-laundering . . .

Also, sees mention of BARCLAYS BANK UGANDA LTD. (Kampala, Uganda), NILE BANK LTD. (Kampala, Uganda), and STANBIC BANK (Kampala, Uganda) positions, plus KAGERO-ECO CITIES CO. complaining - on behalf of the LAKE VICTORIA FREE TRADE ZONE (LVFTZ) - to the Uganda government about STANBIC bank not doing business with LVFTZ interalia KAGERA-ECO CITIES LTD.




Tackling Money Laundering in East and Southern Africa

An Overview of Capacity

In Uganda all sectors that are charged with detecting money laundering and activities that result in illicit proceeds are making increased efforts to combat money laundering.

However, these efforts are still hampered by the lack of law or policy specifically dealing with money laundering.

This is aggravated by the fact that money laundering is not a specific crime in Uganda.

To forestall the inadequacies in legislation, most financial and commercial institutions have put internal or sector measures in place to detect money laundering.

This has been possible largely because most of these institutions, such as the banks, have global linkages and thus benefit from the macro policies of their parent institutions.

The major multilateral banks all have internal systems developed by their main offices to be used by all their branches globally.

Others have developed specific policies for preventing money laundering in Africa, such as BARCLAYS BANK 2001 Africa Policy for the Prevention of Money Laundering.

This is based on the anti-money laundering legislation of the United Kingdom (UK) (Money Laundering Regulation, 1993) and European Union (EU) (section 2(2) of the European Money Laundering Directive).

The principle laws that have influenced the BARCLAYS Policy are from the UK, which includes:

- European Communities Act, 1972 [section 2(2)], under which the European Money Laundering Directive was implemented by member states including the UK;
- UK Money Laundering Regulation, 1993;
- UK Drug Trafficking Act, 1994;
- Criminal Justice Act 1988, as amended by the Criminal Justice Act, 1993;
- Criminal Justice (International Co-operation) Act 1990;
- Terrorism Act, 2000; and,
- Financial Services and Markets Act, 2000.

The lack of an appropriate legal framework in Uganda has made it impossible for the financial and commercial sectors to implement some of the measures that do exist.

For example, banks can only report suspicious transactions but are powerless to stop or freeze the transactions because they do not have legal protection.

Even the central bank (the Bank of Uganda, hereafter BoU) cannot do much when it comes to individual accounts unless the account holder is on the list of individuals under UN sanctions or is a listed terrorist as per UN Security Council Resolution 1373 of 28 September 2001.

In an attempt to develop a framework for combating money laundering in Uganda, the government, through its enforcement agencies under the co-ordination of the BoU, initiated a multi-institutional process to develop anti-money laundering policies and a legal framework.

The Uganda Anti-Money Laundering Committee (UAMLC) has been formed to spearhead the process.

The formation of this committee was motivated by the initiatives of the Commonwealth and the East and Southern Africa Anti-Money Laundering Group (ESAAMLG), of which Uganda is a member.

As the law-making progresses, the BoU developed anti-money laundering guidelines (hereafter the BoU Guidelines) in 2002 for banks and other financial institutions to guide them in establishing and maintaining specific policies and procedures to guard against the use of the financial system for money laundering.

Scope of this study

The overall objective of this study was to collect and synthesise information on the institutional and policy mechanisms that exist in Uganda, and their strength and weaknesses.

The study covered accountable institutions in Uganda, which were very difficult to identify as there is no legislation that defines them.

Using the list of 19 possible accountable institutions in Schedule 1 of the 'South African Financial Intelligence Centres Act' as a guide, people from the financial and banking sectors, legal and accountancy professions, foreign exchange - FOREX - dealers, couriers, regulators, and law enforcement agencies were consulted.

However, the major focus was on the financial and commercial sectors.

Institutional mechanisms to detect and control money-laundering and other illicit proceeds in Uganda

The success of anti-money laundering policy requires strong, efficient and committed multi-sector institutions. In Uganda, the relevant institutions were not working in partnership until recently.

The current institutions involved in combating money-laundering and related activities, include:

Capital Market Authority (CMA);
Directorate of Public Prosecution (DPP);
Uganda Communication Commission (UCC);
Uganda Revenue Authority (URA);
Department of Immigration;
External Security Organisation (ESO); and,
Internal Security Organisation (ISO).



Currently, commercial banks are required to report any transfer of $100,000 (USD) or more to BoU.

This is beginning to bear fruit as more and more financial institutions are reporting out-of-the-ordinary transactions.

Two [2] examples illustrate development:

- October 2000, STANDARD CHARTER BANK turned back a $40-million (USD) transaction when a sender attempted to wire transfer the money from Boston (USA) to Uganda.

- [No Date], POSTA UGANDA LTD. withheld and reported a transaction involving the transfer of hundreds of thousands of U.S. dollars by a Ugandan living in Japan. The matter was reported to police, which obtained a court injunction to withhold the transaction until it was investigated, however the transaction proceeded after investigations proved the money were an accident compensation award from insurance.

The Governor of BoU, in an address to the UGANDA FOREX BUREAUX ASSOCIATION (UFBA) - on the role of the Central Bank in combating financial crimes - said, that though the BoU will not target the exchange FOREX market, it would interfere in that (FOREX) market to ensure that appropriate action is taken against money launderers.

He stated that a lot of progress was made in 2001 in flushing out bicupuli4 dealers [ Kibanda (black market) trades in foreign exchange ] who target the foreign exchange (FOREX) market.

The BoU has developed draft anti-money laundering guidelines for the foreign exchange (FOREX) bureaux.

This new initiative is crucial because since 1993, Uganda has liberalised its exchange (FOREX) markets to the extent that there are now no checks at all.

The government wants to check money laundering to protect remittances from Ugandans living abroad, whose remittances nearly doubled from $400-million (USD) to $780-million (USD) in 2001.

With U.S. assistance, BoU is implementing a system allowing it to monitor its FOREX market, which grew from $2-billion (USD) in 2000 to US$2.4 billion in 2001 according to BoU, more effectively.

In its role as overseer and supervisor of the smaller banks, the BoU has acted hard against banks that do not follow its Guidelines, regulations and banking norms, as well as against those that are lax on money laundering.

From 1999 to date, numerous banks have been shut down due to either insolvency or clandestine transactions, in an effort by the BoU to paralyse the money laundering process.

One of the most well-known examples is the collapse and closure of the INTERNATIONAL CREDIT BANK, which was notorious in Uganda for money laundering.

Another highly suspicious bank that was closed down was the GREENLAND BANK.


Internal and External Security Organisations

The ISO and ESO are specialised security agencies, with special training and skills to handle national security matters from both inside and outside Uganda.

The two [2] agencies have created special units to deal with terrorism.

The counter-terrorism sections handle drug trafficking and money laundering activities.

ISO became active against money-laundering and drug trafficking upon getting information that the ALLIED DEMOCRATIC FRONT (ADF) rebels were using the trade to raise money for their rebellion.

ISO’s efforts were foiled by the officers put in charge of counter-terrorism who started collaborating with the traffickers. What exposed the officers was that their activities were not coordinated with ANU, which led the ANU to suspect ISO of aiding the traffickers.

According to the police, the ANU started tracking some ISO officers in 1997 and considered them accomplices to the drug trade.

The ANU suspicions were not unfounded as they discovered the leader of the drug racket was a girlfriend of one of the ISO bosses who was arrested in 2001 for aiding the traffickers.

In February 2002, the head ISO at Entebbe Airport was arrested along with other security personnel for reportedly aiding the traffickers.


Fiscal Authorities (URA and Department of Immigration)

The intervention of the fiscal authorities - like the financial institutions - is generally confined to detecting and tracking suspicious activities and transactions and reporting them to the financial regulator (the BoU).

The Department of Immigration is responsible for checking and controlling movements of people into and out of Uganda. They are therefore very crucial in fighting against money laundering, but the Department was penetrated by traffickers.

Following the arrest of the head of the ISO at Entebbe Airport in February 2002, according to the Inspector General of Police, traffickers used the VIP Area at Entebbe Airport where they 'did not undergo security checks', which later led to changes in Airport security management with the appointment of an 'aide to the President' as the person-in-charge of Entebbe Airport security.

Immigration officials helped foreign and local criminal gangs get Ugandan passports.

This led to the arrest of Uganda senior passport officials in July 2002 with several forged passports in their possession. According to the former (until January 2003) head of police force fraud, police investigated this passport racket after receiving an information tip.

URA set up a Special Revenue Protection Unit to deal with money laundering and other organized crimes, and plans to train its staff appropriately.

The Unit is responsible for tracking 'tax evaders' and 'organized crime' activities, which led to a number of arrests, but also revealed some URA officials who were collaborating.

Officials in the URA taxpayers department were suspended and detained for conniving with crooked exporters to make fictitious claims, leading to the loss of an estimated $14-million (USD) between September 2000 and December 2001.

This led to setting up a Commission to probe URA operations whose findings have not yet been made public.

The head of URA taxpayers department was charged with fraud in July 2002, and the case is still under way.


Other Institutions and Professions

The success of any anti-money laundering policy requires the commitment of all involved legislators, regulators, enforcement agencies and the financial sector, who should forge a partnership among themselves.

Professions and businesses dealing in cash, such as casinos, lawyers, notaries and accountants, are not yet required by law to detect money laundering or report any suspicion thereof in Uganda.

The professionals spoken to, were largely ignorant about money laundering, and those who do know something about it did not see it as a big problem in Uganda today.

A professional respondent cynically remarked:

"It is illicit money which forms a foundation for the development in the Western world," such as proceeds from slave trade, gold, ivory etc. from Africa, "spices from India and war bounties from conquered people."

Factors that expose the financial, commercial and other sectors’ money laundering and other illicit proceeds

According to executive director of operations Mr J K Wanderema-Nangai at BoU, "Implementing BoU anti-money laundering guidelines and other measures depend very much on the cooperation and determination of the banks and other financial institutions since guidelines are not backed by law."

That statement summarises Uganda’s dilemma:

Without an adequate legislative framework, the anti-money laundering measures being put in place cannot effectively deal with the problem.

The absence of legislation combined with other factors such as poor recordkeeping, lack of technical know-how, lack of staff, and amongst others, competition between institutions to expose financial and commercial sectors to money laundering and other illicit activities.

Lack of Legislation

Uganda 'does not currently have a specific law against money laundering', which is not an offence.

According to the Inspector General of Police, this has made Uganda a 'major conduit for drug traffickers and money launderers'.

The lack of legislation is particularly a very difficult problem for institutions that have attempted to adopt anti-money laundering measures in their operation, whose efforts have been made impotent.

Bank employees are exposed to danger as the people who launder money often either 'buy-off' or 'threaten to kill anybody' hinderong their business.

Bankers, lawyers, and accountants who in one way or another come across money laundering in the ordinary course of their work are vulnerable and impotent in the absence of an adequate legislative framework.

The weaknesses of the current legislative situation was clearly exposed in the POSTA UGANDA LTD. case when lack of legislation meant it could 'only temporarily delay' suspicious payment from Japan and report the matter to the police, who in-turn, did nothing until a court injunction halted payment while completing their investigation.

Bank Confidentiality Requirements

Bank operations are governed by confidentiality rules.

They are thus exposed to the risk of lawsuits and of loss of trust if they breach confidentiality by reporting customers' whose identity is then revealed.

Bankers argue that banking is first and foremost a business and that anti-money laundering measures such as KYC sometimes scare off potential or existing customers.

This is a short-term problem for the banks, though reputable banks are willing to take this risk as they believe there will be long-term benefits for their efforts.

According to the legal and compliance manager of STANBIC bank, although STANBIC has anti-money laundering policies and rules in place they have trained staff in how to use them but without revealing what they are aimed at because they fear the staff may not use them or that they may scare off customers.

There is therefore hesitancy within the Uganda financial sector on the best means to deal with money laundering.

In some instances, banks are suspicious of certain kinds of activities, but may fail to enforce appropriate measures because fear of losing their customers.

There is a need to review confidentiality laws in Uganda with a view to removing confidentiality impediments or giving legal protection to banks who breach confidentiality as part of implementing anti-money laundering policy.


Failure to Know Customers

Some financial institutions, especially those that are not banks, cannot know their customers because they operate without accounts.

In most cases they conduct once-off transactions.

The financial institutions most affected by this include FOREX bureaus, where transactions take place at the counter and no record or identity of the customer is kept.

Cash receipts are issued, which are used by the BoU Research Department to assess foreign (FOREX) exchange flow.

The postal and courier services also have a similar problem.

Poor Recordkeeping

In most of the financial institutions there are either 'no records at all' that can help in monitoring transactions and tracking cases of money laundering, or 'records poorly kept'.

This is especially true with FOREX bureaus:

The nature of their (FOREX bureau0 operations means that records about customers are not kept.

In an attempt to tighten the loose ends, in the fight against money laundering, BoU and banks have adopted some unpopular methods regarding FOREX bureau operations.

BARCLAYS BANK OF UGANDA LTD. announced it had stopped FOREX bureaus from doing 'telegraphic transfers through the bank'.

This followed a directive from the BoU and resolution of the UBA.

Other banks have followed suit.


Problem of Cash Economy

According NILE BANK LTD. risk and compliance director Mr. M. Rugadya, Ugandans prefer using cash for all forms of transactions - including the purchase of high-value items such as real estate and motor vehicles - because of a lack of trust and a fear that checks will bounce. This makes detecting the source of money difficult.

The widespread use of cash rather than other means of exchange is perhaps the biggest handicap to detecting and controlling money laundering.

Banks and other stakeholders find it impossible to trace the origin of cash in Uganda as people refuse check payments, even when transactions involve millions of Uganda shillings.

Buyers go to their banks, withdraw cash, and pay for all kinds of transactions in this way.

The problem of a cash economy has curtailed banks’ ability to distinguish between ‘clean’ and ‘dirty’ money.

Banks rely on the information customers provide, which may or may not be accurate, as customers fear that such information may be given to URA tax department for evaluation.

The prevalence of the cash economy undermines the fight against money laundering and makes it difficult to detect when money laundering is taking place.

The vast majority of Ugandans do not hold bank accounts and conduct their business only on a cash basis, making regulation difficult.

All financial sector interviewees believed that for anti-money laundering measures to succeed, the Uganda government has to assist the financial sector in 'sensitizing the public' about dangers money laundering poses to individuals and the economy, informing the public on how they can contribute to fighting it, and allaying fears that information given to the financial sector would be passed on to the URA tax department.


- - - -





International Narcotics Control Strategy Report

Released March 2003 by, the:

Bureau for International Narcotics and Law Enforcement Affairs

Money Laundering and Financial Crimes


Office of Technical Assistance (OTA)

OTA is located within the Office of the Assistant Secretary for International Affairs in the U.S. Treasury Department.

OTA delivers interactive, advisor-based assistance to senior level representatives in various ministries and central banks in the areas of tax reform, government debt issuance and management, budget policy and management, financial institution reform, and more recently, law enforcement reforms related to money laundering and other financial crimes.


In 1997, the Enforcement Program was added to the OTA Advisory Office.

The OTA Enforcement Program is a long-term, advisor-based program developed out of concern that financial crime, corruption, organized criminal enterprises, and other criminal activities undermine economic reforms promoted by the U.S. Government (USG).

The OTA Enforcement Program focuses on the development of legal foundations, policies, and organizations in three [3] areas:

(1) Money Laundering, Terrorist Financing, and other Financial Crimes;

(2) Organized Crime, and Corruption; and,

(3) Reorganization of Law Enforcement and Financial Entities in developing economies to help them prevent, detect, investigate, and prosecute 'complex international financial crime'.

The Enforcement Program relies on 'intermittent advisors' and 'resident advisors' to deliver it's technical assistance.

It works with embassy staff, and host country clients, on long-term projects designed to promote systemic changes and new organizational structures.

The Enforcement Program receives funding from:

- U.S. State Department 'Bureau for International Narcotics and Law Enforcement Affairs' (INL);

- U.S. State Department - Africa Bureau;

- USAID country Missions; and,

- U.S. Congressional direct appropriations.

The Enforcement Program group is comprised of approximately 50 experienced advisors with backgrounds in various areas of 'investigating', 'prosecuting' or 'regulating' financial and economic crimes such as money-laundering, terrorist financing, white-collar crime, organized crime, securities fraud, internal affairs and corruption, criminal law, and organization administration.

In 2002, Enforcement Program advisors provided assistance to the governments of:

Eastern Caribbean countries
El Salvador
South Africa

OTA conducted several assessments of anti-money laundering regimes in 2002, often working in concert with U.S. Embassies and/or international bodies.

These assessments addressed legislative, regulatory, law enforcement, and judicial components of the various programs.

The assessments included the development of technical assistance plans to enhance country efforts to fight money laundering and terrorist financing.

In 2002, such assessments were carried out in:

Burkina Faso




An assessment trip to Kampala, Uganda took place in July 2002.

Since then, the Uganda enforcement team completed two [2] additional work trips.

OTA is working with a 'governmental interagency group' establishing financial crimes and anti-money laundering policy, procedures, and laws.

Work has begun on 'drafting a law to criminalize money laundering'.

The enforcement team is also working closely with the other Uganda OTA advisors, who work in the Central Bank and in the Capital Markets Authority, to coordinate efforts to strengthen the government’s ability to properly supervise financial institutions and markets, and with the IGG (Inspector General for the Government) on strengthening anti-corruption capacity.


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