Edline E. Murungi is a Legal Counsel of Yellow Card Financial. Yellow Card is a cryptocurrency exchange platform that allows users to buy and sell safely at the best rates in over 13 countries in Africa, using their local currency.

Monetix partner in Uganda - CapitalSavvy launched the Blockchain Innovation Program in Uganda, on September 2, 2022. Murungi was one of the panelists. The program aims to enlighten and empower the country with the application of Blockchain. She emphasized that blockchain is a technology, while cryptocurrency and other virtual assets are just a few of its use cases.

The legality of Virtual Assets and Cryptocurrency in the country are considered as accountable persons.  

"There is no specific regulation on virtual assets in Uganda. However there is a regulation that governs virtual assets in terms of as accountable persons and this is specifically for the Anti-Money Laundering laws". - Edline E. Murungi

In 2020, the Financial Intelligence Authority (FIA) required all Virtual Asset Service Providers to comply with all the legal requirements in the Anti-Money Laundering Act, 2013 (as amended).

"All Virtual Asset Service Providers are therefore required to register with the Financial Intelligence Authority as accountable persons within 30 days from the day of publication of the Instrument in the National Gazette." - Financial Intelligence Authority
Watch the Full Statements Here. Video extracted from the BIP Livestream

Murungi made it clear that what is unregulated is not necessarily illegal.

"There is a difference between illegality and something that is not unregulated. And when I say unregulated I mean in terms of the general law or a specific law." -Edline E. Murungi

Cryptocurrency or Virtual Asset service providers like banks, accountants lawyers, NGOs, or anyone who provides financial services and financial advisory are accountable persons under the Anti-Money Laundering Law. These entities are required to register and provide annual compliance reporting. She added.

Murungi thinks that what they have in the country are Soft laws, which are essential things that regulators or people in the industry released verbally or in form of writing, but are not actually laws.

" I think the first secular we saw officially from the minister of finance was, it's not illegal But deal with cryptocurrency at your own risk" - Edline E. Murungi

In Uganda, most fintech is governed by Mobile Money Guidelines and the NPS National Payment Systems Policy for Uganda aims to promote the safety and efficiency of payment systems in the country, with a view to fostering financial sector stability and economic growth.

Fintech cryptocurrency virtual service providers are usually in the technology space. The country currently has, is the secular from BoU, specifically cryptocurrency, But not the blockchain. Therefore, the application of blockchain technology can be explored to solve any use case that it may serve.

"The limitation right now is the conversion of mobile money to currency. Blockchain is still unregulated but NOT illegal". - Edline E. Murungi
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