IMMACULATE NALUBEGA
Kampala
Summary
Dynamic compliance professional with extensive experience at Jubilee Life Insurance Company, recognized for enhancing compliance levels significantly. Expert in anti-money laundering and risk assessment, I excel in policy formulation and team leadership, driving impactful training programs that foster a culture of compliance and operational excellence.
Overview
16
16
years of professional experience
1
1
Certification
Work History
Assistant Manager – Compliance, Money Laundering Control Officer (MLCO), Data Protection Officer (DPO)
Jubilee Life Insurance Company of Uganda Limited
Kampala
11.2022 - Current
- Act as a liaison between the company and the different regulators that oversee the existence and operations of the company, disseminating all regulatory information to stakeholders, and attending regulatory engagements for the industry.
- The dissemination of information and updates regarding regulatory modifications, heightened risk awareness, instruction, concerns about compliance, and guidance to all departments within the company to attain optimal compliance levels.
- Enforcing internal controls throughout the organization and adhering to all external regulations.
- In charge of upholding moral principles and legal compliance in the company's business operations, preserving a good reputation, and cooperating with internal and external stakeholders to reduce the likelihood of legal action, penalties, and regulatory scrutiny.
- Establishing compliance rules, such as AML/CTF, and carrying out regular reviews and audits will guarantee that all compliance protocols are being followed by the requirements and SLAs and that any vulnerabilities or risks are found and addressed promptly.
- Verification of compliance with internal operational policies and systems of control by each business line and support function to ensure compliance with insurance and other applicable laws and regulations.
- Develop and put into action enhancements for compliance standard monitoring, communication, and enforcement.
- Make sure to review Suspicious Activity Reports (SARs) and disclose any necessary information about them.
- Streamlining compliance procedures and instruments across the entire company, including its branches.
- Keeping an eye on how the authorities are handling requests and making sure that concerns are resolved quickly.
- Ensuring prompt filing of all necessary regulatory reports and reporting policy/compliance violations to the appropriate regulatory agencies.
- Evaluate and carry out all board directives, and make sure management and the Board are informed on the company's compliance risk using thorough ad hoc, monthly, quarterly, and yearly status reports.
- KYC and AML Compliance
- Enforce the creation and application of process manuals and provide frequent updates on their progress.
- Stay updated with regulatory changes that affect the firm and outside of it, along with the best practices for compliance management that are always changing.
- Keep an eye on the Compliance team and make sure the annual performance cycle is followed correctly.
- Organizing and assessing every business procedure to detect and reduce any possible hazards.
- Reports on Compliance with the Annual Work Plan
- Employee education and awareness of all aspects of compliance; make sure employees understand the purpose and goals of compliance as well as their duties as outlined in the compliance procedure manual.
- Maintain a register of compliance breaches containing information on the date, nature, and extent of each compliance breach.
- In conjunction with the IT team, I spearheaded the development of the XML file that reports suspicious transactions to the FIA through the goAML system.
- Leading the KYC awareness program for employees, agents, and other company stakeholders, my goal is to increase compliance with the mandatory KYC that is collected from customers during onboarding.
- I received a formal compliment on behalf of the company from the Insurance Regulatory Authority of Uganda for the improvement noted in the AML controls implemented compared to other players in the sector.
- I recently carried out the company-wide AML/CFT risk assessment, the first of its kind by the company. This was also submitted to the FIA, from which we received applause.
- I have successfully resolved all 22 audit concerns that were found during the independent AML audits that regulators and external auditors carried out in August 2022. This entails sanction screening of current clients, acquiring business entities' ultimate beneficial ownership information, and putting customer risk profiling control into practice.
- Additionally, I have created and initiated a program to educate company stakeholders about the norms and requirements of the Data Protection and Privacy Act. I have also designated champions for data privacy.
- I designed the customer service charter and monitored vendors’ Service Level Agreements.
- I have also developed and implemented both the Data privacy notice and data consent forms for all business segments of customers and carried out the processes and systems data protection impact assessments.
- Oversee the inspection of the company’s compliance program by the Financial Intelligence Authority and Insurance Regulatory Authority.
- Developed data protection and data processing agreements for third parties that handle company’s personal data.
- Championed the development and implementation of the customer AML risk profiling automation project.
- Spearheaded the first ever Data protection compliance check in conjunction with Ernst & Young in which the company scored a rating of 'greatly compliant'.
AML Senior Associate- Anti-Money Laundering (AML) - Risk Assurance
FORVIS MAZARS
01.2022 - 11.2022
- Ensure regular review of AML/CFT policy and procedures as per applicable laws, regulations, and circulars for guidance and interaction with clients.
- Ensure compliance within the team with Mazar’s policies and quality/performance standards.
- Function as an AML/CFT subject matter expert and provide valuable knowledge and expertise as well as adequate solutions to Mazars clients’ issues or concerns as part of their AML/CFT activities, obligations, and requirements.
- Prepare, review, and/or remediate clients’ KYC files as per the agreed timeline and undertake compliance verifications and screening as per AML/CFT requirements.
- Work as part of the team and assist in anti-money laundering and counter-financing terrorism (“AML/CFT”) client assignments or projects.
- Support clients for the AML/CFT reports as per regulatory requirements.
- Provide AML/CFT training and workshops as per clients’ specificities as directed by the Managing partner.
- Support the development and update of AML/CFT training materials (incl. e-learning modules) as per regulatory requirements.
- Monitor new laws and regulations and provide impact assessments of any changes in the Uganda regulatory environment related to AML/CFT.
- Ensure a high quality of work focused on client experience and client satisfaction.
- Develop your AML/CFT competencies and experience and maintain an awareness of business and market trends.
- Contribute to the development of client services as well as in the creation of business opportunities and assist in the preparation of proposals and presentations.
- Support other lines of services as appropriate and necessary.
- I spearheaded the onboarding of Sportech as the first AML/CFT client of the firm, developing their firm-wide Risk Assessment.
- I am the Money Laundering Control Officer for the firm and have developed the Mazars AML program including the development of internal policies and procedures, training program, and firm-wide risk assessment.
- Carried out a sectoral risk assessment for the accounting sector of Rwanda on behalf of the sector supervisor – Institute of Certified Public Accountants of Rwanda (ICPAR).
- Designed the practitioners’ risk assessment methodology on behalf of ICPAR.
- Carried out periodic AML/CFT independent audits for Excel Insurance and Marsh Insurance Brokers.
Anti-Money Laundering and Risk Officer (Mobile Money Department)
Lycamobile Uganda
08.2021 - 01.2022
- Handling the management and execution of Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) programs.
- Designing and periodically updating the Lycamobile internal agent and customer onboarding policies with reference to AML/CFT regulations.
- Developing internal policies relating to AML/CFT, Mobile Money Risk Management and overseeing the continuous development of the company Risk Register.
- Developing AML guidance materials, training resources, and controls as per industry requirements.
- Identify and inform of any changes to legislation and other regulatory requirements relating to AML/CTF.
- Ensure timely submission of AML/CFT reports to the Financial Intelligence Authority, Bank of Uganda and Lycamobile senior management as and when required.
- Identify any AML/CTF loopholes and coordinate projects to bridge those gaps.
- Handle file reviews of suspicious activity to ensure compliance with the Mobile Money policies and governing procedures.
- Aid in preparing for impending regulatory changes or revisions to licensing structure.
- Report results of reviews of AML/CFT risk assessments, imminent breaches and monitor remedial proceedings to management.
- Maintain a proper register of Mobile Money related incidents reported internally and externally.
- Collaborate with local and international stakeholders in matters to do with AML/CFT research and understand changes in regulation.
- Advise Lycamobile senior management of any likely implications of changes to internal policies impacting AML/CFT regulations.
- Conduct due periodic diligence reviews on the entire Mobile Money ecosystem including customers and sales agents.
- Aid in the improvement of tools to monitor, analyze, and report Mobile Money suspicious activity.
- Identify, investigate, and report all Mobile Money activities that are deemed non-compliant.
- AML training sessions for internal and external customers.
- Address issues relating to Mobile Money transaction monitoring, filtering, and sanctions.
- Developed the organization’s AML/CFT policy.
- Developed AML training materials for Agents and staff.
- Developed the organization’s AML risk control framework.
- Developed the organization’s Risk Assessment policy.
- Undertook regulatory compliance reviews of the AML and Data protection and Privacy laws.
- Developed policies and procedures on fraud, whistleblowing, AML controls.
Risk Officer (Risk Department)
Bank of Africa - Uganda
11.2020 - 08.2021
- Assist the Head of Risk, to develop, maintain, monitor, and update an Operational risk policy and ensure that it consistently reflects the Bank’s approach to Operational risk management.
- Carry out fraud investigations and make recommendations to management and Audit.
- Contribute to the institution’s maintenance of a risk awareness culture by educating staff on the operational risks inherent in their roles and responsibilities.
- Identify and monitor key risk indicators in the bank’s day-to-day activities and report on them to provide insight into the bank’s risk exposure.
- Manage incident/event/loss reporting and conduct regular Branch visits to snap-check key controls following an audit program.
- Preparation of monthly Operational Risk report to the management Risk and Compliance committee.
- Prepare Risk Event, Operation loss, and control chart reports.
- Develop and maintain an operational risk register to enable the Bank to Understand its Operational Risk report.
- Conduct Risk and control self-assessments along with business Processes.
- Reviews to identify risk in the overall business process and propose Control/ mitigating strategies.
- Attend the UBA fraud committee and summarize observations for Bank of Africa management.
- Spearheaded the re-formulation of the Bank's Risk Register for the year 2021 by conducting the required Risk Control Self Assessments for Bank processes and procedures.
- Undertook system checks and reviews and re-aligned staff access rights.
Compliance Officer (Compliance Department)
Bank of Africa - Uganda
03.2017 - 10.2020
- Advising business on compliance-related matters in day-to-day operations. Including providing solutions to business requirements to ensure continued business growth and success while adhering to regulatory and corporate requirements.
- Periodically, undertake reviews, and tests on bank control processes and policies, where necessary develop action plans to address control deficiencies or gaps identified to ensure compliance with prevailing legislations across all departments of the bank.
- Act as a primary point of contact and driver of compliance knowledge, awareness, and implementation by employees to the fullest extent.
- In liaison with the Executive Assistant, regularly organize and conduct committee meetings to discuss, and update compliance and non-compliance issues.
- Conduct compliance risk tests on various bank products and services and implement appropriate management techniques to ensure compliance.
- The team led the team in doing a continuous follow-up on non-compliance Audit issues, ensured corrective actions were taken, and advised management appropriately.
- As a training champion, organized and facilitated compliance AML training across the bank network and empowered staff in AML monitoring and reporting.
- Managed all databases and filed compliance investigative reports to the Head of Compliance, Management, Bank of Uganda, Financial Intelligence Authority, and other regulatory and oversight bodies.
- Managed correspondence with other Financial Institutions and regulatory bodies such as BOU, URA, FIA, and NSSF on all due diligence and compliance requests.
- Compiled and submitted transactional reports such as those of Western Union, MoneyGram (monthly), Suspicious Transactions (as and when), and Large Cash Transactional Reports to FIA every week.
- Daily in line with both the local and international sanctions, updated both local and international blacklists to ensure compliance.
- As and when required, did a timely review of the bank’s new products and services to ensure compliance with prevailing standards and laws before management approval and sign-off.
- Co-ordinate, analyzed, prepared, and submitted monthly activity reports to the Group Inspection team, Management Risk, and Compliance.
- In liaison with the branch operations and Project teams, I oversaw the customer data update project in compliance with the Deposit Protection Fund directive to have all Ugandan National clients’ identification corrected to National IDs and updated on their files and in the core banking system.
- Intercepted laundered funds received on clients’ accounts and reported transactions to the FIA which saved the bank from losing UGX 700M to the Launderer and regulatory fines.
- Conducted the project of reviewing and updating credit files to streamline KYC on file before extending loans, in this over thirty accounts’ documents were corrected thus saving the bank from further extension of loans to poorly documented client files.
- Participated in the risk profiling of clients’ accounts (high, medium, and low risks) thus helping management put in place proper monitoring systems for the different risk levels.
Banking Officer (Global Operations/Trade Finance)
Bank of Africa - Uganda
01.2015 - 02.2017
- I put effort into performing trade services-related tasks in the following roles while working in coordination with the Treasury back office.
- Took charge of receiving, verifying, posting, and swift input of outgoing customer Telegraphic Transfers and Real Time Gross Settlement instructions.
- Led the team in daily initiation and processing of incoming funds transfers through Straight Through Processing (STP).
- I managed customer and interbank trade deals and did monthly reconciliation of Nostro accounts.
- I was tasked with receiving and handling customer trade service queries and monitored turnaround time (TAT) for smooth and timely service delivery.
- Monitored customer documentation availed for trade services to ensure proper KYC.
- Championed the achievement of three STP awards from Citibank with a score of 100% for both incoming and outgoing funds transfers.
- Participated in the streamlining and strengthening of client relations through my tireless follow-ups on clients’ requests, queries, and timely procession of customer instructions.
Banking Officer/Teller/Customer Service (Branch Operations)
Bank of Africa - Uganda
02.2012 - 12.2014
- Oversaw the branch team's cash handling, customer support, and bank product cross-selling. I created snap checks and reports on branch operations on a daily, weekly, and monthly basis.
- Observing and maintaining branch cash and vault limits.
- Handling forex transactions and money transfers like EFTs.
- Marketing and building relationships.
- Handling customer needs and queries.
- Processing salaries as per client’s requests.
- Verifying and posting both outward and inward customer cheques.
- Account opening, handling petty cash, refilling the ATM.
- Following up on bounced cheques, posting, and informing affected clients.
- Reconciling branch internal accounts on a daily, weekly, and monthly basis.
Collections and recoveries officer (Credit department)
Barclays Bank - Uganda
01.2011 - 01.2012
- Collected funds from loan customers.
- Made field visits.
- Maintained good bank-customer relations.
- Wrote and sent demand notices/letters to the bank’s debtors.
- Participated in reducing the bank’s bad debts to a tune of 35% between 2011 and 2012 thus improving the bank’s loan portfolio.
- Recovered credit funds worth 3.8bn in my one-year portfolio which in turn contributed to the bank’s profits.
Change and Performance Officer
Barclays Bank - Uganda
09.2010 - 01.2011
- Performed customer due and advanced diligence.
- Validated and authorized customer information.
- Performed system and physical cheques of customer files.
- Generated daily management information reports.
- Oversaw the bank’s clients’ information system upgrade project as instructed by the Bank of Uganda and saved the bank a penalty of UGX 5bn.
Compliance Officer
Barclays Bank - Uganda
02.2010 - 10.2010
- Compiled daily, weekly, and monthly AML reports.
- Performed customer due and advanced diligence.
- Managed both customer and employee queries.
- Trained both customers and employees about bank policies.
- Timely resolution of suspicious transaction issues.
Education
Bachelor of Entrepreneurship and Small Business Management - Kampala
Makerere University
Kampala01.2011
Uganda Advanced Certificate of Education (UACE) - Namugongo
Naalya Senior Secondary School Namugongo
Namugongo01.2007
Uganda Certificate of Education - Bweyogerere
Naalya Senior Secondary School Bweyogerere
Bweyogerere01.2005
Skills
- Policies review
- Regulatory compliance
- Anti-money laundering (AML)
- Risk assessment
- Data protection
- Internal controls
- Compliance training
- Relationship management
- Process improvement
- Policy formulation
- Effective communication
- Detail orientation
- Problem solving
- Team leadership
- Strategic planning
- Policy enforcement
- Consulting
- Workload management
- Orientation and training
- Project management
- Employee engagement
- Adaptability and flexibility
- Financial reporting
- Operations management
- Workplace safety compliance
- Customer service and satisfaction
- Negotiation
- Conflict resolution
- Reporting and documenting
- Record keeping
- Customer Query handling
- Know Your Customer (KYC)
- Advice on Key Audit findings
- Interpersonal skills
- IT skills
- Creative thinking
Certification
- 09/01/10 to 10/31/10, Certificate in Public Speaking, Makerere University Business School, Kampala, Public Speaking
- 02/01/21, Enterprise Risk Management for Financial Institutions, the Uganda Institute of Banking and Financial Services, enterprise risk management
- 02/01/24, the Sales Mindset for Peak Performance, Insurance Training College, Professional Sales
- 11/01/24, Anti-Money Laundering and Combating Terrorism Financing, Insurance Training College, anti-money laundering controls in the insurance sector
- 11/01/24, completed the Senior Leadership Program, Strathmore University, business management skills
Personal Information
- Date of Birth: 08/21/88
- Gender: Female
- Nationality: Ugandan
- Marital Status: Single
Languages
- English, Fluently spoken and written
- Luganda, Fluently spoken and written
- Lusoga, Good enough to make myself understood
- Lunyankole/Lukiga, Fairly understood but not spoken
Awards
Currently pursuing a course in Certified Anti-Money Laundering Specialist (CAMS) and a master’s degree in business administration at UNICAF University, Zambia.
References
- Mrs. Irene B. Bagenda, Legal Manager, Jubilee Life Insurance Company of Uganda Ltd, irene.bagenda@jubileeuganda.com, +256752 985758
- Mr. Emmanuel Epedu, Manager Trade Finance, Bank of Africa, epedu.emmanuel@boauganda.com, +256 772 590695
- Mr. John Bosco Turyaheebwa, Head of Audit, Bank of Africa, bosco.turyaheebwa@boauganda.com, +256 772 513379
Extracurricular Activities
Participating in public debates Reading business magazines Adventuring and Travel Working in teams to achieve big Reaching out to people with different concerns
Home
+256 701043357
Leadership Positions
- Currently overseeing the company’s Compliance department and both the Anti-Money Laundering and Data Protection compliance programs.
- At Bank of Africa as the substantive assistant to the head of compliance, oversaw the entire team when she was not there, spoke on her behalf in management meetings, handled requests and inquiries from third parties and correspondents, reviewed policies, and gave management advice on various risk and compliance controls.
- Throughout tenure in Compliance, oversaw two other department officers whose work directly contributed to several management and regulatory reports submitted on a weekly, monthly, and quarterly basis.
- Worked as the branch manager's assistant, supervising all branch operations when he was away, ran weekly meetings, carried out branch snap checks, turned in reports, visited clients, and handled challenging consumer inquiries.
- In the Compliance division, served as a Regulatory Compliance champion especially for AML aspects, AML training champion, and department meetings and training champion.
Affiliations
I am the treasurer of the Risk and Compliance sub-association in the insurance industry in Uganda
Accomplishments
I was awarded the CEO/Board award in the year 2024 in recognition of my impact on the overall performance of the company, which has seen its compliance levels significantly improve in the past two years of my service
Languages
English
First Language
References
References available upon request.
Timeline
Assistant Manager – Compliance, Money Laundering Control Officer (MLCO), Data Protection Officer (DPO)
Jubilee Life Insurance Company of Uganda Limited
11.2022 - Current
AML Senior Associate- Anti-Money Laundering (AML) - Risk Assurance
FORVIS MAZARS
01.2022 - 11.2022
Anti-Money Laundering and Risk Officer (Mobile Money Department)
Lycamobile Uganda
08.2021 - 01.2022
Risk Officer (Risk Department)
Bank of Africa - Uganda
11.2020 - 08.2021
Compliance Officer (Compliance Department)
Bank of Africa - Uganda
03.2017 - 10.2020
Banking Officer (Global Operations/Trade Finance)
Bank of Africa - Uganda
01.2015 - 02.2017
Banking Officer/Teller/Customer Service (Branch Operations)
Bank of Africa - Uganda
02.2012 - 12.2014
Collections and recoveries officer (Credit department)
Barclays Bank - Uganda
01.2011 - 01.2012
Change and Performance Officer
Barclays Bank - Uganda
09.2010 - 01.2011
Compliance Officer
Barclays Bank - Uganda
02.2010 - 10.2010
Bachelor of Entrepreneurship and Small Business Management - Kampala
Makerere University
Uganda Advanced Certificate of Education (UACE) - Namugongo
Naalya Senior Secondary School Namugongo
Uganda Certificate of Education - Bweyogerere
Naalya Senior Secondary School Bweyogerere