Call for Consultancy Services for Legal and Regulatory Advisory Services for AWAC Compliance With Financial Intelligence Authority, and Training AWAC Grass Root Members on The Processes Involved in Legitimizing their Legal Existence

The Alliance of Women Advocating for Change (AWAC) is an umbrella network of grass root emerging female sex worker (FSW) led organizations. AWAC was established in 2015 by champions of the female sex worker movement. We exist to promote the voices and work of grassroot FSWs led organizations based in rural and peri-urban settings. Our core target constituency are female sex workers including those with intersecting vulnerabilities such as FSWs using drugs; FSWs living with HIV/AIDS; refugees FSWs in urban setting; FSWs living with disability; elderly FSWs; children of sex workers and adolescents surviving in the sex work settings in Uganda. AWAC has successfully mobilized her members to challenge stigma, discrimination and criminalization of all forms, has championed access to integrated quality HIV/SRHR/GBV and mental health services, led legislative advocacy campaigns, conducted operational research, capacity building programs on leadership and grassroot movement building in Uganda. Our geographical areas of implementation are: slum areas, Islands, landing sites, transit routes, mining, quarrying, plantations, road construction sites and boarder areas in Uganda. Our work is implemented at grass-root, district, national level in Uganda, and seeks to impact practices, processes and policies at all levels. We work collaboratively with grass root communities, health and human rights organizations and professional and associations as well as relevant government ministries and departments.

AWAC’s core purposes are: acceleration of the Sustainable Development Goal (SDG); addressing stigma, discrimination & challenging criminalization of all forms using the Community Led Monitoring(CLM) and Score Card (SC) Model; providing and championing access to integrated quality HIV/SRHR/TB/Gender Based Violence (GBV)/Mental health and harm reduction interventions services; including access to preventive biomedical innovations; advocacy for gender equality and equity and campaigns; conducting operational research and documentation; capacity building in feminist transactional leadership, mentorship and grassroot advocacy movement building to strengthen grassroot community structures; social economic empowerment (SEE) to diversify female sex workers and those with intersecting vulnerabilities’ income through her innovative models in Uganda.

AWAC also work in collaboratively with other individual and organisation which serve as referral points for services that it does not directly offer. These include grass root communities, health units, professional and associations, social welfare departments of government, law enforcement officers, non-governmental organizations- especially human rights organizations and other donor funded projects. With her head office is in Kampala-Mengo Kayuwa Zone, Off Balintuma roads-on Nabulagala road, but also with physical field offices/Drop in Centres in Kyotera, Masaka, Busia boarder, Terego-Rhino based Camp and Luwero districts- Wobulenzi highway.

AWAC’s geographical areas of implementation are; slum areas, Islands, landing sites, transit routes, mining, quarrying, plantations, road construction sites and boarder areas in Uganda. AWAC implements at the grass-root using the bottom up approach across the country in Uganda, and seeks to impact practices, processes and policies at all levels in 47 districts of implementation include; Kampala, Wakiso, Mukono, Busia, Tororo, Kabale, Isingiro, Kyotera, Masaka, Rakai, Lyantonde, Mbarara, Kasese, Kabarole, Kyegegwa, Kamwenge, Bundibugyo, Mbale, Jinja, Terego, Arua, Yumbe, Adjuman, Hoima, Gulu, Nakasongola, Kiryandongo, Masindi, Lira, Kitgum, Pader, Amuria, Kaberamaido, Moroto, Soroti, Kotido, Nepak, Luwero, Kabongo, Napiripiti, Mityana, Buikwe, Iganga, Mayuge, Bugiri, Namayingo and Kalangala.

AWAC Mission: “To build a resilient movement of female sex workers’ that advocates for sustainable integrated universal health care, promotion of human rights and social protection, economic justice for FSWs and those with intersecting & Compounded vulnerabilities in Uganda”.

AWAC Vision: “An inclusive policy and social environment where grassroots FSWs and those with intersecting & compounded vulnerabilities live healthy and productive lives that are free from human rights abuse in Uganda”.

AWAC Strategic Objectives
1) To strengthen the economic security and social protection of FSWs and those with intersecting vulnerabilities.
2) To contribute to attainment of Sustainable Development Goals (SDGs)- 1, 2, 3, 4, 5, 6. 8,10, 16, 17 by enhancing social mobilization and promotion of human rights among FSWs and those with intersecting vulnerabilities.
3) To advance SRHR services so that all FSWs, including those with intersecting and compounded vulnerabilities exercise their bodily autonomy, consent and control over their choices and decisions.
4) To strengthen a resilient female sex workers’ movement to leverage on their capacities to demand for an enabling environment, equitable services and hold duty bearers accountable on existing development programmes.
5) To enhance access to integrated universal health care services among FSWs & those with intersecting vulnerabilities.
6) To strengthen the institutional capacity of AWAC and her network members to effectively deliver the strategic plan.

AWAC Core Values:
• Mutual Respect and Integrity.
• Empowerment and Meaningful involvement
• Transparency and Accountability
• Appreciating diversity and non-discrimination
• Innovation, Excellence and Team Work
• Human rights and evidence based programming

Background and Justification of the project
The purpose of this document is to invite the submission of proposals to provide legal and regulatory advisory services for AWAC compliance with Financial Intelligence Authority, and training AWAC grass root members on the processes involved in legitimizing their legal existence. The work to be undertaken by the advisors (the Consultant) will focus on providing legal and regulatory support to facilitate the successful completion of a proposed organization FIA processes and requirements, and training of our grassroot network members on: adherence to FIA processes, registration processes and requirements for URSB and NGO Bureau, Anti-Money Laundering Regulations, awareness on risks relating to money laundering and terrorism financing, and where necessary, enhance them on a regular basis, procedures and mechanisms for monitoring the implementation of policies, controls and procedures to address the risks relating to money laundering and terrorism financing, filing of annual returns, monitoring systems for complex, unusual or large transactions or suspicious activities, enhanced due diligence procedures with respect to persons and business relations and transactions carrying high risk.

The intended project results/Expected deliverables are;
1. Completed process of registering AWAC with Financial Intelligence Authority (FIA),
2. Training plan for the AWAC network members on: adherence to FIA processes, registration processes and requirements for URSB and NGO Bureau, Anti-Money Laundering Regulations, awareness on risks relating to money laundering and terrorism financing, and where necessary, procedures and mechanisms for monitoring the implementation of policies, controls and procedures to address the risks relating to money laundering and terrorism financing, and filing of annual returns.
3. Training report.
4. Filled annual compliance reporting template for accountable persons with the guidance of the consultant.

Purpose/objectives of the consultancy

1. Identify risks associated with non-compliance with the laws and regulations on governing NGO registration, filing of annual returns, tax obligations ie remitting PAYE and Local service tax.
2. Sensitization on money laundering, terrorist financing and financial intelligence
3. Identify indicators of money laundering within financial documents, Acts & Regulations ie the Anti-Money Laundering (Amendment) Act 2017; Penal Code Act, The Anti-Corruption Act, 2009 etc.
4. Demonstrate an understanding of the differences between money laundering and terrorist financing.
5. Identify financial and non-financial institutions that have vulnerabilities toward money laundering.
6. Identify international remittance systems and alternative banking methods which can involve money laundering
7. Identify predicate offences and crimes that may indicate money laundering as our organization’s source of funding.
8. Demonstrate knowledge of Ugandan Laws applicable to money laundering investigations and non-compliance with the financial laws and regulations.
The consultant will use participatory approaches to execute the assignment. S/he will be responsible for developing specific and friendly facilitative techniques (brainstorming sessions) that are appropriate to meet the purpose of this assignment.

Roles of AWAC
1. Contract the consultant to lead the process, preferably a Lawyer from a reputable law firm.
2. Mobilize participants to attend the meetings and brief them about the entire process.
3. Provide the consultant with related documents for literature review.
4. Organize field logistics including for meetings.
5. Support a rapporteur to capture all proceedings/processes
6. Provide a dedicated team working with the consultant

Specific roles of the consultant
Work with AWAC and keep timely communication flow in the process of executing the assignment
1. The Completed process of registering AWAC with the Financial Intelligence Authority (FIA),
2. Develop a comprehensive training plan for the AWAC network members on: adherence to FIA processes, registration processes and requirements for URSB and NGO Bureau, Anti-Money Laundering Regulations, awareness of risks relating to money laundering and terrorism financing, and where necessary, procedures and mechanisms for monitoring the implementation of policies, controls and procedures to address the risks relating to money laundering and terrorism financing, and filing of annual returns.
3. Training report.
4. Filled annual compliance reporting template for accountable persons with the guidance of the consultant.

To apply, submit your Expression of Interest (one page), CV (3 pages max), one reference/recommendation letter from previous consultancies to and copy in, and no later than 15th April

2020 Report On The Protection and Violation Of The Human Rights of Sex Workers In Uganda

A Snippet

The 2020 Report on the Protection and Violation of Human Rights of Sex workers
in Uganda examines the protection and violation of the rights of sex workers by
state actors and non-state actors in the year 2020.
The report is based on cases documented by Human Rights Awareness and
Promotion Forum (HRAPF), both through the central legal aid clinic and the regional
legal aid centres, the Alliance for Women Advocating for Change (AWAC) and the
wide network of HRAPF trained community paralegals. HRAPF currently operates
a countrywide network of legal aid service provision, with regional centres in each of
the four major regions of the country, specialised legal aid desks hosted by different
organisations and the network of HRAPF trained community paralegals.

More about this report, follow this: link

Our contribution to HIV response among female sex workers and AGYW in sex work settings in 2021

Female sex workers (FSWs), Adolescent girls surviving in sex work settings especially those with compounded and intersecting vulnerabilities in Uganda bear a disproportionate burden of HIV and Sexual Reproductive Health challenges. This is compounded by the existence of little evidence on the barriers that impede their access to HIV/AIDs and SRH related services. According to Wabwire- Mengen, Sempiira and Kwesiga (2019) as cited by Mukwaya & Kyomya (2021), it is important to note that, an estimated 130,359 FSWs in Uganda operate in a criminalized environment and this environment has exposed FSWs to increased risks of HIV infection leading to extreme stigma, discrimination and denial of access to health services in health facilities.
The Alliance of women advocating for change as an umbrella network of grass-root female sex workers (FSW) led-organizations in Uganda has promoted and advocated for human rights and access to affordable, acceptable, responsive and quality health and socio-economic services among female sex workers and other minoritized women and girls in Uganda. In a bid to enhance access to integrated universal health care services among female sex workers, AWAC established models such as the Drop-In Centre, Community Health and Livelihood Enhancement Groups (CHLEGs), Outreaches and stepping stone out of the need to plummet the rate of HIV/AIDS spread among female sex workers in Uganda. Through AWAC clinic days (Wednesday and Thursday) at the DiCs, our members have been provided with integrated Universal Health care services – these include HIV screening and testing, counselling, refills for clients on ART and PrEP, mental health, psychosocial support for GBV survivors, SRH commodities for FSWs, other minoritized women and girls at our DiC safe space.

Mr Charles Okoth -AWAC DiC Clinician. carrying out a Viral Load Bleeding.

In 2021, AWAC initiated 287 clients on ART and 2957 clients on PrEP. AWAC has further donated emergency food relief to 121 of her members to ensure their ART and PrEP adherence is not compromised by malnutrition due to a shortage in food during this extraordinarily challenging period. It is worth to note that, prevention of HIV is one of the core focus areas of our service delivery programs. Besides PrEP, this has been enhanced through distribution of sexual reproductive health commodities and services such as family planning to 3089 female sex workers and other minoritized women as a tandem to promote health equity and UHC as an integral focus area of 2030 SDG agenda.
We have continued to empower and mentor 294 FSWs and adolescent girls on sexual reproductive health, relationships and behavioral change through stepping stone workshop series. Most notable of this economic empowerment program has been on integration of an intersectional focus through economically empowering 40 adolescent girls and young women (including 13 of these with disability) in tailoring and design skills to strengthen their economic risk resilience and tide over the immediate impact of COVID-19 on their livelihood sources. This has improved adherence for 13 minoritized AGYWs on ART and increased uptake of PrEP for 27 HIV negative AGYWs benefiting from the “Make Me Visible” Project. Further to note, through our empowerment programs and models such as Community Health and Livelihood Enhancement Groups model, our community members have been able to establish 11 saving groups from Masaka region, 5 from Kampala including a savings group for AGYW with hearing impairments and 1 from Wakiso. This has been an enabler to our groups to save money and further invest into their jointly owned economic ventures.
AWAC introduced MALAIKA toll-free line 0800-333-177 which operates for 24hours. Through this toll-free line, over 1025 FSWs have shared their experiences, provided with psychosocial support, sexual reproductive health commodities and services and food relief to improve their ART and PrEP adherence.
Much as AWAC continues to spearhead the resilience of the FSWs movement to demand equitable health services and a free environment from discrimination and stigma of FSWs and marginalized/PLWHIV in Uganda, the government should be at the forefront in the fight against inaccessible health services, and discrimination and stigma against FSWs and other minoritized women/PLWHIV. Since the COVID-19 outbreak, the government has diverted most of its attention to COVID-19 yet HIV is still an epidemic in Uganda. The government should put in place inclusive responsive policies to address the needs of FSWs and other women/PLWHIV at the society periphery such as the inclusion of FSWs and other minoritized women and their children in social protection programs and national health insurance scheme –such that they can access adequately health services without being discriminated and stigmatized in health facilities.


Mukwaya, R. and Kyomya, M. 2021 (Advocacy issues Brief, Decriminalizing Sex work and enhancing equitable access to Health, Justice and Social Protection by Female sex workers in Uganda .

Activists protest police raids on sexual workers

Kampala, Uganda | THE INDEPENDENT | HIV advocates have condemned the continued harassment of sex workers especially by police officers under the guise of enforcing the standard operating procedures (SOPs) against Covid-19 to defraud them of their money.

Speaking to journalists on Wednesday, Macklean Kyomya, the Executive Director at Alliance of Women Advocating for Change (AWAC), an organization that advocates for rights of key populations, said that they have recorded complaints of officers breaking into hotel rooms and arresting sex workers while threatening them to pay bribes.

She says that during the recent police raid on a guest house in Rubaga division, the sex workers claim to have paid not less than Shillings 100,000 for their freedom.

Calling on the President not to assent to the controversial Sexual Offenses Bill that was approved by parliament in May, Kyomya said the police are already warming up for its operationalization since it criminalizes sex work.

According to Kyomya, they have rescued nine sex workers who were being held in custody and they reported majority of their colleagues to have paid their way out of detention.

While the curfew that starts at 7pm has pushed sex workers off the street, another activist Richard Lusimbo says the women have found themselves in a hard place without food yet they are not considered among the needy to receive the Shillings 100,000 COVID-19 cash relief from the government.

He pushes for inclusiveness of key populations in programming such as sex workers, prisoners and injection drug users among others whose needs should be prioritized since already some national policies and programmes like the National HIV and AIDS strategic plan have recognized them.

But Dr. Daniel Byamukama who heads the HIV Prevention at the Uganda AIDS Commission says this is hard at the moment given the societal prejudices, especially the call to repeal laws criminalizing sexual activity and sex work.

He however notes that the commission is set to conduct a legal environment assessment. In this exercise, he says even the sexual offenses bill, which is not yet assented to will be evaluated. He says the consultants will among others ask communities and other stakeholders their view about the legal regime in relation to the HIV/AIDS response.

The report from this assessment will then act as a guide or reference book for MPs when legislating such issues as human rights and HIV.



AWAC receives food relief items and masks from NAFOPHANU

Yesterday we received food relief items and masks from @NAFOPHANU. This food relief will go to AGYWs and our members, including those in care straggling with ART/PrEP adherence to due to inadequate food availability.

During this time of great uncertainty we have been supported, encouraged, and humbled by the outpouring of generosity and support from our partners.

Our gratitude goes to NAFOPHANU

Uganda’s new criminalization bill further endangers those in the sex industry

“You have to live a double life.” Daisy Nakato Namakula, 38, has spent the last two decades in the sex industry in Uganda. The East African nation criminalizes ”sexual intercourse or other sexual gratification for monetary or other material gain” in its penal code, but the stigma alone is enough to enforce a culture of secrecy.

“You cannot be open about where you live and work,” she said. “You have to lie to your neighbors and children — telling them you do a [different] business — for you to be safe and comfortable.” Still, it remains a primary form of income for many — predominantly women and members of sexual minority groups — who see it as their best option to make a reliable living wage.

The job comes with significant risks: Sex workers face the constant threat of police raids, monetary fines, and sexual exploitation by clients and police officers, with no legal recourse to report this abuse when it occurs.

And in recent weeks, the work has become even more dangerous: New legislation is triggering a crackdown on the sex industry, especially in rural districts and low-income areas.

On May 3, the Ugandan Parliament voted to pass the 2019 Sexual Offenses Bill, which reinforces the criminalization of sex work and same-sex relations under the pretense of strengthening protections against sexualized violence. Uganda has long been hostile to the rights of LGBTQ+ people, criminalizing consensual same-sex relations as an “unnatural offense” with up to life in prison. The new bill goes one further by prosecuting Ugandans who engage in consensual same-gender sexual acts or anal sex even outside of Uganda.

The consequences of this new legislation will fall heaviest on women and marginalized groups during an already fraught year, as COVID-19 continues to ravage the health and economic security of many Ugandans.

Human rights organizations and activists have condemned the bill, claiming that it infringes on the rights of consenting adults. “We’ve always wanted to have a safe working environment, but now it’s going to be the opposite of what we have been advocating for,” said Namakula, who now works as the national coordinator of the Uganda Network for Sex Worker Led Organizations (UNESO), an advocacy network that partners with public health and government officials to support the safety and wellbeing of sex workers.

Namakula worries that the bill will be a significant setback to UNESO’s organizing capacities. UNESO leaders have been working to organize a dialogue between the Ministry of Health and sex workers’ advocates across Uganda, but those discussions have been delayed due to current COVID-19 lockdown restrictions, which prevent gatherings of more than 20 people. “The national dialogue was going to be very helpful in bringing every player on board,” she said, “but now that it may not happen soon, we are trying to strategize to make sure we engage everyone.”

As the bill awaits signing by President Yoweri Museveni, its repercussions are already being felt within the community. “There is a lot of tension,” said Kyomya Macklean, executive director of the Alliance of Women Advocating for Change (AWAC), a grassroots initiative calling for better health care access and economic opportunity for women sex workers in Uganda. “Police in the rural districts are intimidating people, saying, ‘If [the president] signs that document, you are dead. You should find another way to survive.’”

Many sex workers have retreated into hiding, no longer attending support groups or seeking health care services like STI testing, birth control, and PrEP for HIV prevention. “This act is really going to take us back,” said Macklean, who feels betrayed by the government and frustrated that the concerns put forth by the sex workers’ movement are not being heard. “If the president has not even signed it yet and this is already happening, what is going to happen if the bill is actually signed into law?”

Decriminalization and deconstructing stigma

Rather than protecting the rights of those in the sex industry to access healthcare or justice in cases of abuse (challenges they face on a day-to-day basis), advocacy groups argue that this bill only contributes to a culture of abuse, making sex work seem inherently like a dishonorable occupation.

“The term ‘sex work’ represents what we do, and it’s not derogatory,” Namakula explained to me. “We even have a term in our local language, Nekolera gyange, meaning ‘entrepreneur.’” Using these terms, she said, helps legitimize the profession. “You wake up, you dress up, and you go out knowing you are going to make money,” she said. “You go out with intention — not just loitering around looking for people to sleep with.”

Sex trafficking does happen in Uganda, Namakula said, but not often. “We will see people who have been trafficked being taken to outside countries, but it is not very common here.” In 2018, the Ugandan government identified 18 cases of sex trafficking of children and 15 cases of sex trafficking of adults within the country; by contrast, it identified 599 cases of Ugandan travelers (477 of whom were women) attempting to leave the country in situations considered high risk for trafficking.

Occasionally, Namakula said, there will be cases in which a sex worker is coerced into the work by a relative or stranger, who then takes any money she makes for themselves. To this point, Namakula emphasized the importance of agency and personal choice. “As a movement, we strongly disagree with trafficking,” she said. “We believe someone should be above 18, able to make their own decisions, and choose to be in the industry — not forced.”

Namakula, Macklean, and other advocates have been working for years to end the cultural stigma against the sex industry in Uganda and to campaign for decriminalization. For them, that starts with countering the prevailing narrative that sex work is always a last resort. “No one believes that you can wake up and make a decision that you want to be a sex worker, and yet we have,” said Namakula. “There might be other options, but you feel like being a sex worker is the best option for you.”

Namakula worked in food service in her early career but wasn’t able to make a reliable salary. Sex work, she said, gave her financial stability. “When you have money, you are an empowered woman,” she asserted. “You decide which house to rent; you decide what to eat; you decide what to do with your life.”

Regardless of what motivates someone to enter into the sex industry — financial opportunity, family circumstances, personal history, or otherwise — Macklean said that decriminalization would help make the industry safer and protect those vulnerable to mistreatment.

“Sex workers should be left to operate just like any other profession in the country,” she said. “If we can do that, it would give us a way to protect the young minors [getting involved in] this business. We would be able to track those who violate the rights of sex workers and report [those] cases.”

Macklean wants to see a legal distinction between adult sex workers who work of their own free will and minors who are coerced into the industry — the latter of which should not be considered sex work, both women adamantly assert. Decriminalization would also allow for laws protecting sex workers from being denied health care services or subjected to blackmail.

One significant issue right now is sexual and financial exploitation of sex workers by police — something made worse in the wake of this new legislation. “We use a lot of out-of-pocket money to bail ourselves and others out,” Macklean said. Officers will raid a brothel and ask for US $50 or $100 per sex worker to keep everyone out of detention. Worse, they may solicit free sex from a sex worker as a means of bail. “They’ll say, ‘If you want to go home, you know what to do,’” she said.

Even if a sex worker acquiesces, the officer often brings her right back into detention afterward. “You are traumatized, you are being abused, [and] the police probably don’t even have condoms,” Macklean said. “You are being put at risk.”

On the health front, decriminalizing sex work could aid in Uganda’s fight against HIV. Uganda’s HIV rates are among the highest in the world: an estimated 1.5 million people in the country are HIV-positive, or 6 percent of the population. Sex workers are an especially vulnerable group by nature of their industry — around 31 percent of sex workers are currently living with HIV.

Namakula worries that the Sexual Offenses Bill will discourage productive relationships between health providers and sex workers. While it is not illegal to provide these services to sex workers, health providers may shy away from doing so for fear of police retribution. “When you are offering health services, you are also ‘aiding and abetting’ the industry,” she said. “So, it will now be very challenging for sex workers to come out to access services.”

Namakula and Macklean, with their respective organizations, are ultimately fighting for the right of sex workers to live and work freely, just like anyone else. “I am still a human being,” Namakula said. “I am still a woman and so many things besides what I do for a living. As much as I am a sex worker, I also have a right not to be arrested or violated or treated differently.”

The legal landscape continues to be stacked against the movement, yet its advocates aren’t backing down. “If we can decriminalize,” said Macklean, “it will be safe for us to work, look after our family, and continue with a good life like any other profession.”

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