In March 2021, the United States reinstated sanctions against the billionaire, decided in December 2017 by the US State Department, but which had been eased just before Donald Trump left the White House.
Washington accused him of causing the DR Congo to lose “$1.36 billion in tax revenue” in the 2010s.
The leaked records of alleged money-laundering centred on Afriland First Bank’s branch in Kinshasa, were made public by the campaign group, the Platform for the Protection of Whistle-blowers in Africa (PPLAAF).
The two auditors have since fled to Europe after expressing fear for their lives taking with them a trove of documents. They were sentenced to death in their absentia. Part of these documents show an elaborate scheme of how firms linked to Gertler were able to circumvent sanctions imposed on him by the United States.

US view
The US Treasury had accused Gertler of amassing his fortune ‘through hundreds of millions of dollars’ worth of opaque and corrupt mining and oil deals’ in Congo-Kinshasa.
The revelations came a month after it emerged that Gertler had cut a deal with officials in the outgoing Donald Trump administration suspending the sanctions for a year.   
The move has prompted three Democrat lawmakers – including the chair of the House Committee of Foreign Affairs – to write a February 3 letter to Treasury Secretary Janet Yellen, saying the waiver ‘upends US policy’ towards Congo-Kinshasa and calling for it to be reversed. These concerns are being raised as President Félix Tshisekedi appears to have wrested control of the National Assembly in Kinshasa away from his predecessor Kabila whose leverage and clout continues to wane. 
Gertler says the documents were forged. 
Mr Asubo says Uganda should not be concerned about Afrilands Bank footprint in the DR Congo as the subsidiary here is different and ‘as far as we concerned there are no money laundering concerns that have been associated with this bank.’

“The rules that apply to the banks, apply to the customers of the banks those are the transactions we focus on. The transactions that the banks do between themselves or one their own behalf are expressively excluded because their oversight falls under the purview of the Central Bank. But also, these banks operate as independent subsidiaries, so the subsidiary in Uganda is run independently to the subsidiary in the DR Congo. It doesn’t translate that the misdeeds of the subsidiary of another country will apply to a subsidiary in another because the management is different, the rules are different.”
Scrutiny of the documents on the company accounts at Afriland First Bank, one of Central Africa’s largest financial groups, and these latest allegations of money-laundering made against Gertler’s companies, are likely to form part of the review of his case in Washington DC.  
On February 25, representatives for Gertler and Afriland told journalists that a court in Kinshasa had convicted the whistleblowers for ‘criminal conspiracy’ and sentenced them to death. 

The documents reveal how Gertler’s murky network operated below the radar to avoid detection by US anti-money-laundering restrictions and banks’ compliance departments. A previously unknown company, which had ties to Gertler, received around a quarter of the Afriland branch’s entire loans in early 2019, and several companies tied to alleged financiers of Hezbollah and North Korea’s armaments programme also held accounts at the branch, the evidence shows.
The whistle-blowers revealed that they took notice of these strange transactions at Afriland in early 2018, soon after the US imposed sanctions on Gertler and his companies in December 2017. 

Some of the evidence gathered by Navy Malela, one of the in-house auditors officers at Afriland First Bank in Kinshasa, show how a special intermediary account at the bank that was not tied to any individual – called the disposition à payer (DAP) account - allowed companies in Dan Gertler’s network to convert millions of US dollar banknotes into euros. The euros were then moved into accounts run by associates of Gertler, or members of his immediate family.
These methods appear designed to navigate United States sanctions, which prohibited Gertler from conducting bank wire transactions in dollars. The use of front companies could also allow him to avoid compliance officers at other banks, who can block transactions over corruption risks.
Mr Alain Mukonda, a Congolese businessman was a key figure using the intermediary DAP account in Kinshasa. 
 
Over six months, from January to July 2018, Mr Mukonda made deposits of $10.5m and €3.5m of cash into the DAP account, and withdrew $7.1m and €6.3m. He has denied operating on behalf of Gertler, yet he is listed as the ‘president’ of Ventora Development and personally handled the re-domiciling of several of Gertler’s companies.
Mr Mukonda’s last euro withdrawal took place on 10 July 2018, when he took €2.169m from the Kinshasa DAP account. Records indicate that this money arrived in the DAP account from Ventora Global Services, another Gertler-linked company at which Mr Mukonda was manager. 

On the same day, the exact same amount was deposited, in cash and in euros, into the account of Western Financial Services (WFS) the bank records show. This is the very first transaction visible in WFS’s Afriland records.
Money laundering is a form of Illicit Financial flows and it is estimated that Uganda loses Shs2 trillion annually.
 Insufficient levels of financial transparency—globally and domestically—and government accountability in Uganda, coupled with a regulatory system that can incentivise financial crimes, are helping to drive high levels of illicit financial inflow and outflows in the country, which are undermining development efforts. Uganda will struggle to meet its goal of rising to the lofty middle-income status and reducing its reliance on foreign debt unless it combats illicit financial flows. Three policy areas should be the central focus for the government: eliminate the allowance and use of anonymous companies in the economy, reduce the ease and volumes of trade misinvoicing, and enforce anti-money laundering laws, particularly within the banking sector.