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Financial Integrity Monitor

Kenya KE

Domains covered
6 of 8
Sources
169
Role actions
8
Horizon <90d
4
Jurisdiction profile
FATF status: Grey-List Tier: B Risk direction: Stable Enablement vs enforcement: Mixed

Kenya's AML/CFT regime rests on the Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) as amended post-2022 MER, supervised by the Financial Reporting Centre (FIU), Central Bank of Kenya and Capital Markets Authority.

MoreGrey-listed by FATF since February 2024; reforms since include a VASP licensing framework and increased TF investigations, but core supervisory, BO/trust and NPO gaps persist.

Key deficiencies
  • Risk-based AML/CFT supervision of financial institutions and DNFBPs remains inadequate
  • Insufficient STR filing and preventive-measures understanding among FIs/DNFBPs
  • No authority designated for regulation of trusts and verification of accurate beneficial ownership information
  • Weak use and quality of financial intelligence products
  • Insufficient ML/TF investigations and prosecutions relative to risk
  • TFS framework for terrorism (R.6) not fully compliant or effectively implemented
  • NPO regulatory framework not yet revised to a proportionate, risk-based model
Recent developments (18m)
  • FATF October 2025, February 2026 and June 2026 Plenary statements confirm continued grey-list status with unmet action-plan deadlines
  • Kenya adopted a legal framework for licensing and supervision of virtual asset service providers (noted by FATF Oct 2025/Feb 2026)
  • EU Commission added Kenya to its high-risk third country AML/CFT list via Delegated Regulation (EU) 2025/1184 (10 June 2025), retained in the December 2025 update
  • UK HM Treasury listed Kenya as a High-Risk Third Country under MLR Regulation 33 following the FATF October 2025 Plenary
  • OFAC counter-terrorism (SDGT) designation of a Kenya-linked Al-Shabaab facilitator (28 March 2025)
  • EACC/UK National Crime Agency international cooperation concluded the Migori County corruption case, recovering KES 235.6m (USD 1.8m) in property and vehicles (reported December 2025)
Brief

Lead signal

Lead Signal

Kenya enters November 2026 with its financial-crime architecture caught between formal completion and operational absence. The country remains among the eighteen jurisdictions left on the Financial Action Task Force's increased-monitoring list following the October 2026 plenary, which removed four other listed jurisdictions and added none. National Treasury Principal Secretary Chris Kiptoo has stated that nineteen of twenty-one identified deficiencies have now been remedied, with an April 2027 exit targeted. That self-reported progress sits alongside a separate and more structurally significant development: the one-year transition deadline under section 47 of the Virtual Asset Service Providers Act, 2025 expired on 4 November 2026, and reporting at the time indicates no virtual asset service provider had yet been licensed by either the Central Bank of Kenya or the Capital Markets Authority. Operating without a licence is understood to become a criminal offence from 5 November 2026. The result is a jurisdiction where a comprehensive anti-money-laundering and counter-terrorist-financing regime for digital assets, complete with customer due diligence, travel-rule, sanctions-screening and suspicious-transaction-reporting obligations, is now nominally binding on a population of operators that is substantially unlicensed.

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Lead Signal

Kenya enters November 2026 with its financial-crime architecture caught between formal completion and operational absence. The country remains among the eighteen jurisdictions left on the Financial Action Task Force's increased-monitoring list following the October 2026 plenary, which removed four other listed jurisdictions and added none. National Treasury Principal Secretary Chris Kiptoo has stated that nineteen of twenty-one identified deficiencies have now been remedied, with an April 2027 exit targeted. That self-reported progress sits alongside a separate and more structurally significant development: the one-year transition deadline under section 47 of the Virtual Asset Service Providers Act, 2025 expired on 4 November 2026, and reporting at the time indicates no virtual asset service provider had yet been licensed by either the Central Bank of Kenya or the Capital Markets Authority. Operating without a licence is understood to become a criminal offence from 5 November 2026. The result is a jurisdiction where a comprehensive anti-money-laundering and counter-terrorist-financing regime for digital assets, complete with customer due diligence, travel-rule, sanctions-screening and suspicious-transaction-reporting obligations, is now nominally binding on a population of operators that is substantially unlicensed.

This is best read as a capacity and sequencing problem rather than deliberate regulatory enablement. The legal instruments exist, are gazetted, and are in force; what has not yet materialised is the administrative capacity to license the entities those instruments govern. The gap between legal force and institutional readiness is itself an analytically meaningful signal for a jurisdiction trying to exit increased monitoring.

Other Developments

Beneficial ownership signals diverge by track. The FATF's June 2026 assessment flagged ownership transparency as one of seven outstanding action items for Kenya's grey-list exit, a national-level gap that remains open. Separately, and on a distinct track, the newly gazetted Gambling Control (Licensing) Regulations 2026 introduce a sector-specific beneficial-ownership and corporate-control disclosure duty for gambling licensees. This sectoral requirement does not resolve the national register gap the FATF has identified; it is a parallel, narrower development that nonetheless adds to the overall disclosure architecture piece by piece.

The virtual asset regime is now substantively in force but substantially unimplemented. The Virtual Asset Service Providers Regulations, 2026, gazetted as Legal Notice 134 of 2026 on 22 July 2026, set a minimum capital requirement of KSh 300 million for stablecoin issuers and impose customer due diligence, transaction monitoring, sanctions compliance and suspicious-transaction-reporting duties aligned to FATF standards. The expiry of the section 47 transition window on 4 November 2026 without any licence yet granted converts this architecture from a readiness exercise into a live enforcement question: a population of previously tolerated operators is reported to now be operating outside the law, pending licensing capacity catching up with the statute.

Cross-Monitor Connections

The Virtual Asset Service Providers Regulations establish a Virtual Assets Services Coordination Forum drawing together twenty public agencies, including the National Treasury, the Central Bank of Kenya, the Capital Markets Authority, the Financial Reporting Centre, the Asset Recovery Agency, and the data protection regulator. This cross-sectoral coordination structure is a natural routing point for findings that straddle financial integrity and data governance, since beneficial-ownership and transaction-monitoring obligations under the new crypto regime will increasingly intersect with the data protection regulator's own registration and enforcement functions. Analysts tracking digital-asset infrastructure risk should treat the licensing vacuum as a watch item for downstream consumer-protection and data-handling exposure wherever it surfaces.

Outlook

The two threads now in motion, grey-list remediation and virtual-asset licensing, will likely be read together by the FATF as it assesses Kenya's April 2027 exit target. A persistent licensing vacuum in a sector the FATF has already flagged for weak supervision could complicate the narrative of remediation that Treasury is presenting, even as formal deficiency counts fall. Expect continued attention to whether the Central Bank of Kenya and Capital Markets Authority issue the first substantive licences in the coming months, and whether enforcement against unlicensed operators becomes visible, both of which would materially affect how the grey-list trajectory is assessed heading toward the next plenary cycle.

Earlier periodic briefs (5)
4 Nov 2026 · fim-2026-11-01

Lead Signal

Kenya's virtual-asset regime reaches a hard compliance cliff on 4 November 2026, when the one-year transitional window created by the Virtual Asset Service Providers Act, 2025 and the gazetted VASP Regulations, 2026 closes. From that date, offering a virtual-asset service in or from Kenya without a licence from the Central Bank of Kenya or the Capital Markets Authority becomes a criminal offence, and licensed providers become reporting institutions under the Proceeds of Crime and Anti-Money Laundering Act, with customer due diligence, suspicious transaction reporting to the Financial Reporting Centre, and sanctions screening obligations attaching directly. Commentary reviewing the gazetted regulations is split on whether the text references the Financial Action Task Force Travel Rule by name, a gap that matters because Kenya's own regulators have indicated no virtual-asset service provider had yet been licensed as the deadline approached, suggesting an industry readiness gap sits underneath a now-binding legal obligation.

The timing is not coincidental to Kenya's wider standing with the Financial Action Task Force. Kenya has remained under increased monitoring since February 2024, and a 19 June 2026 plenary statement identified seven outstanding action-plan items spanning ownership transparency, financial intelligence, and money-laundering investigations and prosecutions. Kenya's National Treasury has now attached an April 2027 exit target to that process, a government-stated ambition rather than a confirmed Financial Action Task Force position.

Other Developments

Beneficial-ownership enforcement signalled, not yet legislated. Treasury has indicated it intends to strengthen beneficial-ownership disclosure enforcement for companies and trusts as part of the broader grey-list exit strategy. This is a stated policy intent rather than a new instrument: no amending law or regulation accompanies it yet, and the statement should be read as the structural direction Treasury wants to travel in, not as a change already in force.

Gambling-sector AML duties confirmed as a parallel reporting-institution track. The Gambling Control Act, 2025 requires every licensee of the Gambling Regulatory Authority to appoint a money-laundering reporting officer, maintain anti-money-laundering and counter-financing-of-terrorism internal controls, and submit to risk-based inspections as a reporting institution under the proceeds-of-crime statute. A commonly cited two-day reporting-deadline figure circulating in secondary commentary could not be confirmed against the primary instrument's own text, and should be treated as unverified rather than repeated as settled law.

Cross-Monitor Connections

The virtual-asset compliance cliff sits squarely at the junction between financial-integrity supervision and payments-market structure: the same licensing perimeter that creates reporting-institution duties under proceeds-of-crime law is also the gate that determines who may lawfully operate a stablecoin or exchange business in Kenya at all, so enforcement posture on one side shapes market entry on the other. The beneficial-ownership enforcement signal and the FATF exit timeline both touch the same underlying architecture question other monitors track when assessing whether enabler-jurisdiction risk is rising or falling in East Africa — a tightening ownership-transparency regime, if it materialises, would narrow the space such jurisdictions can offer to opaque corporate structures.

Outlook

The period immediately following 4 November 2026 is the point at which Kenya's virtual-asset regime stops being prospective and starts generating enforcement choices: regulators will have to decide how they treat providers still operating without a licence, and whether a grace period or an enforcement sweep follows. Separately, the FATF review cycle leading toward Treasury's stated April 2027 target will test whether the seven outstanding action items — including the ownership-transparency strand Treasury has now flagged for domestic reform — can be closed on that timetable, or whether the exit date proves optimistic against a June 2026 plenary statement that gave no indication Kenya was close to completion.

3 Nov 2026 · fim-2026-11-03

Lead Signal

Kenya enters November 2026 with its financial-integrity posture defined by a single structural fact: the Virtual Asset Service Providers Act, 2025, together with the Virtual Asset Service Providers Regulations, 2026, reaches the end of its one-year transitional compliance window on 4 November 2026. Secondary reporting as at 10 October 2026 indicates no virtual asset service provider had yet been licensed under the regime at that point, leaving a probable gap between the dates set by the Central Bank of Kenya and the Capital Markets Authority as joint regulators and the operational readiness of the sector they are meant to supervise. The Act designates the Central Bank of Kenya and the Capital Markets Authority as the regulators of virtual asset service providers, and the transitional window requires those providers to obtain a licence and register as reporting institutions under the Proceeds of Crime and Anti-Money Laundering Act before operating lawfully from that date. Whether the gazetted regulations themselves reference the Financial Action Task Force Travel Rule by name is disputed between secondary commentators, and the underlying gazette text has not been independently retrieved to resolve that dispute, so the obligation is recorded with that uncertainty attached rather than asserted as settled.

Alongside this, Kenya remains under the Financial Action Task Force's increased-monitoring category, having been placed there in February 2024, with the Treasury reportedly targeting an exit by April 2027 against seven outstanding action items identified in a Financial Action Task Force statement dated 19 June 2026. That statement has not been independently retrieved and the claim rests on business-press summary, so it is treated as probable rather than confirmed. Treasury intent to tighten beneficial-ownership disclosure enforcement ahead of that targeted exit has also been reported, though this is a policy-intent statement only, with no new legal instrument behind it.

Other Developments

Gambling-sector anti-money-laundering obligations reaffirmed. The Gambling Control Act, 2025, requires all Gambling Regulatory Authority licensees to designate a money-laundering reporting officer and to maintain anti-money-laundering and counter-financing-of-terrorism internal control systems, with the Act and its accompanying Conduct of Gambling Operations Regulations, 2026 providing for anti-money-laundering risk-based inspections of licensees. This obligation is in force on the text as retrieved from Kenya Law. A frequently cited figure for a short suspicious-transaction-report filing deadline attached to this regime could not be confirmed against the primary statutory text, and is accordingly not asserted here.

Beneficial-ownership disclosure signalled, not yet instrumented. Reporting ahead of Kenya's targeted exit from increased monitoring describes an intent to strengthen beneficial-ownership disclosure enforcement, framed explicitly as a policy signal rather than as a new regulation, statute or gazetted instrument. No underlying legal text accompanies this signal at this time.

Virtual-asset transitional deadline closing with licensing status unresolved. The one-year window opened by the Virtual Asset Service Providers Act, 2025 on its 4 November 2025 commencement closed on 4 November 2026, after which operating as an unlicensed virtual asset service provider becomes a criminal offence. Secondary legal commentary reports that, with the deadline then under a month away, providers faced a compressed compliance timeline; whether providers achieved licensing in time has not been independently confirmed.

Cross-Monitor Connections

The virtual-asset licensing transition carries a direct crypto-infrastructure dimension: a disputed Travel Rule reference inside Kenya's gazetted virtual-asset regulations is the kind of technical-standard gap that correspondent-level crypto monitors and digital-asset compliance-technology trackers elsewhere in the fleet would read as a potential evasion seam, since originator and beneficiary information requirements on virtual-asset transfers are only as enforceable as the instrument that states them. Kenya's continued increased-monitoring status under the Financial Action Task Force, read together with gambling-sector and virtual-asset anti-money-laundering architecture both being newly operational or newly tested in the same window, is the kind of structural, multi-sector regulatory tightening that conflict-finance and enabler-jurisdiction trackers elsewhere in the fleet would want on their radar as a jurisdiction whose compliance architecture is in active transition rather than settled.

Outlook

The period through the Treasury's targeted April 2027 exit from Financial Action Task Force increased monitoring is likely to be read, on current reporting, as the frame within which Kenya's beneficial-ownership disclosure intent either hardens into an instrument or remains a statement of policy. The immediate test is the virtual-asset licensing regime: whether supervision by the Central Bank of Kenya and the Capital Markets Authority converts the 4 November 2026 compliance deadline into licensed, reporting virtual asset service providers, or whether an unlicensed sector persists past the date at which operating without a licence became an offence. Resolution of the disputed Travel Rule reference inside the gazetted regulations, once the underlying text is read directly, would materially change how that virtual-asset obligation is assessed.

18 Oct 2026 · fim-2026-10-18

Lead Signal

Kenya's Financial Reporting Centre told the National Assembly Committee on Delegated Legislation on 13 October 2026 that the country has now addressed 19 of 21 FATF action items, with six items cleared in the preceding two and a half months, and the government is targeting April 2027 for removal from the FATF increased-monitoring list. That target has already slipped once from an initial goal, and no FATF plenary statement itself has been retrieved to corroborate the 19-of-21 figure, which rests on secondary reporting of parliamentary testimony. Alongside this, a new implementing instrument for the UN Security Council terrorism-suppression resolutions, Legal Notice 172 of 2026, was gazetted 7 September 2026 and reviewed by the same parliamentary committee on 13 October 2026, with a focus on asset-freeze exemption safeguards.

Other Developments

The Virtual Asset Service Providers Regulations, 2026 came into force on 22 July 2026, establishing a dual Central Bank of Kenya and Capital Markets Authority licensing regime across ten licence categories and designating virtual asset service providers as POCAMLA reporting institutions subject to customer due diligence, suspicious transaction reporting, record-keeping and transaction-information duties. Existing providers have until 4 November 2026 to obtain a licence, directly answering FATF Recommendation 15 on virtual assets. Beneficial-ownership disclosure has also been extended into the gambling sector: under the Gambling Control Act, 2025, the Gambling Regulatory Authority is reported to carry risk-based anti-money-laundering inspection duties over casinos and online betting operators, who must disclose beneficial ownership at licensing under section 30 and the Second Schedule. This rests on a single law-firm source, with no primary Financial Reporting Centre or Gambling Regulatory Authority notice yet confirming the supervisory arrangement.

Cross-Monitor Connections

The VASP Regulations development connects directly to the digital-asset and payments monitors covering Kenya's new licensing perimeter, and the gambling beneficial-ownership extension intersects with payments-sector oversight of gambling-related transaction flows given the parallel requirement for payment service providers to obtain prior regulatory approval before processing gambling transactions.

Outlook

The proliferation-financing regulations expected to close Kenya's remaining FATF action items had not been tabled as of the mid-October 2026 reporting window; their appearance, or continued absence, in the fourth quarter of 2026 will be a key signal for whether the April 2027 delisting target is realistic. A primary FATF plenary statement, if issued, would corroborate or revise the FRC's 19-of-21 self-assessment.

11 Oct 2026 · fim-2026-10-11

Lead Signal

Kenya's crypto-asset AML perimeter expanded materially this cycle through the Virtual Asset Service Providers Act, 2025 and its implementing Regulations, 2026 (L.N. 134), which designate VASPs as reporting institutions under the Proceeds of Crime and Anti-Money Laundering Act. The designation triggers customer due diligence and know-your-customer obligations, suspicious transaction reporting to the Financial Reporting Centre, record-keeping, and transfer-level transaction-information duties with a seven-year retention period, operationalised through a dual Central Bank of Kenya / Capital Markets Authority licensing regime. Existing virtual-asset businesses have until 4 November 2026 to come into compliance.

Other Developments

The gambling sector's AML supervision architecture is now in force. The AML/CFT Laws (Amendment) Act, 2025, in force since 20 June 2025 and fully effective from March 2026, amended the Proceeds of Crime and Anti-Money Laundering Act and the Betting, Lotteries and Gaming Act to give the gambling regulator vetting, onsite and offsite inspection, and consolidated-supervision powers over gambling-sector reporting institutions for AML, CFT and counter-proliferation-financing purposes.

Kenya remains on the FATF increased-monitoring list following the 19 June 2026 plenary, having missed its own May 2026 target exit date. The Financial Reporting Centre's own Director-General has cited a funding shortfall as an obstacle to a credible exit plan: the FRC's FY2026/27 budget request of Sh2.49bn was cut to an allocation ceiling of Sh765.5m, leaving, on the Director-General's own account, zero operational funds after fixed costs are met.

Tether and the Nairobi Securities Exchange signed a memorandum of understanding on 28 July 2026 covering tokenised-securities infrastructure, blockchain-based settlement, and the development of a Kenya-specific AML/KYC framework for digital-asset market participants. This commercial development runs in parallel with, and is distinct from, the statutory AML perimeter established by the VASP Act and Regulations.

Cross-Monitor Connections

The VASP Act and Regulations' designation of digital-asset businesses as reporting institutions intersects directly with the crypto monitor's tracking of Kenya's new licensing regime, where the same instrument is read primarily through a market-access and capital-requirement lens rather than an AML-designation lens. The draft National Payment System Bill tracked by world-payments, which proposes bringing VASPs offering payment services within a unified payments perimeter, will interact with this AML designation once the payments legislation is finalised, since a VASP licensed as a payment provider would sit under two overlapping supervisory regimes.

Outlook

The FRC's funding position is the structural variable most likely to determine whether Kenya's grey-list exit timeline, already missed once in May 2026, slips further past the next FATF plenary expected in Q4 2026. A funding shortfall at the agency tasked with producing a credible exit plan is, on its own terms, a material constraint independent of the substantive legislative reforms already enacted. Separately, the 4 November 2026 VASP transition deadline will test whether the dual CBK/CMA licensing and AML-designation regime is operationally ready to process existing virtual-asset businesses at scale.

4 Oct 2026 · fim-2026-10-04

Lead Signal

Kenya was retained on the FATF list of Jurisdictions under Increased Monitoring at the 19 June 2026 Plenary, alongside 21 other jurisdictions. FATF's statement acknowledged reform progress but kept Kenya's exit conditional on unresolved action items concerning supervision quality, STR filing standards and prosecution rates. This is the structural fact governing Kenya's financial-integrity posture this cycle: an increased-monitoring designation that has not moved toward delisting despite continued institutional reform activity. Structurally, the persistence of the grey-list designation across a Plenary cycle while reform work continues is more analytically significant than any single enforcement action, because it signals that Kenya's supervisory architecture — rather than any discrete failure — remains the object of concern.

Other Developments

A CBK/CMA split licensing perimeter is now the operative crypto architecture. Kenya's Virtual Asset Service Providers Act, 2025 commenced 4 November 2025, and the implementing Virtual Asset Service Providers Regulations, 2026 were gazetted as Legal Notice No. 134, Kenya Gazette Supplement No. 185, dated 22 July 2026. The Regulations split ten licensable virtual-asset activities between the Central Bank of Kenya and the Capital Markets Authority. FATF's February 2026 statement specifically recognised Kenya's adoption of this legal framework for licensing and supervising virtual asset service providers as a positive step in the country's reform trajectory. A compliance deadline looms. Existing virtual-asset operators must obtain licences under the new framework by 4 November 2026; as of late July 2026 reporting, no firm had yet been licensed. This creates a structural test of the new architecture's practical bite: a framework recognised by FATF as credible remains, for now, untested against an informal market that has operated without licensing to date.

Institutional coordination intensified in September. Kenya's Director of Public Prosecutions chaired a 23 September 2026 meeting of law-enforcement and financial-sector principals to review outcomes of the FATF Africa Joint Group meeting held in Abidjan on 11 September 2026, aimed at accelerating Kenya's grey-list exit. The Financial Reporting Centre remains Kenya's designated reporting entity and financial intelligence unit under POCAMLA as amended, though funding constraints have been reported as a friction point in the exit effort — an enablement-relevant signal, since a funding-constrained FIU is itself a structural limitation on supervisory capacity regardless of the legal framework's design.

Cross-Monitor Connections

The VASP licensing architecture described above is the same underlying development that the crypto monitor's licensing, stablecoin and cross-border modules address from a digital-asset-market perspective; here it is read as an AML/CFT supervisory-perimeter question rather than a market-structure one — specifically, whether a CBK/CMA split licensing regime with a not-yet-tested compliance deadline can deliver the STR filing standards and supervisory quality that FATF's continued grey-listing implicitly demands. The gambling-sector guidance to casinos on targeted financial sanctions implementation, referenced under this jurisdiction's separate D1 tracking, is a further adjacent AML/CTF obligation layered onto a non-bank sector, though it did not carry sufficient signal to warrant its own domain sub-brief this cycle.

Outlook

The near-term marker to watch is 4 November 2026, the VASP licensing compliance deadline. Whether any licences have been granted by that date will be the clearest available signal of whether Kenya's newly recognised legal framework is translating into operative supervisory capacity, which is precisely the kind of evidence FATF will weigh in any future Plenary review of Kenya's Increased Monitoring status. The 23 September 2026 coordination meeting following the Abidjan Africa Joint Group review suggests continued institutional pressure toward an exit strategy, but no confirmed delisting timeline exists as of this cycle.

Domain intelligence (D1–D8)

D1 Sanctions

no_change

Prevention of Terrorism (Implementation of UNSCR on Suppression of Terrorism) Regulations, 2026 (LN 172/2026) gazetted 7 September 2026, latest iteration of Kenya's domestic TFS implementing instrument.

D2 Beneficial Ownership

watch

Beneficial Ownership and Corporate Transparency

Kenya's beneficial-ownership picture this cycle shows movement on two separate tracks that should not be conflated. At the national level, the FATF's June 2026 assessment of Kenya's standing identified ownership transparency as one of seven areas still requiring further action before the country can exit the increased-monitoring list. That gap concerns the general corporate and legal-person ownership-disclosure architecture that underpins the country's anti-money-laundering framework, and it remains open as of the October 2026 plenary, where Kenya was retained among the eighteen listed jurisdictions.

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Separately, and on a narrower sectoral track, Kenya has gazetted the Gambling Control (Licensing) Regulations 2026, which introduce a specific beneficial-ownership and corporate-control disclosure duty applicable to gambling licensees. This sector-specific requirement reinforces transparency and accountability within the gambling licensing regime itself, but it does not substitute for, or resolve, the national-level ownership-transparency gap the FATF has flagged. The two developments sit at different altitudes: one is a sector-specific compliance obligation newly placed on a defined population of licensees, the other is a structural gap in the national disclosure regime that FATF assessors continue to track as a condition of grey-list exit.

This divergence is itself a notable pattern. Kenya is building beneficial-ownership disclosure obligations piecemeal, sector by sector, rather than through a single consolidated national register initiative moving in step with FATF's stated expectations. Whether the accumulation of sectoral disclosure duties, in gambling and potentially elsewhere, eventually adds up to something that satisfies the national-level gap, or whether it remains a parallel patchwork that leaves the core deficiency unaddressed, is a live question bearing directly on the credibility of the April 2027 exit target that Treasury has set for itself.

For institutions and counterparties operating in or through Kenya, the practical implication is that beneficial-ownership verification currently rests on a fragmented set of sources rather than a single authoritative national register. Due diligence on Kenyan corporate structures and, now, gambling licensees specifically, will need to account for the existence of sector-specific disclosure duties that may carry different enforcement mechanisms and different levels of public accessibility than a unified register would provide.

Outlook

The near-term question is whether Kenya moves toward consolidating beneficial-ownership disclosure into a single national mechanism ahead of the April 2027 FATF exit target, or continues to add sector-specific duties, as it has just done for gambling, without closing the structural gap FATF identified in June 2026. The next FATF review point will likely test whether sectoral accumulation is treated as credible partial progress or as a parallel track that leaves the core deficiency unresolved. Continued attention to how the gambling-sector disclosure duty is implemented and enforced in practice, as distinct from its mere gazettal, will be a useful proxy for whether Kenya's broader transparency commitments are operationalising or remaining largely declaratory.

Cumulative analysis

Beneficial Ownership and Corporate Transparency

Kenya's Business Registration Service continues to intensify enforcement of the beneficial-ownership disclosure regime established under section 93A of the Companies Act, 2015 and given operative detail in the Companies (Beneficial Ownership Information) Regulations, 2020. Non-compliance now carries a fixed penalty of KES 500,000 plus a daily accruing fine of KES 50,000 for continuing non-compliance, escalating in persistent cases to deregistration risk, the most severe sanction available against a corporate entity short of criminal referral. This is a domestically anchored compliance-architecture story rather than a single enforcement event: the BRS is not announcing prosecutions so much as tightening the administrative machinery, penalty notices, deregistration threat, that sits behind the register's day-to-day operation.

The significance of this within Kenya's own regulatory perimeter is direct. Beneficial-ownership transparency is a named deficiency area in Kenya's ESAAMLG/FATF mutual evaluation, and continued BRS enforcement pressure is the domestic remediation track most directly responsive to that finding. It should be read as evidence of administrative capacity-building rather than as a completed remediation; the claims describing enforcement intensity here rest on secondary legal-commentary sources rather than published BRS compliance statistics, and the actual compliance rate achieved by this enforcement regime remains unquantified in the material available this cycle.

Globally, the structural backdrop against which any BO/transparency signal should now be read is the European Union's AML Package, even though Kenya sits well outside its direct perimeter. The Package comprises three distinct instruments: the AML Regulation (AMLR, Regulation (EU) 2024/1624), which applies directly across the bloc without national transposition; the sixth AML Directive (6AMLD), which each Member State transposes into domestic law on its own timeline; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority itself. Together these shift the EU's beneficial-ownership and broader AML supervisory perimeter from a purely national-authority model toward a hybrid regime in which AMLA exercises direct supervision over a defined set of higher-risk cross-border obliged entities and indirect, coordinating supervision over the rest. This is standing architecture, not a single-cycle development, and it is not the primary subject matter for Kenya's own BO transparency track; it is the durable global reference point against which the domestic BRS enforcement story sits, illustrating what a more institutionally mature, multi-layered BO-transparency supervisory architecture eventually looks like as a point of comparison rather than as a direct constraint on Kenyan corporate registries.

Outlook

The domestic watch point is whether BRS's tightening enforcement posture converts into a measurable compliance-rate improvement ahead of Kenya's next FATF Plenary review, or whether it remains, as this cycle's evidence base suggests, an administrative signal without yet a published outcome metric. No further beneficial-ownership-specific reform, such as amendments to the disclosure thresholds or a public BO-register access model, was identified this cycle. The absence of a T1 primary source confirming the scale of enforcement action is itself a gap worth flagging for the next cycle's research pass.

domain_sub_briefs · D2 · Cumulative analysis
Standing baseline position

AML/CFT Amendment Act 2025 extends BO record-retention (10 years) and disclosure obligations for companies/LLPs; central registry contemplated with authorities-only access.

Periodic updates (2)
3 Nov 2026 · fim-2026-11-03

Beneficial Ownership and Corporate Transparency

In Kenya, the directly relevant beneficial-ownership development this period is a Treasury signal of intent to tighten disclosure enforcement, reported as part of a stated ambition to exit the Financial Action Task Force's increased-monitoring category by April 2027. This is reported as a policy-intent statement, not as a new statute, regulation or gazetted instrument; no legal text accompanies it at this time, and it is treated here as an unconfirmed signal of direction rather than a structural change. It sits against the backdrop of Kenya's continued increased-monitoring status, entered in February 2024, and a Financial Action Task Force statement dated 19 June 2026 that is reported to identify seven outstanding action items standing between Kenya and removal from that category; the content of those action items, including whether beneficial-ownership transparency is among them, has not been independently confirmed.

Globally, the European Union's three-instrument anti-money-laundering package sets the structural direction for beneficial-ownership and corporate-transparency supervision: a directly applicable Anti-Money Laundering Regulation, a sixth Anti-Money Laundering Directive transposed individually by each member state, and an Anti-Money Laundering Authority Regulation establishing a new Authority with direct and indirect supervisory powers over cross-border obliged entities. That architecture shifts supervision of the highest-risk obliged entities from purely national authorities toward a hybrid regime combining national and European Union-level oversight. Kenya sits outside that package's direct perimeter; it is not a European Union member state and is not subject to the Anti-Money Laundering Authority's supervisory reach. The package is relevant to Kenya only indirectly, as part of the international landscape against which bodies such as the Financial Action Task Force and European Union list-makers assess third countries, and as the kind of structural benchmark that a jurisdiction such as Kenya, seeking to demonstrate strengthened beneficial-ownership controls as part of its own increased-monitoring exit case, might be measured against by counterpart regulators and correspondent banks even without being bound by the European instruments themselves.

The practical significance for firms and counterparties dealing with Kenyan entities is that beneficial-ownership transparency in Kenya remains, on the evidence available this period, a matter of stated government intent rather than of enacted legal obligation. Firms conducting due diligence on Kenyan corporate structures should treat the absence of a new disclosure instrument as the operative fact, while noting that the direction of travel, as reported, points toward tightening rather than loosening. The gap between signalled intent and enacted instrument is itself the data point worth carrying forward: a jurisdiction can declare an enforcement ambition well before, or indeed without, the legal architecture to support it, and the two should not be conflated when assessing current exposure.

Outlook

Whether Treasury's stated intent converts into an actual beneficial-ownership instrument is likely to become clearer as Kenya approaches its targeted April 2027 exit date from increased monitoring, since a credible exit case before the Financial Action Task Force would typically require demonstrable legal and institutional steps rather than policy statements alone. Until a specific instrument, register amendment or regulatory circular is published and retrieved, this domain remains a signal to monitor rather than a structural change to report, and this brief will continue to flag it as such.

D5 Crypto / Digital Assets / Financial Innovation

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Crypto, Digital Assets, and Financial Innovation

The defining development in Kenya's digital-asset space this cycle is not a new rule but the expiry of an old deadline. Section 47 of the Virtual Asset Service Providers Act, 2025 set a one-year transition window for existing operators, and that window closed on 4 November 2026. The accompanying Virtual Asset Service Providers Regulations, 2026, gazetted as Legal Notice 134 of 2026 on 22 July 2026, are now in force and impose a KSh 300 million minimum capital requirement on stablecoin issuers, alongside customer due diligence, transaction monitoring, sanctions-screening, suspicious-transaction-reporting, and mixer and tumbler prohibitions aligned to FATF standards. As the deadline passed, reporting available at the time indicated that no virtual asset service provider had yet been licensed by either the Central Bank of Kenya or the Capital Markets Authority, the two bodies jointly responsible for licensing under the regime. Secondary legal commentary indicates that operating without a licence becomes a criminal offence from 5 November 2026.

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The significance of this is architectural rather than incidental. Kenya has built, on paper, one of the more comprehensive virtual-asset AML/CFT frameworks in the region, covering the full span of FATF-aligned obligations expected of regulated financial intermediaries. But a regime's substantive force depends on licensing capacity existing to bring operators inside it, and the available evidence as the deadline passed suggests that capacity had not yet caught up with the statute. This creates an unusual interim state: a population of operators that was until recently operating in a transitional grace period now sits, nominally, outside the law, while the institutions meant to license them have not yet completed that process for any applicant. Absence of visible enforcement action against this unlicensed population in the days immediately following the deadline is itself worth watching, since persistent non-enforcement in a newly binding regime says as much about regulatory capacity as an enforcement action would.

This sits directly against the backdrop of Kenya's FATF increased-monitoring status, since digital-asset and virtual-currency related AML/CFT deficiencies are a common theme in FATF assessments of jurisdictions under review, and weak supervision of a newly regulated sector is unlikely to help the case for exit. The timing is consequential: the licensing vacuum opened in the same window as Treasury's public assertion that nineteen of twenty-one FATF-identified deficiencies have been remedied, and continued visible non-implementation of the virtual-asset licensing regime could be read as working against the remediation narrative Treasury is advancing toward an April 2027 exit target.

Outlook

The near-term signal to watch is whether the Central Bank of Kenya or the Capital Markets Authority issues the first substantive VASP licence in the weeks following the 4 November 2026 deadline, and whether any enforcement action is taken against operators continuing to function without one. A continued licensing vacuum stretching into 2027 would be a materially different signal than a rapid clearing of a backlog of pending applications, and the distinction between the two will matter considerably to how FATF assessors weigh Kenya's digital-asset supervision capacity against its stated remediation progress.

Cumulative analysis

Crypto, Digital Assets, and Financial Innovation

Kenya's Virtual Assets Service Providers Act, 2025 came into force on 4 November 2025, following gazettal on 21 October 2025, formally bringing virtual-asset service providers into the country's AML/CFT/CPF obliged-entity perimeter for the first time. The Act names the Central Bank of Kenya and the Capital Markets Authority as joint regulators, splitting oversight along functional lines rather than creating a standalone virtual-asset authority. This is a direct, structural response to a deficiency named in Kenya's ESAAMLG mutual evaluation: the absence of any supervised VASP perimeter, a gap FATF's Recommendation 15 requires jurisdictions to close.

It is important to be precise about what is, and is not, operative. The obliged-entity designation is statutory and in force; the licensing regime that would make it operational is not. As of the National Treasury's March 2026 draft VASP Regulations, neither CBK nor CMA has licensed a single virtual-asset service provider, and the substantive prudential and conduct detail, capital adequacy, safeguarding of client assets, reporting formats, remains contingent on regulations still moving through consultation. In practical terms, Kenya has built the legal shell of a VASP-supervision regime before populating it with the operative rules that would let a service provider actually become licensed, register a compliance officer, or face a supervisory examination. This sequencing, statute first, implementing detail later, is common in emerging-market crypto regulation but it does leave an interim supervisory gap: virtual-asset activity continues in Kenya during this window without an operative licensing check, even though the obliged-entity status nominally already applies.

The joint-regulator structure itself carries an analytical dimension worth surfacing. By splitting responsibility between CBK, whose institutional core competence lies in payment systems and monetary stability, and CMA, whose core competence lies in securities and investment products, Kenya has implicitly pre-classified virtual-asset activity into payment-like and investment-like categories without yet publishing a formal token taxonomy. How cleanly that split holds in practice, particularly for hybrid instruments that combine payment and investment characteristics, will be one of the more consequential unresolved questions once licensing actually begins.

The claim underlying this obliged-entity designation is assessed at the highest confidence tier available in this cycle's evidence base, anchored to a Tier-1 primary source: CBK's own public notice on the Act. That is a meaningfully stronger evidentiary footing than much of the secondary-source commentary elsewhere in this cycle's Kenya coverage, and it means the in-force status of the VASP Act, as distinct from its operative licensing detail, can be treated as a settled structural fact rather than a probable or assessed one. The obliged-entity category also implicitly captures VASP counterparties as a defined customer typology under Kenya's evolving framework, which, once licensing commences, will require CBK- and CMA-supervised entities to apply customer due diligence to virtual-asset counterparties in a manner analogous to existing bank and securities-sector obligations. Until licensing is operative, however, this due-diligence obligation exists on paper without a supervised population of licensed entities against which to apply it.

Outlook

The next concrete marker is the finalisation of the VASP Regulations, 2026, expected in the fourth quarter of 2026 following continuing consultation between the National Treasury, CBK and CMA. Until that instrument is issued, no licensing activity should be expected, and the sector's practical AML/CFT exposure remains defined by statutory obligation without corresponding supervisory examination capacity. Whether the finalised regulations preserve the CBK/CMA functional split or consolidate elements of it will be the first substantive test of how the institutional architecture translates into operative supervision.

domain_sub_briefs · D5 · Cumulative analysis
Standing baseline position

The one-year VASP Act transition deadline expired 4 November 2026 with no VASP yet licensed by CBK or CMA; FATF-aligned AML/CFT obligations are now formally binding on a substantially unlicensed operator population.

Periodic updates (4)
3 Nov 2026 · fim-2026-11-03

Crypto, Digital Assets, and Financial Innovation

Kenya's own virtual-asset regulatory perimeter is the dominant fact in this domain this period. The Virtual Asset Service Providers Act, 2025 designates the Central Bank of Kenya and the Capital Markets Authority as joint regulators of virtual asset service providers, and the accompanying Virtual Asset Service Providers Regulations, 2026 set out the licensing and registration conditions those providers must meet. The Act opened a one-year transitional compliance window on its 4 November 2025 commencement, requiring providers to obtain a licence from the Central Bank of Kenya or the Capital Markets Authority and to register as a reporting institution under the Proceeds of Crime and Anti-Money Laundering Act before continuing to operate; that window closed on 4 November 2026, after which unlicensed operation becomes a criminal offence. Secondary legal commentary reported, with the deadline then under a month away, that no provider had yet achieved licensed status, leaving the sector's compliance position as the window closed unresolved on the evidence available.

A specific and unresolved technical question sits inside this transition: whether the gazetted 2026 regulations reference the Financial Action Task Force's Travel Rule, the originator-and-beneficiary information requirement that typically accompanies virtual-asset transfers above a prescribed threshold. One secondary legal source describes Travel Rule-style originator and beneficiary information obligations as part of the regime; another describes the gazetted regulations as not referencing the Financial Action Task Force Travel Rule by name at all. These two characterisations are in direct tension, and the underlying gazette text has not been independently retrieved this period to resolve which reading is correct. This is treated as a disputed point rather than an settled obligation, and firms relying on either characterisation for their own compliance posture should treat the underlying instrument, not secondary commentary, as the authority to consult.

Globally, structural developments such as the Markets in Crypto-Assets framework in the European Union and the Financial Action Task Force's own virtual-asset standards form the backdrop against which national regimes such as Kenya's are increasingly measured, but they are not the operative law for virtual asset service providers in Kenya; the operative law is the 2025 Act and its 2026 Regulations, applied by the Central Bank of Kenya and the Capital Markets Authority. The practical consequence of the unresolved licensing position as the transitional window closes is a jurisdiction-specific supervisory gap: a sector that was required, as of 4 November 2026, to be licensed and registered, apparently operating in large part without either, at least as far as public secondary reporting could establish. That gap is itself the structural signal worth tracking, independent of any individual enforcement action, since the significance of a transition deadline lies as much in whether the regulators subsequently act on an unlicensed sector as in the deadline's passing.

Outlook

The period immediately following the 4 November 2026 deadline is the point at which the next readable signal should emerge: either confirmation that providers have obtained licences, or visible enforcement action against those operating without one, or continued silence that would itself suggest a supervisory capacity gap. Resolution of the Travel Rule reference dispute, once the gazetted text is read directly rather than through secondary summary, would materially sharpen the assessment of how closely Kenya's virtual-asset regime tracks the Financial Action Task Force standard it is nominally built against.

D6 Compliance Technology & Active Defence

no_changestanding position

Compliance Technology and Active Defence

Kenya's clearest active-defence signal this cycle sits not inside the core AML/CFT institutions but at the tax authority. The Kenya Revenue Authority has integrated real-time monitoring across more than 100 betting operators, and KRA-linked commentary attributes a roughly fivefold rise in gambling-sector tax collections to that integration, from KSh 5.7 billion in the 2021/22 financial year to KSh 28.45 billion by April 2026. The figure is a tax-administration outcome rather than a directly AML/CFT one, but the underlying capability, real-time transactional visibility across a large, previously opaque cash-intensive sector, is the same class of SupTech infrastructure that a financial-integrity supervisor would want for market-abuse or suspicious-transaction detection.

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That read-across is not this cycle's speculation alone: the evidence base notes that the Central Bank of Kenya has signalled interest in extending a comparable real-time monitoring posture toward market-abuse detection more broadly, beyond the betting-sector deployment where the capability has so far been proven out. This is a single-source, T2-sourced development, and the compliance-technology narrative here rests on one illustrative data point rather than a documented CBK programme; it is flagged as a genuine but thin signal rather than a confirmed institutional rollout.

Outlook

Whether KRA's regtech capability is formally extended to, or replicated by, CBK's AML/CFT supervisory function is the development to watch. No implementation timeline or regulatory instrument establishing such an extension was identified this cycle.

D7 AML/CTF Regime

watch

AML/CTF Regime

Kenya's position in the global anti-money-laundering architecture was confirmed rather than changed at the FATF's October 2026 plenary. Four jurisdictions were removed from the increased-monitoring list at that sitting, and none were added, leaving eighteen jurisdictions listed, Kenya among them. National Treasury Principal Secretary Chris Kiptoo has stated publicly that Kenya has remedied nineteen of the twenty-one deficiencies the FATF originally identified, with an April 2027 target for full exit. This is a claim of substantial self-reported progress, though it rests on government statements rather than a directly retrieved FATF plenary document, and the underlying June 2026 FATF assessment is understood to have identified seven areas still requiring action, including ownership transparency, financial intelligence, money-laundering investigations and prosecutions, and risk-based supervision.

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The most concrete structural development reinforcing the regime this cycle is the entry into force of the Virtual Asset Service Providers Act's AML/CFT provisions, which bring customer due diligence, travel-rule compliance, suspicious-transaction reporting to the Financial Reporting Centre, sanctions screening, and a prohibition on anonymising mixer and tumbler services into formal effect for the digital-asset sector. On paper, this closes a gap that FATF assessors have flagged in prior reviews of virtual-asset supervision. In practice, the one-year transition deadline for existing operators expired on 4 November 2026 with no licences yet granted by either the Central Bank of Kenya or the Capital Markets Authority, meaning the architecture is formally complete but its population of regulated entities is not yet actually regulated. This is the kind of gap between legislative completion and supervisory capacity that FATF's risk-based supervision criterion is specifically designed to test, and it bears directly on whether the claimed remediation of the financial intelligence and supervision deficiencies will be accepted as genuine by FATF assessors rather than merely declaratory.

Taken together, the architecture-over-incident reading is that Kenya has done substantial legislative and regulatory drafting work across its AML/CTF framework in 2026, but the test that matters for an April 2027 exit is not whether rules exist, it is whether supervisory bodies can demonstrate they are applying them to real populations of obliged entities. The virtual-asset licensing vacuum is the clearest current test case of that distinction, and it sits alongside the unresolved national beneficial-ownership transparency gap as the two most consequential open items standing between Kenya and the exit Treasury has publicly targeted.

Outlook

The period between now and the FATF's next scheduled review will likely be dominated by whether Kenya can show the financial intelligence and supervision deficiencies have moved from legislated to operational, with virtual-asset licensing throughput as the most visible proxy. A credible showing of licences granted and enforcement actions taken against unlicensed operators would materially strengthen the case for an April 2027 exit; continued visible inaction on licensing would cut the other way, regardless of how the self-reported deficiency count is framed.

Baseline-Tracked Domains with No Current-Cycle Escalation (2 of 8)
  • D3 Enabler Jurisdictions: Standing coverage — no activity this cycle.
  • D4 Conflict Finance: Standing coverage — no activity this cycle.
Regulatory horizon
In Force2026-12 · ±quarter

EU Commission next high-risk third country list update

Following the pattern of updates tracking FATF Plenary outcomes, the Commission is expected to issue its next delegated regulation update around year-end 2026, determining whether Kenya remains listed into 2027.
Source
Proposed2026-Q4 · ±quarter

Next FATF plenary (October 2026) - possible Kenya grey-list review

Possible plenary statement on Kenya's grey-list status; outcome not yet known as of this cycle
FATF Source
In Force Pending2026-Q4 · ±quarter

VASP licensing go-live under VASP Act/Regulations 2025-2026

First cohort of licensed VASPs expected to emerge; unlicensed crypto activity becomes an active enforcement target thereafter.
CBK / CMA Source
In Force Pending2026-Q4 · ±quarter

VASP Act 2025 transitional compliance deadline for existing operators

Persons already providing virtual-asset services must come into compliance with the licensing and AML/CFT regime by 4 November 2026
Central Bank of Kenya / Capital Markets Authority Source
Consultation2027-Q1 · ±half_year

FATF Africa Joint Group face-to-face evaluation of Kenya grey-list exit progress

Kenyan agencies are preparing for a face-to-face engagement with the FATF Africa Joint Group that will recommend on Kenya's grey-list status.
FATF / ESAAMLG Source
In Force Pending2027-Q1 · ±year

FATF ICRG follow-up / Kenya grey-list exit plan

Continued enhanced due diligence expected on KE counterparties pending FATF's assessment of operational effectiveness.
FATF / National Treasury Source
Consultation2027-Q2 · ±multi_year

FATF grey-list exit

Removal from increased monitoring would reduce correspondent-banking and cross-border due-diligence friction for Kenyan institutions.
FATF / Kenya FRC Source
7 dated · 3 pending date · baseline fim-2026-07-05
Role action cards
MLRO

The virtual-asset AML/CFT regime is now formally in force but its licensed population is effectively empty as of early November 2026.

Suspicious-transaction-reporting, travel-rule and sanctions-screening obligations under the VASP Act are now binding, but counterparty due diligence on Kenyan virtual-asset operators cannot currently rely on licensing status as a reliability signal, since no licences had been confirmed granted as the transition deadline passed.

1 evidence refs
Compliance

Kenya remains on the FATF increased-monitoring list after the October 2026 plenary, with Treasury citing substantial self-reported remediation progress.

Enhanced due-diligence posture toward Kenyan counterparties should continue pending a confirmed exit; the gap between Treasury's remediation claims and FATF's own outstanding action items, including ownership transparency and risk-based supervision, is not yet closed.

1 evidence refs
Legal

Operating a virtual asset business in Kenya without a licence is reported to become a criminal offence from 5 November 2026.

Clients with Kenyan virtual-asset exposure face a live legal-exposure question given the reported criminalisation of unlicensed operation alongside an apparent absence of granted licences at the point the transition deadline expired.

1 evidence refs
Board

Kenya's grey-list exit trajectory and its new virtual-asset licensing regime are moving on different timelines, creating reputational and regulatory-exposure questions for institutions with Kenyan links.

The April 2027 exit target set by Treasury is a material institutional risk marker; the unresolved licensing vacuum in the virtual-asset sector is a concrete test of whether that target is credible.

2 evidence refs
CTO

A comprehensive virtual-asset compliance architecture, including a stablecoin capital threshold and travel-rule obligations, is now formally in force in Kenya without a confirmed licensed population to apply it to.

Technical integrations with Kenyan virtual-asset platforms should account for the current absence of confirmed licensing status as a verifiable counterparty attribute.

1 evidence refs
Risk

A structural gap between legislated AML/CFT architecture and actual supervisory capacity has opened in Kenya's virtual-asset sector at the same moment Treasury is asserting grey-list remediation progress.

This is a capacity-deficit risk rather than a deliberate-enablement risk, but it is material to exposure assessments on Kenyan virtual-asset counterparties and to confidence in the broader remediation narrative.

2 evidence refs
Operations

Screening and monitoring workflows touching Kenyan virtual-asset counterparties cannot currently rely on licensing confirmation as a control point.

Until licensing throughput becomes visible, operational screening should treat Kenyan VASP counterparty status as unverified rather than assume licensing has completed given the deadline has passed.

1 evidence refs
Audit

Documentation supporting Kenya's self-reported FATF remediation progress (19 of 21 deficiencies) rests on government statement rather than a directly verified primary FATF document.

Audit trails citing Kenya's grey-list trajectory should note the provenance distinction between Treasury's public remediation claims and FATF's own published assessment findings.

1 evidence refs
Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo KE-specific signal identified this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable to this non-EEA autonomous jurisdiction.
T3 · FATF Grey ListwatchOctober 2026 plenary removed four jurisdictions, added none; Kenya remains among 18 listed jurisdictions. Treasury targets April 2027 exit.
T4 · Beneficial-Ownership Register StatuswatchFATF flags ownership-transparency gaps; gambling-sector BO disclosure duty introduced as a parallel sector-specific development.
T5 · Crypto & Digital-Asset Integritymaterial_changeVASP transition deadline passed 4 Nov 2026 with no licences yet granted.
T6 · Sanctions Regime Divergenceno_changeNo KE-specific divergence signal identified this cycle.
Registers

Enforcement actions

  • 28 Mar 2025
  • 24 Oct 2025
  • 9 Dec 2025
  • 13 Feb 2026
  • 19 Jun 2026
  • OFAC added a Kenyan national to the SDN list under counter-terrorism authority (Executive Order 13224, as amended), designating him as a senior Al-Shabaab figure subject to secondary sanctions risk. 28 Mar 2025
  • At the October 2025 Plenary, FATF reviewed Kenya's continued implementation of its February 2024 action plan, noting sensitisation activities, FIU dissemination increases and enhanced interagency TF-investigation cooperation at the border, while confirming continued grey-list status. 24 Oct 2025
  • EACC investigation established embezzlement of approximately KES 2 billion from Migori County (2013-2017) via irregular procurement; international cooperation through the IACCC enabled mutual legal assistance and asset tracing across jurisdictions, concluding in an out-of-court settlement. 9 Dec 2025
  • At the February 2026 Plenary, FATF recorded Kenya's adoption of a legal framework for licensing and supervision of virtual asset service providers and a sustained increase in TF investigations and prosecutions in line with its risk profile. 13 Feb 2026
  • At the June 2026 Plenary, FATF confirmed Kenya remains under increased monitoring, reiterating the seven outstanding action-plan items including risk-based supervision, STR filing, trust/BO authority designation, financial intelligence quality, ML/TF prosecutions, TFS compliance and NPO framework reform. 19 Jun 2026

Sanctions changes

  • 28 Mar 2025
  • 9 Dec 2024
  • 4 Feb 2026
  • The European Commission adopted Delegated Regulation (EU) 2025/1184 (10 June 2025), adding Kenya to the EU list of high-risk third countries with AML/CFT strategic deficiencies, requiring EU obliged entities to apply enhanced due diligence to Kenya-linked transactions. 10 Jun 2025
  • HM Treasury updated its Money Laundering Advisory Notice following the FATF October 2025 Plenary, listing Kenya as a 'High-Risk Third Country' under Regulation 33 of the UK Money Laundering Regulations, triggering mandatory enhanced due diligence for UK-regulated firms. 24 Oct 2025
  • OFAC updated the SDN List to add a Kenyan national (Abdikadir Mohamed Abdikadir, alias 'Ikrima') under counter-terrorism authority for links to Al-Shabaab, with secondary sanctions risk attached. 28 Mar 2025
  • The European Commission's December 2025 update (Delegated Regulations (EU) 2026/46 and 2026/83) delisted Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania from the EU high-risk third country list, while Kenya was retained, underscoring Kenya's comparatively slower reform trajectory relative to regional peers. 4 Dec 2025

Regulatory horizon (register)

  • EU Commission next high-risk third country list update
  • VASP licensing go-live under VASP Act/Regulations 2025-2026
  • FATF ICRG follow-up / Kenya grey-list exit plan
  • VASP licensing go-live under VASP Act/Regulations 2025-2026
  • FATF Africa Joint Group face-to-face evaluation of Kenya grey-list exit progress
  • AML/CFT Laws (Amendment) Act, 2025 - full operational effect
  • VASP Act 2025 transitional compliance deadline for existing operators
  • Next FATF plenary (October 2026) - possible Kenya grey-list review
  • VASP licensing compliance deadline
  • Proliferation-financing regulations to close final FATF action items
  • FATF grey-list exit
  • VASP Act/Regulations transitional compliance deadline
  • Kenya targets FATF grey-list exit
  • FATF October 2026 Plenary review of Kenya's action plan
  • Designation of trust-regulation and BO-verification authority
  • CBK/CMA operational rollout of VASP licensing regime
  • EU Commission next high-risk third country list update

Active schemes

  • [HIGH] Kenya as regional gold-smuggling transit hub
  • [HIGH] Nairobi-based Al-Shabaab facilitation and MVTS network
  • Legacy grand-corruption PEP layering via UAE shells
  • Emerging VASP sector amid nascent licensing regime
Sources
  1. The draft Money Laundering and Terrorist Financing (Amendment and Miscellaneous Provision) Regulations 2025 - Policy note - GOV.UK
  2. https://www.fatf-gafi.org/en/countries/detail/Kenya.html
  3. https://new.kenyalaw.org/akn/ke/act/2025/6/eng@2025-06-20
  4. https://www.parliament.go.ke/node/23702
  5. https://www.ey.com/en_gl/technical/tax-alerts/kenya-s-new-anti-money-laundering-law-adds-compliance-obligation
  6. https://techcabal.com/2026/07/24/kenya-virtual-asset-service-providers-regulations/
  7. https://www.trigarc.com/insights/fatf-grey-list-kenya-aml-cft
  8. Financial Reporting Centre (Kenya)
  9. Capital FM Kenya
  10. FATF
  11. TLA Advocates
  12. Zigram
  13. Trigarc
  14. KnowYourCountry
  15. Sanctions Lawyers
  16. https://new.kenyalaw.org/akn/ke/act/2009/9/eng@2025-11-04
  17. https://amluae.com/fatf-grey-list-countries-update-19th-june-2026/
  18. https://locallistingdealz.com/kenyas-push-to-exit-the-fatf-grey-list/
  19. https://ynews.digital/development-news/kenya-aml-cft-reforms-exit-fatf-grey-list-2026/
  20. https://bowmanslaw.com/insights/kenya-from-grey-to-green-vasp-act-and-the-road-out-of-fatfs-watchlist/
  21. https://snnyagaadvocates.co.ke/kenya-vasp-regulations-2026-what-virtual-asset-businesses-should-do-next
  22. https://en.cryptonomist.ch/2026/07/28/tether-nse-partnership-kenya/
  23. https://riskhouse.co.ke/the-anti-money-laundering-and-combating-of-terrorism-financing-laws-amendment-act-2025-is-your-business-ready-for-march-2026/
  24. https://peopledaily.digital/business/kenya-targets-april-2027-exit-from-anti-money-laundering-grey-list
  25. https://kenya-today.com/report-kenya-aims-to-leave-fatf-grey-list-by-april-2027-after-clearing-19-of-21-action-points-11071/
  26. https://new.kenyalaw.org/akn/ke/act/ln/2026/172/eng@2026-09-07
  27. https://www.oraro.co.ke/virtual-asset-service-providers-regulations-2026/
  28. https://new.kenyalaw.org/akn/ke/act/ln/2026/134/eng@2026-07-22
  29. https://manwaadvocates.com/anti-money-laundering-aml-in-kenyas-gambling-industry-compliance-reporting-guide/
  30. bne IntelliNews
  31. Checklynx
  32. Kenya Law
  33. Global Law Experts
  34. Central Bank of Kenya
  35. Vellum Advocates
  36. https://www.intellinews.com/kenya-targets-april-2027-fatf-grey-list-exit-with-tighter-ownership-disclosure-rules-478788
  37. https://checklynx.com/en/resources/knowledge-base/fatf-grey-list
  38. https://new.kenyalaw.org/akn/ke/act/2025/14/eng@2025-08-12
  39. https://globallawexperts.com/vasp-licensing-kenya/
  40. https://tladvocates.com/2026/08/14/unpacking-the-gazetted-virtual-asset-service-providers-regulations-2026/
  41. https://www.centralbank.go.ke/uploads/press_releases/665231223_Public%20Notice%20on%20the%20Virtual%20Assets%20Service%20Providers%20Act%202025.pdf
  42. https://vellum.co.ke/kenyas-virtual-asset-regime-enters-compliance-phase-as-vasps-face-november-deadline/
  43. Kenya Today
  44. Data Protection Digest Africa
  45. CM Advocates
  46. Jurisdictions under Increased Monitoring - 19 June 2026
  47. Jurisdictions under Increased Monitoring - 13 February 2026
  48. "Black and grey" lists
  49. Jurisdictions under Increased Monitoring - 13 June 2025
  50. Jurisdictions under Increased Monitoring - 24 October 2025
  51. Kenya
  52. Jurisdictions under Increased Monitoring - 21 February 2025
  53. Jurisdictions under Increased Monitoring - 23 February 2024
  54. Countries / Jurisdictions
  55. Mutual Evaluation of Kenya
  56. Kenya's measures to combat money laundering and terrorist financing
  57. Kenya's progress in strengthening measures to tackle money laundering and terrorist financing
  58. Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG)
  59. Advancing AML/CFT initiatives in the South and Eastern Africa region
  60. Ethiopia's measures to combat money laundering and terrorist financing
  61. News
  62. Uganda's measures to combat money laundering and terrorist financing
  63. FATF contributes to AML/CFT discussions in Eastern and Southern Africa
  64. Malawi's progress in strengthening measures to tackle money laundering and terrorist financing
  65. Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance
  66. European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance
  67. Anti-money laundering and countering the financing of terrorism at international level - Finance
  68. High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission
  69. List of countries in the scope of the EU assessment on high ...
  70. EU methodology for the identification of high-risk third countries - Finance
  71. INFORM Risk - Results and data - DRMKC - European Union
  72. INFORM > INFORM Risk > Country Risk Profile - DRMKC
  73. UNODC Regional Office for Eastern Africa
  74. Enhancing Financial Investigation Capabilities of Law Enforcement Agencies to Combat Money Laundering and Terrorist Financing
  75. United States Department of the Treasury Financial Crimes Enforcement Network - Home | FinCEN.gov
  76. Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering, Combating the Financing of Terrorism, and Counter-Proliferation Deficiencies | FinCEN.gov
  77. Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs
  78. 2025 Crypto Regulatory Round-Up
  79. Ghana Passes Law to Legalize Widespread Use Of Cryptocurrency - Bloomberg
  80. How crypto regulation changed in 2025: a global review
  81. Crypto regulatory affairs: CLARITY Act Senate compromise meets mixed reception
  82. Crypto regulatory affairs: OCC gives US banks go-ahead on riskless crypto transfers
  83. Global crypto regulation review 2025
  84. Crypto regulatory affairs: CLARITY Act Senate delay creates uncertainty
  85. Breaking Down Brazil’s New Crypto Framework
  86. Crypto regulatory affairs: Hong Kong introduces Stablecoin Bill in further boost to crypto hub status
  87. Comprehensive Update on Terrorist Financing Risks FATF REPORT July 2025
  88. FATF report highlights evolving terrorist financing risks and warns of gaps in global understanding of the threats
  89. CTED Trends Tracker Evolving Trends in the Financing of Foreign Terrorist
  90. The role of Hawala and other similar service providers in money laundering and terrorist financing
  91. fatf REPORT THE ROLE OF HAWALA AND OTHER SIMILAR SERVICE PROVIDERS
  92. FinCEN Advisory, FIN-2025-A001, April 1, 2025
  93. FATF REPORT Emerging Terrorist Financing Risks October 2015
  94. fatf REPORT TERRORIST FINANCING IN WEST AFRICA October 2013
  95. UK and Kenya sign new Defence Cooperation Agreement to tackle shared threat from Al-Shabaab - GOV.UK
  96. Africa Gold Advisory
  97. RESPONDING TO ILLEGAL MINING AND TRAFFICKING IN METALS AND MINERALS
  98. Stories from UNODC
  99. Part 2b – Minerals Crime: Illegal Gold Mining
  100. UNODC Regional Office for Eastern Africa
  101. Jurisdictions under Increased Monitoring - 13 June 2025
  102. Kenya Is a Hub for Smuggled African Gold, Report Says - Bloomberg
  103. Sanctions Programs and Country Information | Office of Foreign Assets Control
  104. Home | Office of Foreign Assets Control
  105. Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control
  106. Counter Terrorism Designations; Issuance of General License; Publication of Amended Global Magnitsky Sanctions Regulations | Office of Foreign Assets Control
  107. Recent Actions | Office of Foreign Assets Control
  108. Sanctions List Updates
  109. Sanctions List Search Tool | Office of Foreign Assets Control
  110. 2023 Civil Penalties and Enforcement Information | Office of Foreign Assets Control
  111. Five steps to effective cryptocurrency sanctions compliance in 2026
  112. Archive of Changes to OFAC's Sanctions Lists | Office of Foreign Assets Control
  113. Counter Terrorism Designations; Administrative List Updates: Addition of Secondary Sanctions Information | Office of Foreign Assets Control
  114. ​Counter Terrorism Designations | Office of Foreign Assets Control
  115. Counter Terrorism Designations and Designation Update; Libya Designation Removal; Issuance of Russia-related General License | Office of Foreign Assets Control
  116. Counter Terrorism Designations Removals | Office of Foreign Assets Control
  117. Global Magnitsky Designations; Syria-related Designation Update | Office of Foreign Assets Control
  118. Sanctions List Service | Office of Foreign Assets Control
  119. Security Council Al-Shabaab Sanctions Committee Adds Three Entries to Its Sanctions List | Meetings Coverage and Press Releases
  120. Counter Terrorism Designations | Office of Foreign Assets Control
  121. Kenya Suspends Eyeball-Scanning Crypto Project Worldcoin - Bloomberg
  122. From trading bans to total embrace, a global guide to crypto regulation
  123. Global Crypto Policy Review & Outlook 2024/2025 Report | TRM Labs
  124. 2025 Crypto Crime Report
  125. Crypto Sanctions: 2026 Crypto Crime Report
  126. FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth
  127. Cyprus, Ghana and Kenya join growing list of countries to create beneficial ownership registries - ICIJ
  128. 1. Definition of beneficial ownership and mechanisms for ...
  129. U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov
  130. Beneficial Ownership Information Reporting | FinCEN.gov
  131. Frequently Asked Questions | FinCEN.gov
  132. Small Entity Compliance Guide
  133. Small Entity Compliance Guide | FinCEN.gov
  134. Beneficial Ownership Information Reporting Filing Instructions
  135. BOI E-FILING - FinCEN
  136. Small Business Resources | FinCEN.gov
  137. International cooperation in the Migori County corruption case - National Crime Agency
  138. The Ethics and Anti-Corruption Commission DIRECT ASSET RECOVERY
  139. The Cost of Kenya’s ‘Budgeted Corruption’ | OCCRP
  140. Launch of the Report on Corruption and Unethical Conduct in the Kenyan Health Care Projects
  141. Digest of Asset Recovery Cases
  142. FATF releases detailed guidance to help practitioners recover criminal assets
  143. 1 Country Review Report of The Republic of Kenya
  144. UNODC Regional Office for Eastern Africa
  145. Corruption and Good Governance KENYA University Module Series Anti-Corruption
  146. Kenyan Police Fire Guns to Save Colleagues from Anti-Graft Bust | OCCRP
  147. Virtual Asset Service Provider (VASP): Definition, Compliance & Examples
  148. 1 EASY GUIDE TO FATF STANDARDS AND METHODOLOGY Virt ual Asset s:
  149. Virtual Assets
  150. Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers
  151. Virtual Assets and Virtual Asset Service Providers
  152. New FATF report highlights illicit finance risks linked to Offshore VASPs
  153. Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK
  154. Money Laundering Advisory Notice: June 2026 - GOV.UK
  155. Anti-Money Laundering and Terrorist Financing Directive 4 - Finance
  156. Page 1 of 4 HM Treasury Advisory Notice: Changes to the FATF’s Public Lists
  157. High-risk third countries
  158. The draft Money Laundering and Terrorist Financing (Amendment and Miscellaneous Provision) Regulations 2025 - Policy note - GOV.UK
  159. ESAAMLG (FATF-Style Regional Body, mutual evaluation of Kenya)
  160. FATF
  161. FATF
  162. European Commission
  163. HM Treasury (UK)
  164. OFAC (US Department of the Treasury)
  165. OFAC (US Department of the Treasury)
  166. UK National Crime Agency
  167. Bloomberg
  168. ICIJ
  169. OCCRP
Coverage gaps
fim-int-2026-07-07-G001: Primary-source confirmation of the …
fim-int-2026-07-07-G001: Primary-source confirmation of the enactment status and operative date of Kenya's Trust Administration Bill 2025 (designating the Registrar of Companies as trust/BO authority) was not established in the reviewed research corpus. [resolved]
fim-int-2026-07-07-G002: The finalisation and gazettement da…
fim-int-2026-07-07-G002: The finalisation and gazettement date of Kenya's draft VASP Regulations 2026 (public consultation closed April 2026) was not established this cycle. [resolved]
fim-int-2026-07-07-G003: No dedicated OFAC/OFSI/EU designati…
fim-int-2026-07-07-G003: No dedicated OFAC/OFSI/EU designation or investigative reporting establishing a confirmed (as opposed to latent/structural) link between Kenya-based intermediaries and Russian sanctions-evasion architecture was identified. [resolved]
fim-int-2026-07-07-G004: No reform roadmap or timeline for m…
fim-int-2026-07-07-G004: No reform roadmap or timeline for making Kenya's beneficial-ownership register publicly accessible was identified in the reviewed sources. [resolved]
fim-int-2026-07-07-G005: Aggregate financial-value estimates…
fim-int-2026-07-07-G005: Aggregate financial-value estimates for Al-Shabaab-linked MVTS/hawala flows transiting Kenya were not available in the reviewed corpus, limiting quantification of scheme materiality beyond qualitative designations. [resolved]
fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1 Sanctions Architecture (KE-specific) evidence not located this cycle. [resolved]
fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): D4 Conflict Finance (KE-specific) evidence not located this cycle. [resolved]
fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Enforcement actions (KE-specific fines/prosecutions this cycle) not located; awaiting primary source. [resolved]
fim-int-2026-09-05-G004 ({'scheme': 'financial_integrity', '…
fim-int-2026-09-05-G004 ({'scheme': 'financial_integrity', 'value': 'D5'}): No direct CBK/CMA primary-page text retrieved this cycle for the VASP Regulations text itself. [resolved]
fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Outcome of the Kenyan High Court's 2 October 2026 judgment on the Gambling Control (Licensing) Regulations' fee/capital schedules is not yet available; GRA's own account states it runs AML and consumer-protection due diligence on pending licence applications, so the outcome has an AML-adjacent dimension. [resolved]
fim-int-2026-10-04-G002: No Mexico- or Colombia-specific Oct…
fim-int-2026-10-04-G002: No Mexico- or Colombia-specific October 2026 material surfaced despite a dedicated Tier D sweep; status quo recorded per mandatory-collection rule rather than omitted. [resolved]
fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Exact reserve-composition and segregation rules for CBK-approved stablecoin issuers under the VASP Regulations 2026 were not located; the gazetted regulation text (Legal Notice 134) was not independently read this cycle. [resolved]
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No T1 FATF.org primary statement directly retrieved confirming the 19 June 2026 plenary outcome for Kenya. [resolved]
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 gazette text of VASP Regulations 2026 (L.N. 134) directly retrieved this cycle. [resolved]
fim-int-2026-10-11-G003: Tier D watch jurisdictions (KH, LA,…
fim-int-2026-10-11-G003: Tier D watch jurisdictions (KH, LA, MX, CO) were not actively searched this cycle because the pooled research budget was prioritised to Kenya. [resolved]
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary FATF plenary statement retrieved confirming Kenya's 19-of-21 action-item progress; relies on secondary reporting of FRC testimony to Parliament. [resolved]
fim-int-2026-10-18-G002: Tier D jurisdictions (KH, LA, MX, C…
fim-int-2026-10-18-G002: Tier D jurisdictions (KH, LA, MX, CO) were not reached this cycle given the pooled search budget bound to a single-JID dispatch. [resolved]
fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): No primary FRC/GRA notice located confirming the AML supervisory handover from BCLB to GRA for the gambling sector. [resolved]
fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Tier-D watch jurisdictions (KH/LA/MX/CO) were not researched in this single-jurisdiction dispatch per the union operator routing lock. [open]
fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3 (Enabler Jurisdictions) and D4 (Conflict Finance) had thin or not-applicable coverage this cycle. [open]
fim-int-2026-11-01-G005 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G005 ({'scheme': 'financial_integrity', 'value': 'D1'}): No enforcement actions or sanctions changes identified/sourced this cycle. [open]
fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): Primary FATF statement of 19 June 2026 naming Kenya's seven outstanding action-plan items was not independently retrieved; reliance is on secondary summary. [open]
fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Conflicting secondary commentary on whether the gazetted VASP Regulations, 2026 reference the FATF Travel Rule was not resolved against the primary gazetted text. [open]
fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-08-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No primary FATF.org plenary document was directly retrieved this cycle; the plenary outcome and the Treasury's self-reported 19/21 remediation figure rest on secondary press. [open]
fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', '…
fim-int-2026-11-08-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No CBK/CMA primary licensing register was retrieved to confirm whether any VASP has been licensed since the 4 November 2026 deadline. [open]
fim-int-2026-11-08-G003: Tier D jurisdictions (KH, LA, MX, C…
fim-int-2026-11-08-G003: Tier D jurisdictions (KH, LA, MX, CO) were not swept this cycle; this is an out-of-scope coverage gap, not a no-material-change finding, since the dispatch was single-jurisdiction-bound to KE. [open]
FIM-GAP-001 (D3): Despite reform commitments since February …
FIM-GAP-001 (D3): Despite reform commitments since February 2024, FATF's June 2026 statement continues to flag inadequate risk-based AML/CFT supervision of financial institutions and DNFBPs in Kenya, with insufficient outreach to increase STR filing.
FIM-GAP-002 (D2): No authority has been designated for the r…
FIM-GAP-002 (D2): No authority has been designated for the regulation of trusts and the collection of accurate, up-to-date beneficial ownership information, an outstanding action-plan item repeated unchanged across every FATF statement from February 2024 through June 2026.
FIM-GAP-003 (D3): Kenya's NPO oversight framework has not ye…
FIM-GAP-003 (D3): Kenya's NPO oversight framework has not yet been revised to ensure that mitigating measures are risk-based and proportionate, an unresolved item across all FATF statements through June 2026.
FIM-GAP-004 (D1): Declared Kenyan gold exports (672kg in 202…
FIM-GAP-004 (D1): Declared Kenyan gold exports (672kg in 2023) are a small fraction of the estimated 2+ tonnes/year of gold smuggled through the country from the DRC and South Sudan, indicating minimal detection capacity in the precious-metals trade chain.
FIM-GAP-005 (D2): Kenya's beneficial ownership register, ope…
FIM-GAP-005 (D2): Kenya's beneficial ownership register, operational since 2020 under Companies Act amendments, remains non-public, limiting independent verification by journalists, civil society and foreign counterparts despite pressure from transparency advocates documented by ICIJ.

Evidence

Confidence-tiered claims

Requested KES 2.49bn for FY2026/27, received allocation ceiling of KES 765.5m, leaving zero discretionary operational funds after fixed costs. [Source 1]
Probable · 1 source
Requires CDD prior to onboarding, sanctions screening and STR reporting to the FRC; imposes seven-year transaction-information retention instead of naming the FATF Travel Rule. [Source 1]
Probable · 1 source
VASP Regulations 2026 Regulation 83 lets CBK direct licensed intermediaries to restrict access to or trading in a foreign-issued stablecoin, a currency-control-style lever framed as a financial-stability safeguard. [Source 1]
Probable · 1 source
Kenya remains on the FATF increased-monitoring list following the 19 June 2026 plenary (22-jurisdiction list, Iraq added); outstanding action-plan items include DNFBP risk-based supervision and beneficial-ownership transparency. [Source 1]
Probable · 1 source
Raised beneficial-ownership and director/shareholder information retention to a minimum of 10 years from the date a person ceases to hold that status; introduced a nominee-director register. [Source 1]
Probable · 1 source
Announced designation of 13 individuals under targeted financial sanctions linked to terrorism financing, ordering immediate asset freezes under POT-TFR 2024. [Source 1]
Probable · 1 source
Remains on the FATF Jurisdictions under Increased Monitoring list as of the 19 June 2026 plenary [Source 1]
Probable · 1 source
VASPs designated as reporting institutions under POCAMLA, triggering CDD/KYC, STR reporting to FRC, record-keeping and transfer-level transaction-information duties (7-year retention) under dual CBK/CMA licensing [Source 1]
Probable · 1 source
Gives BCLB/GRA vetting, onsite/offsite inspection and consolidated-supervision powers over gambling-sector reporting institutions for AML/CFT/CPF purposes [Source 1]
Probable · 1 source
MoU covering tokenised-securities infrastructure, settlement, and a Kenya-specific AML/KYC framework, signed 28 July 2026 [Source 1]
Probable · 1 source
FY2026/27 budget request of Sh2.49bn cut to an allocation ceiling of Sh765.5m, leaving zero operational funds after fixed costs [Source 1]
Probable · 1 source
19 of 21 [Source 1]
Probable · 1 source
April 2027 [Source 1]
Probable · 1 source
In force, gazetted 22 July 2026, dual CBK/CMA licensing across ten licence categories [Source 1]
Probable · 1 source
2026-11-04 [Source 1]
Probable · 1 source
7 September 2026; reviewed by Parliament's Committee on Delegated Legislation 13 October 2026 [Source 1]
Probable · 1 source
GRA carries risk-based AML inspections of casinos/online betting; BO disclosure required at licensing (s.30, Second Schedule) [Source 1]
Probable · 1 source
Treasury targets April 2027 exit; FATF 19 June 2026 statement identified 7 outstanding action items [Source 1]
Probable · 1 source
2026-11-04 [Source 1]
Disputed · 1 source
MLRO designation, AML/CFT internal control systems, risk-based inspections required of all GRA licensees [Source 1]
Uncertain · 1 source
under increased monitoring since February 2024; remained listed as of the 19 June 2026 plenary statement citing seven outstanding action items [Source 1]
Probable · 1 source
CBK- or CMA-licensed virtual asset service providers in Kenya must be registered as POCAMLA reporting institutions with CDD, STR filing to the FRC and sanctions screening; one-year transitional compliance window closes 4 November 2026 [Source 1]
Disputed · 1 source
every GRA licensee must appoint a money-laundering reporting officer, maintain AML/CFT internal controls and be subject to AML risk-based inspections as a POCAMLA reporting institution [Source 1]
Uncertain · 1 source
plans to strengthen beneficial-ownership disclosure enforcement for companies and trusts as part of the FATF grey-list exit strategy targeting April 2027 [Source 1]
Uncertain · 1 source
Remains on FATF increased-monitoring list after October 2026 plenary; 18 jurisdictions remain listed after four removals. [Source 1]
Probable · 1 source
One-year transition deadline (s.47) expired 4 November 2026; no VASP yet licensed by CBK or CMA; operating without a licence reported to become a criminal offence from 5 November 2026. [Source 1]
Probable · 1 source