Kenya — Country Risk Report

Kenya (Africa • East Africa). Risk report as of the 19 Jun 2026 FATF plenary.

High country risk, with AML/CFT effectiveness gaps. Kenya's country risk score is 6.7/10, placing it in the high-risk band. The principal score driver is AML/CFT effectiveness, contributing 4.2 of 6.7 points. Separately, the treatment overlays show that Kenya is subject to FATF increased monitoring, and that Kenya is not subject to comprehensive country-wide sanctions and has no direct country-level programme identified. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Enhanced due diligence on every relationship, with senior approval and enhanced ongoing monitoring.

At a glance

• FATF status: Grey list (one indicator only; it does not set the overall country risk rating by itself)
• No direct country-level sanctions programme identified; sanctions remain a legal treatment overlay and applicable lists must still be screened.
• Governance and institutions: 5.5/10
• Corruption (CPI 2025): 30/100, rank #130 of 182
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 6.7/10 (High)

Higher score means higher country risk (global average 5.5). Full information available. Composite score. Strong supporting evidence. Enforcement activity and CPI are context only; FATF listing and sanctions are regulatory overlays except the labelled FATF listing status used where no mutual evaluation exists.

All three underlying risk pillars are available. All three underlying risk pillars are available and weighted using the published formula. Weight sensitivity 6.5–7.0/10.

How this score was calculated

• AML/CFT effectiveness: 9.4/10 — 45% of this score
• Technical compliance: 2.9/10 — 20% of this score
• Governance and institutions: 5.5/10 — 35% of this score

Sanctions treatment: No direct programme identified. FATF treatment: increased monitoring.

Principal risk drivers

• AML/CFT effectiveness: 9.4/10 × 45% = 4.2 points
• Governance and institutions: 5.5/10 × 35% = 1.9 points
• Technical compliance: 2.9/10 × 20% = 0.6 points

Mitigating factors

• No comprehensive country-wide sanctions programme.
• Comparatively stronger voice and accountability (4.9/10).
• Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

• Customer onboarding (Enhanced): Verify ultimate beneficial ownership and control from more than one source.
• Payments and transactions (Enhanced): Review transaction purpose, counterparties and the full payment routing.
• Trade and export activity (Enhanced): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Enhanced): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Enhanced): Alert on ownership changes, new designations and status changes.

Recommended controls

• Verify ultimate beneficial ownership using more than one reliable source.
• Identify state ownership, government influence and politically exposed persons.
• Screen entities, directors and beneficial owners against applicable sanctions lists.
• Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
• Document transaction purpose and source of funds where cross-border structures are complex.
• Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

• State ownership / control
• PEP involvement
• Sensitive / restricted sectors
• Opaque ownership
• Adverse media
• Dual-use goods & technology
• High-risk intermediary routing

FATF status: Grey list

Jurisdiction Under Increased Monitoring. Last reviewed 19 Jun 2026; next FATF plenary Oct 2026.

Source details

International sanctions by issuing body

• UN: No
• EU: No
• UK: No
• US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

• Government Effectiveness: 46/100
• Regulatory Quality: 50/100
• Rule of Law: 49/100

Regulators and legal framework

FATF network

FATF network via ESAAMLG.

• Eastern and Southern Africa Anti-Money Laundering Group

Last mutual evaluation: 2023 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member (FRC Kenya)

Framework signals

• FATF listing: Grey list
• International sanctions: no direct country programme identified (legal treatment overlay remains applicable)
• BO register: Public (live since 2020)
• Corruption (CPI 2025): 30/100, rank #130 of 182
• Rule of law (WGI): 5.2/10 risk

Regulatory ecosystem and enforcement visibility

This evidence map is separate from Country Risk v3. It describes official mandates, publication access and RegActions coverage; it does not judge regulatory strength or add points to country risk.

Transparency Index: not scored · Evidence disposition: local-authority-evidence · Mapped official authorities: 5.

Evidence level: Level 1: Identity confirmed. The ladder uses the authority evidenceLevel schema directly and does not infer a level from a URL, site access or RegActions feed count.

1. 1. Identity confirmed — The authority and its mandate are evidenced by official directory provenance.
2. 2. Regulatory activity visible — A qualified authority-owned route has provisional dated activity in the first-page scan.
3. 3. Enforcement visible — A qualified authority-owned enforcement route has provisional dated activity in the first-page scan.
4. 4. Score eligible — Shown only when the authority evidence schema explicitly records score-eligible; no authority currently does.

Enforcement visibility: No authority is classified enforcement-visible or score-eligible in the authority evidence schema. Enforcement visibility remains unknown or limited to identity/activity evidence; this is not evidence of no enforcement.

Authorities and mandate evidence

• Capital Markets Authority — Level 1: Identity confirmed · Official site returned an error

  Mandates: Securities · Access status: Official site returned an error · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

• Central Bank of Kenya — Level 1: Identity confirmed · Official site reachable

  Mandates: Central bank, Prudential supervision · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: Public Notices

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: news_or_notice · Source scope: authority-owned · Qualification: manual-review-required · Provisional scan signal: low-frequency-first-page-signal · Observed months: 1 · Latest observed month: 2026-05

• Insurance Regulatory Authority — Level 1: Identity confirmed · Official site challenge-protected

  Mandates: Insurance · Access status: Official site challenge-protected · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: Public Notice: Placement of Kenyan Insurance Business With Unlincensed Insurers

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: unknown · Observed months: unknown · Latest observed month: unknown

  • Unqualified publication candidate: Legal Notices

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not-observable · Source scope: not-observable · Qualification: browser-review-required · Provisional scan signal: unknown · Observed months: unknown · Latest observed month: unknown

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

• Retirement Benefits Authority — Level 1: Identity confirmed · Official site reachable

  Mandates: Pensions · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: Notices

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: news_or_notice · Source scope: authority-owned · Qualification: manual-review-required · Provisional scan signal: active-first-page-signal · Observed months: 19 · Latest observed month: 2026-08

  • Unqualified publication candidate: KNBS unveils 2026 Survey of Other Financial Corporations (OFCs)

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: not classified · Source scope: not classified · Qualification: not classified · Provisional scan signal: not-observable · Observed months: 0 · Latest observed month: unknown

• The Financial Reporting Centre (FRC) Kenya — Level 1: Identity confirmed · Official site timed out

  Mandates: Financial intelligence · Access status: Official site timed out · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

• Banking & payments (Elevated): FATF increased-monitoring overlay raises correspondent risk
• Trade & export controls (Low): No direct sanctions or FATF call-for-action overlay identified
• Crypto & virtual assets (Elevated): FATF increased-monitoring overlay raises VASP supervision risk
• Real estate & luxury assets (High): BO subscore 6.8/10; CPI context 30/100
• State-linked & procurement (High): Effectiveness pillar risk is 9.4/10

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Kenya: analysis

Kenya combines a weak governance profile with current FATF grey listing. Corruption is the strongest risk driver, followed by rule of law and institutions and political stability. Voice and accountability is the comparatively lower-risk domain. Kenya carries no sanctions exposure. The CPI ranking confirms a below-median position on transparency, and Kenya sits below the median of assessed jurisdictions on the World Bank governance indicators. No enforcement actions are recorded in the dataset.

Outlook

Kenya's FATF grey-list status means it is subject to increased monitoring and must demonstrate progress on its action plan before delisting. The October 2026 plenary represents the next key review milestone. Sustained reform of AML supervision and beneficial-ownership registries would be required for the risk picture to improve materially. Without delisting, the FATF overlay will remain in place.

Key watchpoints

• Track FATF progress reports and the outcome of the October 2026 plenary for any delisting or escalation decision.
• Monitor developments in beneficial ownership transparency and AML supervisory effectiveness.
• Apply enhanced due diligence and ongoing monitoring to all Kenya-connected customers and transactions.
• Review correspondent banking and trade finance exposures against updated FATF action-plan compliance milestones.

Assessment currency

• FATF status: Increased monitoring (as of 19 Jun 2026)
• Sanctions exposure: None identified (as of Jul 2026)
• Governance (WGI): Latest dataset incorporated (as of 2024)
• Corruption (CPI): 30/100 (as of 2025)
• RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: increased monitoring. FATF identifies the jurisdiction as under increased monitoring; apply the firm's risk-based controls and monitor remediation progress.

Contextual signals (not scored)

• FATF network membership: FATF regional network: ESAAMLG (present, as of 2026-07)
• EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
• Egmont Group FIU: FRC Kenya (present, as of 2026-07-17)
• Beneficial-ownership register: Public (live since 2020) (present, as of 2026-08-23)
• Transparency International CPI: 30/100, rank 130 (present, as of 2025)

Evidence freshness

• FATF monitored-jurisdiction status: current; data 2026-06-19
• FATF mutual evaluation and follow-up ratings: current; data 2026-08-24; follow-up 2024-08; base assessment 2023-01
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-30

Contextual signals are public evidence only and do not change the current country-risk score.

Download evidence PDF · CSV · JSON

Contextual risk evidence (not scored)

These eight evidence families provide context only. They do not change the v3.1 headline score. Unavailable means no reviewed, country-comparable evidence is currently ingested; it does not mean the risk is absent.

• Organised crime: Not available. No reviewed country-level organised-crime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Fraud and cybercrime: Not available. No reviewed country-level fraud or cybercrime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Terrorism and proliferation financing: Not available. No reviewed country-comparable terrorism/proliferation threat dataset is currently checked in; FATF listing status remains a separate overlay. Candidate sources are research leads only; they have not been ingested as evidence.
• Trafficking: Not available. No reviewed country-level trafficking dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Financial secrecy and offshore exposure: Not available. No reviewed, licence-clean financial-secrecy index is currently checked in; jurisdiction type alone is not used as a proxy. Candidate sources are research leads only; they have not been ingested as evidence.
• Tax cooperation: Not listed in EU Annex I. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
• Political stability and conflict: 43/100 WGI percentile. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Source
• Beneficial ownership: Register accessible for due diligence. The Open Ownership map is a live-register snapshot and absence means no register was identified in that snapshot, not that no register exists. Source

Regional peer scores

• Eritrea: 8.7/10 (Very high)
• Central African Republic: 8.2/10 (Very high)
• Chad: 8.0/10 (Very high)
• Democratic Republic of the Congo: 7.9/10 (Very high)
• Equatorial Guinea: 7.9/10 (Very high)
• Somalia: 7.9/10 (Very high)

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)