Kenya — Country Risk Report

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

High country risk, with elevated corruption risk. Kenya's country risk score is 6.0/10, placing it in the high-risk band. The principal driver is weak corruption, alongside political stability risk. Kenya is subject to FATF increased monitoring. Kenya is not subject to comprehensive country-wide sanctions. 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.

At a glance

• FATF status: Grey list (one indicator only; it does not set the overall country risk rating by itself)
• Comprehensive country sanctions: none identified. Targeted sanctions exposure: possible, screen applicable persons, entities and sectors
• Government effectiveness and rule of law: 5.5/10
• Corruption (CPI 2025): 30/100, rank #130 of 182
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 6.0/10 (High)

Higher score means higher country risk (global average 4.6). Full information available. Strong data coverage. Enforcement activity and CPI are shown for context but do not change the score.

All three parts of the score are available.

How this score was calculated

• Financial crime controls: 7.5/10 — 50% of this score
• Government effectiveness and rule of law: 5.5/10 — 30% of this score
• International sanctions: 0.0/10 — 20% of this score
• FATF grey-list status means the score cannot be lower than 6.0. This minimum set the final score.

International sanctions contributes 0.0 because the complete UN, UK, EU and US review found no direct country-level sanctions programme. People or organisations connected to the country may still appear on sanctions lists.

Principal risk drivers

• FATF increased-monitoring status
• Corruption (WGI) — 6.8/10
• Political stability — 5.7/10
• Rule of law & institutions — 5.2/10

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 (High): Additional ownership and control verification may be required.
• Payments and transactions (High): Review transaction purpose, counterparties and geographic routing.
• Trade and export activity (High): Screen goods, end users and potential dual-use exposure.
• Corporate clients (High): Assess state ownership, government links and political exposure.
• Ongoing monitoring (High): Apply alerts for ownership changes, sanctions and geopolitical developments.

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 listed programme identified
• BO register: Public (live since 2020)
• Corruption (CPI 2025): 30/100, rank #130 of 182
• Rule of law (WGI): 5.2/10 risk

Sector exposure

• Banking & payments (Elevated): FATF grey-list status elevates correspondent-banking risk
• Trade & export controls (Low): No sanctions programme or FATF black-list constraint identified
• Crypto & virtual assets (Elevated): FATF grey-list VASP supervision gaps raise virtual-asset risk
• Real estate & luxury assets (Elevated): Elevated corruption exposure (CPI 30/100)
• State-linked & procurement (Elevated): State-capture exposure (corruption WGI 6.8/10)

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 2026-07-17)
• 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 2026-07-31; follow-up 2024-08; base assessment 2023-01
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-13

Contextual signals are public evidence only and do not change the immutable v2 score.

Download evidence PDF · CSV · JSON

Regional peer scores

• Central African Republic: 7.8/10 (Very high)
• Democratic Republic of the Congo: 7.6/10 (Very high)
• Somalia: 7.3/10 (Very high)
• South Sudan: 7.3/10 (Very high)
• Sudan: 7.1/10 (Very high)
• Eritrea: 6.9/10 (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)