Supervisory bodies

Sectors covered

Regulators reading crypto

National FIU (the FRC)

02The regulatory landscape

Who supervises in Kenya

Kenya runs a layered supervisory architecture: sectoral regulators license and conduct-supervise, while one financial-intelligence unit, the Financial Reporting Centre, carries the AML/CFT reporting weight across the whole regime. Map four things before you write a policy:

Which body holds your file.
Which one licenses you, and which merely registers you.
Where your suspicious-transaction reports run to. These are not always the same body, and the distinction changes what you must build.
Where a sector has no dedicated AML regulator, the FRC supervises AML directly: no sectoral licence gate, so the AML obligation to the FRC is the obligation.

One structural point sits apart: Kenya's strategic-goods control regime is not yet operational. The Strategic Goods Control Committee is a proposed body under the Strategic Goods Control Bill, 2024. We do not assert obligations a live statute has not yet created.

VASP & crypto

CBKCMA CBK and CMA are both engaged on virtual-asset and crypto activity, so a crypto operator can face a dual supervisory read, not a single owner. The CMA's public licensees register is the reference for who is authorised on the capital-markets side.

Payments & MSB

CBK CBK licenses money-remittance and payment-service providers and maintains the directory of licensed money-remittance providers. Standing is confirmed there; the programme behind it is judged against CBK's framework.

Banks & FIs

CBK CBK is the prudential and conduct regulator for the banking core: commercial banks, mortgage-finance institutions and non-operating holding companies, all on its published reference directory.

Funds & CSP

CMAFRC CMA regulates funds, fund administrators and the broader investment sector, with its licensees register as the public record. Corporate and trust service providers have no dedicated regulator: AML-supervised directly by the FRC, so the AML programme is the entire regulated surface.

Gold & DPMS

SDMFRC Precious-metals and mining activity sits with the State Department for Mining and the Director of Mines, under the Ministry of Petroleum and Mining, with AML exposure reporting to the FRC.

Gaming

BCLBGRA Gaming is licensed by the Betting Control and Licensing Board, which publishes its licence information, while a Gambling Regulatory Authority is forming under a reformed framework.

Real estate & DNFBP

EARBFRCLSKICPAK Real estate runs through the Estate Agents Registration Board, which registers estate agents and estate-agent companies and publishes that register. For DNFBP professions, self-regulatory bodies apply: the Law Society of Kenya for lawyers, ICPAK for accountants, each sitting under the FRC's AML mandate rather than replacing it.

Defence & dual-use

SGCC The Strategic Goods Control Committee is a proposed body under the Strategic Goods Control Bill, 2024; the regime is not yet operational. What exists today: the export-control screening and integrity exposure dual-use trade already creates for exporters, banks and payment operators, under sanctions and correspondent-banking pressure that does not wait for the Bill.

Art & high-value

FRC No dedicated regulator. Art, auction and high-value dealers are AML-supervised directly by the Financial Reporting Centre, the country's FIU and the destination for suspicious-transaction reporting, record-keeping and risk-based obligations. The absence of a bespoke supervisor does not reduce the obligation.

Every regulator above is drawn from the verified Kenya regulator matrix. The GRA transition and the Strategic Goods Control Bill are tracked as they move: we state a commencement date, threshold or penalty only after verifying it with the named body. The framework requires the programme behind the authorisation to be examinable now, not at some future date.

03Who operates here, and what they build

A licence is a permission. The programme is the proof that you can hold it. In Kenya the point is sharper: for whole categories, corporate and trust service providers, art and high-value dealers, there is no licence to hide behind and the AML programme is the entire regulated surface. Whichever body supervises you, the expectation converges on the same spine:

01A documented, board-owned AML/CFT policy set that maps to your actual products, customers and geographies, not a template.

02A risk-based customer due-diligence and enhanced-due-diligence model, with beneficial-ownership and source-of-funds logic that survives scrutiny.

03Sanctions and export-control screening calibrated to Kenya's exposure as a regional trade, remittance and financial hub, with a defensible list-management and escalation process.

04A named, competent MLRO with a governance line the supervisor can test.

05A working financial-intelligence function that files suspicious-transaction reports to the FRC and holds records to standard.

06Ongoing monitoring, testing and independent audit, so the programme is not just built once but demonstrably run.

Most operators can draft the first version. Fewer can prove, on a regulator's visit, that it lives. That gap is our work. The licence is the easy part. We build what sits behind it.

04By sector here

How we serve every sector here

Nine sectors. Even weight. No flagship. Every one fully served in this market. If a sector is not the right fit for us, we say so before you engage.

VASP & cryptoA CBK and CMA supervisory pairing on a fast-maturing framework. We build the AML/CFT, Travel Rule and sanctions programme a dual review expects, and run it where you need a bridge. Payments & MSBCBK-licensed remittance and payment operators: the monitoring, screening and reporting spine, calibrated to Kenya's mobile-money and remittance corridors. Banks & FIsFull programme build, remediation and independent audit for CBK-licensed banks, mortgage-finance institutions and holding companies, with bridge MLRO capacity. Funds & CSPCMA-licensed funds and administrators, plus FRC-supervised corporate and trust service providers with no licence to lean on. Gold & DPMSDealers alongside the State Department for Mining, with the risk-based CDD, thresholds and STR discipline the FRC expects of a high-value, cash-intense trade. GamingBCLB-licensed operators, with a Gambling Regulatory Authority forming under reform: CDD, player-funds monitoring and suspicious-transaction reporting for a mobile-first market. Real estate & DNFBPEARB-registered agents, plus lawyers and accountants under the LSK and ICPAK, all inside the FRC's AML mandate. Defence & dual-useThe strategic-goods regime is proposed, not live. We build the export-control, screening and integrity programme dual-use trade already demands today. Art & high-valueFRC-supervised dealers and auction houses: CDD, provenance and reporting controls where the AML obligation is the whole regulated surface.

See all sectors → All markets →

05The five service lines, in this market

01
Licensing and new-regime programme build. The AML/CFT and sanctions programme that has to sit behind a CBK, CMA, BCLB or EARB position, or behind an FRC-supervised business with no licence gate at all, built to the standard the supervisor inspects to.
02
Remediation. Rebuilding the programme after an enforcement action or a supervisory finding, on a fixed scope, with a defensible closure trail.
03
Outsourced and bridge MLRO, plus a managed FIU function. A named, competent officer and a working suspicious-transaction reporting line into the FRC while you recruit, scale, or stabilise after a departure.
04
Independent AML audit. The independent test a supervisor expects, run by people who did not build the thing they are testing.
05
Sanctions, export-control and integrity due diligence. Counterparty, corridor and beneficial-owner work, including the FATF Travel Rule for virtual-asset operators and the dual-use exposure Kenyan trade already carries.

Full scope of what we do →

06The operator-side value

Conflict-free

We build the programme that protects the licence holder. We sell no software, take no commission and carry no product to place. Our only interest is that your programme holds. We are the reviewer, not the seller.

Senior-only

Practitioner-grade work, CAMS and ICA credentialled, delivered by senior hands. No leverage pyramid, no junior drafting against a template.

Fixed scope, fixed fee

No hourly billing. You get a defined engagement and a costed plan within 48 hours. No open meter.

Five service lines, one spine, and all five apply in Kenya. Grounded, never guessed: we state a regulatory requirement only when we can source it, and where a specific date or threshold matters, we verify it with the named body before it goes in your programme.

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CredentialsCAMS / ICACAMS and ICA credentialled practitioners across every engagement. No client names, no invented cases.The firm →

Tell us what you hold, or what you are building. We will tell you what sits behind it.

Send us the sector, the CBK, CMA or FRC position you occupy or seek, and the deadline you are working to. A scoped, costed plan within 48 hours. No hourly billing. No obligation.

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