On 28 October, The Sentry published a report compiled using open-source research. It focuses on areas that the FATF-style regional body ESAAMLG assessment team should consider during its preparation for the onsite visit, as well as areas that the government of Kenya may wish to assess as it finalises its national risk assessment (NRA) and prepares for the mutual evaluation report (MER).  The first part of the report discusses illicit finance risks and typologies — many linked to South Sudan — to be considered and addressed as the government seeks to establish Kenya as a financial hub in Africa through its Vision 2030 and the development of the Nairobi International Financial Centre (NIFC). The second part of the report provides a high-level assessment of Kenya’s AML/CFT regime, informed by the FATF 40 Recommendations. The third section provides recommendations to the MER team, the government of Kenya, and international partners, including an overview of steps that Kenya should prioritize to protect the banking sector, the real estate sector, and other areas at risk of abuse by illicit actors.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: