In an increasingly complex financial landscape, asset tracing has become a critical tool in combating fraud, money laundering, corruption, embezzlement, and other financial crimes. Globally, it plays a vital role in protecting economic integrity and advancing financial justice.

The Objective of Asset Tracing

The primary goal of asset tracing is to uncover assets deliberately concealed through complex financial structures such as offshore accounts, shell companies, layered transactions, or third-party holdings. Individuals engaged in financial misconduct often attempt to obscure the origin and beneficial ownership of illicit funds to evade detection.

Asset tracing seeks to dismantle these structures and reveal the true flow of funds.

Key Stages in Asset Tracing

Asset tracing typically involves three core stages:

1. Identification

Investigators determine what assets exist and who ultimately controls them. This may include bank accounts, real estate, company shares, intellectual property, luxury assets, and other holdings.

2. Tracking

This stage focuses on following the movement of assets across financial accounts, jurisdictions, corporate entities, and digital platforms to establish patterns and connections.

3. Recovery

Where appropriate, legal measures are initiated to freeze, seize, or facilitate the return of assets to their rightful owners through civil or criminal proceedings.

Expertise and Tools

Asset tracing is a multidisciplinary effort involving forensic accountants, legal professionals, financial investigators, and, in some cases, law enforcement agencies.

Modern investigations increasingly rely on advanced technologies such as data analytics, artificial intelligence, digital forensics, and access to international financial intelligence databases to detect unusual transactions and ownership patterns.

Civil and Criminal Applications

In civil matters, asset tracing supports the recovery of misappropriated funds and the enforcement of judgments or compensation claims.

In criminal proceedings, it provides evidentiary support for prosecution by establishing financial trails and demonstrating illicit enrichment or unlawful transfers.

Challenges in Asset Tracing

Despite its effectiveness, asset tracing presents notable challenges, including:

• Banking secrecy laws in certain jurisdictions
• Limited transparency in corporate ownership structures
• Cross-border legal complexities
• The growing use of digital currencies and anonymized financial platforms

However, stronger regulatory frameworks, international cooperation, and technological advancements are steadily improving investigative outcomes.

Conclusion

Asset tracing is a powerful mechanism for uncovering hidden wealth, restoring accountability, and reinforcing financial integrity. As financial crimes continue to evolve in sophistication, the role of asset tracing remains indispensable in promoting transparency, justice, and ethical financial conduct worldwide.

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At RISKHOUSE INTERNATIONAL LIMITED, we specialize in uncovering the truth through discreet, professional investigations that empower our clients to make informed and confident decisions.

1. Fraud Investigations

Fraud does more than cause financial loss, it damages credibility, stakeholder confidence, and long-term growth.

Our investigative team applies advanced methodologies to detect, analyse, and document fraudulent activity, including:

• Forensic Accounting – Identifying irregularities, misstatements, and financial manipulation.
• Digital Forensics – Uncovering hidden communications, data breaches, and system misuse.
• Evidence Collection & Documentation – Developing defensible reports to support litigation, regulatory action, or internal disciplinary processes.

We deliver clarity where suspicion exists.

2. Due Diligence

Every investment, acquisition, partnership, or major transaction carries inherent risk. Effective due diligence is not optional, it is essential.

Our due diligence services provide comprehensive insights into:

• Financial standing and operational stability
• Regulatory compliance status
• Litigation history and reputational exposure
• Undisclosed liabilities or conflicts of interest

We help clients enter transactions with full visibility and reduced uncertainty.

3. Background Checks

Trust is important, verification is critical.

Our background screening services help organizations and individuals confirm credibility before making hiring, partnership, or investment decisions. We:

• Verify employment history, academic credentials, and professional certifications
• Authenticate documents and qualifications
• Review criminal and civil records where applicable
• Identify potential reputational or integrity concerns

Sound decisions begin with verified information.

4. Asset Tracing

Hidden or undisclosed assets can complicate fraud investigations, debt recovery, shareholder disputes, and matrimonial matters.

Our asset tracing services establish:

• The physical existence and location of property or individuals
• Ownership structures and beneficial interests
• Asset movement patterns and economic status analysis
• Links between entities and individuals through ownership trail reviews

We uncover what others attempt to conceal.

Conclusion

Fraud, hidden liabilities, and undisclosed assets pose serious threats to business continuity and personal financial security.

At RISKHOUSE INTERNATIONAL, we combine forensic expertise, rigorous investigation, and timely reporting to provide accurate, actionable intelligence. Our work equips clients with the clarity they need to mitigate risk, protect their interests, and make informed strategic decisions.

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WHY CLOUD FORENSICS MATTERS

• In Digital Forensic Investigation, it helps to;
• Identify the Source of Incidents: We determine how, when, and where a breach occurred by analyzing logs, file activity, and metadata within cloud environments.
• Preserve Digital Evidence: Our team follows strict chain-of-custody procedures, maintaining integrity for legal or regulatory use.
• Reconstruct Attack Timelines: Advanced forensic tools allow us to map events across systems, accounts, and virtual environments.
• Ensure Legal & Compliance Readiness: Our reports meet evidentiary and audit standards to support investigations or litigation.
• Minimize Business Disruption: We conduct investigations with minimal impact on your active systems and operations.
• In Cloud Security & Incident Response, it helps to;
• Detect Misconfigurations & Insider Threats: We uncover access loopholes and suspicious user activity that compromise cloud integrity.
• Accelerate Breach Response: Our structured approach helps you contain incidents quickly and restore systems securely.
• Strengthen Future Defenses: Insights from investigations guide improvements to policies, controls, and staff awareness.

WHY CHOOSE RISKHOUSE INTERNATIONAL?

Our certified experts combine deep knowledge of cloud infrastructure, cybersecurity, and legal compliance to deliver accurate and actionable findings. Whether you use AWS, Azure, Google Cloud, or hybrid environments, we tailor our forensic process to your systems while ensuring visibility, accountability, and resilience. We don’t just find the evidence; we help you prevent the next attack.

Take Action Now

When data is compromised, every second counts. Contact RISKHOUSE INTERNATIONAL today to strengthen your cloud security posture or investigate a potential breach. You may reach us through our:-

• LinkedIn: https://ke.linkedin.com/company/risk-house-international
• Phone: 0726748889

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Why network forensics matters

• For Digital Forensic Investigation, it helps to;
• Identify breach origins: We trace attacks through network logs, traffic analysis, and device forensics to determine where and how compromise occurred.
• Preserve critical evidence: Our investigators maintain full chain-of-custody to ensure integrity for legal or regulatory use.
• Reconstruct attack timelines: Using advanced forensic tools, we recreate the sequence of intrusion events for complete visibility.
• Support compliance and legal action: Our detailed reports meet evidentiary and audit requirements, strengthening your position during investigations.
• Maintain operations: We conduct forensic work with minimal disruption to your ongoing business.
• For Network Security & Incident Response, it helps to;
• Expose hidden threats: Detect unauthorized access, data exfiltration, and malware communication across your network.
• Assess security gaps: Evaluate firewalls, intrusion detection systems, and configurations to identify vulnerabilities.
• Contain and recover faster: Our experts isolate affected systems, eliminate threats, and guide secure restoration.
• Build long-term resilience: Findings from investigations help improve network monitoring, controls, and staff awareness.

Why choose riskhouse international

Our certified specialists combine deep knowledge of network infrastructure, cybersecurity, and digital forensics to provide accurate, actionable results. Whether your systems are on-premise, cloud-connected, or hybrid, we tailor our approach to deliver transparency, accountability, and strengthened defense. We don’t just respond to incidents; we help you prevent the next one.

Take Control!

When a network breach occurs, time is critical. Contact Riskhouse International today to investigate suspicious activity or assess your network’s resilience. You may reach us through our:-

• LinkedIn: https://ke.linkedin.com/company/risk-house-international
• Phone: 0726748889

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Sector Specific Compliance Obligations

1. Betting, SACCOs, Retirement Schemes, Mining, Real Estate, Accounting, Legal & Compliance Secretarial Services, key obligations include:
2. Implement Customer Due Diligence (CDD) and customer identity verification.
3. Reporting suspicious transaction to the Financial Reporting Centre (FRC).
4. Proper recording keeping of transactions.
5. Staff training on AML/CFT risks and developing internal compliance controls.

• Public Benefit Organizations (PBOs):

Regulation, supervision and enforcement of compliance for AML purposes including:

• Implementing internal controls to prevent abuse of terrorism financing, including due diligence on donors and beneficiaries, record-keeping, and reporting suspicious activities.
• Developing focused, proportionate and risk-based actions to address Terrorism Financing Risks posed by such public benefit organizations.
• Periodically conducting an assessment of the terrorism financing risks posed to such public benefit organizations.

• Dealers in Precious Metals and Dealers in precious stone, key obligations include:
• Registering as an officially reporting entity.
• Implementing Customer Due Diligence (CDD) and customer identity verification.
• Monitoring high value transactions including when engaging in any cash transaction with a customer equal to or above fifteen thousand US Dollars ($15000).
• Avoiding informal trading practices that could raise red flags.

• Members of Professional Bodies (ICPAK, ICPSK, Estate Agents Board, LSK), key obligations include:
• Integrating AML/CFT practices into daily operations.
• Complying with professional body supervision requirements.
• Preventing misuse of professional services for illicit activities.

If your business falls in any of the above, you need to ask:

1. Have you assessed the money-laundering and terrorism-financing risks covering you customer base, services & products, geographic exposure, and transaction types and limits?
2. Are your identification, verification and screening procedures including beneficial ownership up to date? (including Enhanced Due Diligence (EDD))
3. Are your records properly maintained (transactions, client identities) and internal reviews for the required period?
4. Do you have documented AML/CFT policies, periodic training, framework, internal audits and a designated compliance officer?
5. Do you have procedures in place to flag and report suspicious transactions to the Financial Reporting Centre (FRC) or other competent authority?
6. Do you provide training to your staff and enforce internal controls (segregation of duties, approval thresholds, monitoring)?
7. Is senior management aware and accountable? Are there oversight procedures including sanctions, non-compliance, and escalation processes?
8. Are you prepared for regulatory inspection, peer review or audits of your compliance framework?

Even businesses with internal compliance teams or Artificial Intelligence (AI) compliance systems often discover gaps only during regulator inspections, the right independent review from a consultant will not only save your business from financial and reputational risks but boost regulatory confidence.

In addition, the Act outlines heavy fines and imprisonment as part of penalties for Non-Compliance:

General Provisions (All Sectors and Reporting Institutions):

• Financial fines:
• Of between Kes. 5M to Kes. 20M for legal persons and between Kes. 1M to Kes.10M for natural persons.
• Additional penalties not exceeding one hundred thousand shillings in each case for each day or part thereof during which such violation or non-compliance continues.
• Imprisonment: financing of terrorism attracts a term not exceeding 20 years for a natural person or a fine not exceeding Kes. 20 M for a legal person.

The March 2026 deadline is only four months away, being proactive reduces exposure to fines, imprisonment, and reputational risk while strengthening both investor and regulatory confidence.  At Riskhouse International Limited, our free 30 minutes AML/CFT Health Check & Independent Assessment gives you clarity on your obligations and breaks what needs to be done into practical, sector-specific obligations, whether you are a PBO, Betting or Precious Dealer.  

At RISKHOUSE INTERNATIONAL, our multi-disciplinary team combines legal, risk, and compliance to provide an objective review of policies and controls, specialized guidance in ESG, Crypto, and AI governance, AML/CFT policies, access to benchmarking and best practices from multiple industries, and efficient implementation support. This allows your internal teams to focus on execution while ensuring that your governance framework is comprehensive, practical, and strategically aligned, turning policies into organizational growth.

The post The Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act 2025: Is your Business Ready for March 2026? appeared first on Riskhouse International Limited.

Mobile/digital credit providers in Kenya have been flagged for various data protection and harassment practices:

• In 2022 the Office of the Data Protection Commissioner (ODPC) reported that by 30^th September it had received 1,030 complaints; of those, 555 were admitted, with 299 relating to digital lenders.
• Some lenders were found to be accessing borrowers’ phone contacts, sending messages to those contacts, sharing data with third-parties, or posting personal data of defaulters.
• One lender, White path Company Limited (owner of several apps) was fined Kes. 5 million after about 150 complaints for mining contacts and sending unsolicited messages.
• Another provider, Mulla Pride Ltd (apps: Ke Credit, Fair Cash) was fined Kes 2.9 million for using names/contacts obtained from third parties to shame borrowers.
• There have been reports of apps requesting access to messages, location, calendar, contacts and then using that data for credit scoring or post-default pressure.

While digital credit can promote access, many apps operate with little transparency, and misuse of personal data is widespread.

Mechanisms of Data Collection & Abuse

What data is collected?

Many of these loan apps request wide permissions when installed:

• Access to contacts and call logs.
• Access to messages, mobile money transaction history, location, calendar.
• Some share data with third-party analytics / marketing firms or credit bureaus without clear consent.

How misuse happens

• Debt-shaming tactics: Borrower defaults, app uses contact list to message friends/family of borrower, or threatening calls to contacts.
• Unauthorized sharing of borrower data with third party debt collectors or marketing firms.
• Lack of informed consent: Borrowers may not understand the extent of data being collected or how it’s used.
• Unlicensed or rogue apps: Some apps operate without being properly regulated/licensed, thus operate with fewer safeguards.

Regulatory & Legal Responses

Key laws & rules

• The Data Protection Act, 2019 (Kenya) lays out rights of data subjects, obligations of data controllers/processors including breach-notification duties.
• The Central Bank of Kenya (CBK)’s Digital Credit Providers Regulations 2021: Lenders must be licensed as Data Controllers and Processors, they must avoid unauthorised calls to contacts, must not harass borrowers, must obtain consent for third-party data sharing.
• The ODPC has powers under Section 63 of the Data Protection Act to impose penalties for non-compliance.
• Platform rules: Google (Play Store) updated policy in 2023, banning personal-loan apps from accessing photos/contacts unless essential.

What borrowers Should Do

• Check licensing: Before borrowing from a mobile-loan app, verify whether it is a licensed DCP (digital credit provider) under CBK regulations.
• Review permissions: When installing the loan app, look at what permissions you are granting (contacts, SMS, location) and whether those are reasonable for a loan-app.
• Read the privacy policy: Though often lengthy, see whether the app clearly states how your data will be used, with whom data will be shared, and what rights you have.
• Limit access: If an app is requesting access to data not clearly required (e.g., contacts, photos), you may consider declining or using a different provider.
• Protect your contacts: Be mindful of which apps have access to your address book; avoid granting unnecessary permissions when possible.
• Report abuses: If you receive harassing messages/calls from a lender or your contacts are being targeted, lodge a complaint with the ODPC.
• Budget carefully: Borrow only what you can repay, understand the interest and penalty structure, and avoid rolling over short-term apps into deeper debt.

Conclusion

The rise of mobile-loan apps in Kenya has created both opportunities and risks. On one hand, they provide quick access to credit. On the other, they have been implicated in serious breaches of data protection, harassment of borrowers and misuse of contacts and device data. The regulatory framework is evolving, with enforcement actions increasingly visible, but gaps remain. Borrowers must remain vigilant, understand their rights, and take care in choosing loan apps and controlling the data they share. At RISKHOUSE INTERNATIONAL, we have a team of professionals with the expertise to offer continuous data protection training, data protection impact assessment (DPIA), data protection compliance among others. We would be happy to serve you! Contact us at info@riskhouse.co.ke .

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With our fast-digitalizing world, the field of digital forensics is evolving quicker than ever. New trends and challenges keep surfacing, forcing investigators to acquire new skillsets and adapt daily. They stress the absolute necessity of law enforcement and intelligence in being updated on a constant basis with the emergence of new technology and solutions.

Digital forensics is revolutionized by some significant trends, including:

1. Mobile Forensics

Mobiles are everywhere, and they contain so much information. Mobile forensics, therefore, is a potent force that cannot be taken lightly by investigators. Leading companies like Cellebrite provide specialized tools and services for mobile data and evidence recovery and analysis. Some of the largest criminal cases determination in the world today have relied on mobile evidence and data to reach their verdicts. Refine your skills and keep yourself up to date with these technologies and learn about the various operating systems and their security controls.

2. Cloud Forensics

As more data is moved to the cloud, investigators must understand how to access and analyse this data as efficiently as possible. Cloud forensics entails an understanding of the layout of various cloud-based services and the implications of accessing off-premises data in the eyes of the law. Improve your expertise in this area by further refining your understanding of cloud environments and their accompanying security measures and staying abreast with the evolving legal framework surrounding access to cloud data.

3. IoT Forensics – the Internet of Things (IoT)

A network of connected devices ranging from smart appliances to vehicles — presents another rich data source for investigators. However, extracting and interpreting data from these devices can be complex, which I’m sure you’re familiar with. Deepen your skill by building knowledge about IoT devices, their communication protocols, and how to retrieve and analyse their data.

4. Artificial Intelligence in Forensics

AI arrived — and it’s all anyone can talk about. AI and machine learning are fantastic weapons that can sift through millions of data points to uncover trends and evidence human analysts might miss. Take advantage of the trend by learning more about AI and machine learning basics and how to apply the tools in your investigations to make your work even better—and faster.

5. Encryption Barriers

As privacy protections are strengthened, so are the barriers to accessing encrypted data. Knowledge of decryption functions and legal boundaries around encryption are most important to investigators. Stay ahead of the trend by developing expertise around ever-evolving encryption models, emerging decryption techniques, the laws of encrypted data, and the compliance laws that govern them.

6. Remote Forensics

The COVID-19 pandemic accelerated the movement towards remote digital forensics — and it’s not going anywhere. This entails remote access to and examination of digital evidence when in-person access to a device or network is not feasible or safe. Enhance your skillset by becoming proficient in remote access tools and methods and knowing how to preserve the integrity of digital evidence remotely. These are just some of the large trends that will shape the future of digital forensics. You may know them already, but a reminder doesn’t hurt — especially if you are not yet certified, or your certification has lapsed. Having knowledge of these trends and developing your skills will keep you in the lead. Don’t forget, in the rapidly changing digital age today, keeping abreast through continuous learning and flexibility is the way to achieve success.

Conclusion

The field of digital forensics continuously adapts to meet new technologies and emerging cyber threat scenarios. Keeping abreast of these emerging trends, law enforcement and intelligence agents can enhance their investigative capabilities and aid the successful closure of cases.

At RISKHOUSE INTERNATIONAL, we adopt a comprehensive policy of managing digital investigations. Our operations strictly adhere to the laws of Kenya specifically the constitution of Kenya 2010 and the data protection Act 2019.

Moreover, our experts have experience using some of the best tools in the industry and licensed forensic software.

In case you any query about our service or if you would like to have an idea of your matters discussed in detail with us, please contact the Business Development Team on.

For further information about this and to catch up on our other news and alerts you can have a look at our blog on our website at https https://rb.gy/hvxqzj.

At RISKHOUSE INTERNATIONAL, we boast of a team of expert investigators who have continually assisted clients and their legal advisors, through a mix of analysis of publicly available information, human source inquiries and overt investigations. Our team incorporates specialists in intelligence analysis, financial investigations, cyber security and legal advisory allowing us to advise and assist clients by following the proper legal channels. Please reach us on email at info@riskhouse.co.ke and phone @ 0792603759.

To catch up on our other news and alerts, you may visit our blog on our website at https://riskhouse.co.ke/blog/.

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Occupational fraud typologies highlight different forms of fraud, one of which is corruption. Business corruption is categorized as the second most common type of occupational fraud, with the primary examples being bribery, conflict of interest, improper gratuities, and economic extortion. Bribery and corruption pose significant risks to organizations as they may be subjected to legal, regulatory, and reputational damage. Additionally, a history of corruption can constitute a reputational risk that if not mitigated, may drive away investors, partners, clients, and future employees.

Therefore, zero tolerance for bribery and corruption is essential as it ensures sustainability and business integrity in any organization. Organizations should have robust policies, procedures, and programs to mitigate bribery and corruption risks. Organizations should also train and educate stakeholders to increase their understanding and awareness. An effective Anti-Bribery and Anti-Corruption program should lay focus on the following key areas: –

• • Top management commitment – this entails tone at the top and senior management commitment to upholding ethical conduct and integrity.
  • Risk Assessment – this entails assessments and subsequent assessments of the organization’s bribery and corruption risks.
  • Proportionate Procedures – this involves developing procedures based on risk assessment and ensuring that there is an investigation procedure in place.
  • Training and Information Communication – this involves training all levels of employees on whistleblowing and mechanisms of reporting bribery and corruption.
  • Due Diligence – this involves applying appropriate due diligence procedures to third parties including name screening, integrity, and corruption checks.
  • Monitoring and Review – this involves a continuous evaluation and validation of anti-bribery and anti-corruption programs.

At Riskhouse International, we help organizations spanning multiple jurisdictions to define, assess and respond to bribery and corruption issues. Further, we help organizations identify gaps and provide recommendations for mitigating bribery and corruption risks. We also support organizations with comprehensive Anti-Bribery & Anti-corruption (ABAC) reviews, reviews of the existing relevant legislation, review of the existing policies and procedures, conducting transactions reviews and verifications of third parties.

To learn more about this and to catch up on our other news and alerts you can visit our blog on our website at https://riskhouse.co.ke/blog/.

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A network environment can be defined as a communications system that ties multiple users together. In such an environment, there is a need to establish control measures to detect advanced threats in the network. The security mechanism measures should identify the threat’s movement in, out, and laterally within the environment.

There is a need to establish a network detection response (NDR) that can identify and allow rapid and efficient response to threat incidents and analyze the network traffic matrix. This will enable the identification of zero-day exploits and unknown unidentified threats to enhance advanced security threat hunting and detection capabilities.

The organization should embrace the following practices to prevent the threats: –

1. Human expertise – security experts should have the ability to observe and act on incidents for the purpose of preventing major damages the business may encounter.
2. An automated response – there is a need for integration and automation of security appliances to be capable of taking actions to block and mitigate potential threats as they are detected. This can be done by automatically blocking traffic from active IP addresses that are identified as known threats.
3. Artificial Intelligence/ Threat Intelligence – this is the integration of network devices and other applications by use of intelligence that feeds up-to-date information on known threats and cybercrime attackers on a network.

At Riskhouse International, we assist the management and organizations to develop policies and standards that assess security control measures and embrace a healthy network environment. To learn more about this service and to catch up on our updates and alerts you can visit our website at https://riskhouse.co.ke.

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Criminals launder money mainly using the financial system to transfer funds. Financial institutions, especially banks, are most vulnerable to abuse for laundering purposes. To protect themselves, financial institutions must have adequate controls and procedures in place that enable them to know the person whom they are dealing with. Enhanced due diligence on new and existing customers is a key part of these controls.

The application of thorough Customer Due Diligence (CDD) measures by financial institutions and a high degree of transparency is crucial to fight money laundering and the financing of terrorism effectively. Customer Due Diligence should be applied upon the establishment of a business relationship. Enhanced Due Diligence should also be applied where there is a receipt of a significant cash amount above normal threshold receipts. Customer Due Diligence measures should also be applied whenever financial institutions suspect money laundering or terrorist financing activities.

The Legal Framework for Customer Due Diligence in Kenya.

In Kenya, CDD is a legal requirement under the Proceeds of Crime and Anti-money Laundering Regulations, 2013. Under the regulations, reporting institutions which include banks, insurance companies, and microfinance institutions must undertake due diligence procedures before establishing a business relationship.

Specifically, institutions are required to identify customers using independent source documents, data, or information, verify the identity of beneficial owners and conduct ongoing due diligence on the business relationship to ensure that transactions being undertaken are consistent with the financial institution’s knowledge of the customer, their business and risk profile.

Importance of Customer Due Diligence for Financial Institutions in Kenya

One of the key benefits of conducting customer due diligence is the protection of the institution against reputational risk. Another benefit is the maintenance of customer trust. Lastly, CDD ensures the avoidance of regulatory fines and penalties. In Kenya, a reporting institution that contravenes the provisions of the regulations commits an offence and is liable to a fine not exceeding five million Kenya shillings or imprisonment for a term not exceeding three years or both.

Riskhouse International Limited assists organizations to examine the effectiveness of their Anti-money laundering and Combating Financial Terrorism programs by offering AML/CFT Health Checks, KYC Diligence, Screening, and Remediation, AML/CFT Analytics, Monitoring, and Investigation, and AML/CFT Training and Awareness.

To learn more about this and to catch up on our other news and alerts you can visit our blog on our website at https://riskhouse.co.ke/blog/

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