Starting March 2026, the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act 2025 will be fully effective. This act applies to many everyday businesses, such as Betting and Mining, Professional services such as accounting, real estate and even the Public Benefit Organizations (PBOs).
Sector Specific Compliance Obligations
- Betting, SACCOs, Retirement Schemes, Mining, Real Estate, Accounting, Legal & Compliance Secretarial Services, key obligations include:
- Implement Customer Due Diligence (CDD) and customer identity verification.
- Reporting suspicious transaction to the Financial Reporting Centre (FRC).
- Proper recording keeping of transactions.
- 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:
- Have you assessed the money-laundering and terrorism-financing risks covering you customer base, services & products, geographic exposure, and transaction types and limits?
- Are your identification, verification and screening procedures including beneficial ownership up to date? (including Enhanced Due Diligence (EDD))
- Are your records properly maintained (transactions, client identities) and internal reviews for the required period?
- Do you have documented AML/CFT policies, periodic training, framework, internal audits and a designated compliance officer?
- Do you have procedures in place to flag and report suspicious transactions to the Financial Reporting Centre (FRC) or other competent authority?
- Do you provide training to your staff and enforce internal controls (segregation of duties, approval thresholds, monitoring)?
- Is senior management aware and accountable? Are there oversight procedures including sanctions, non-compliance, and escalation processes?
- 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.