Kenya was placed on the FATF grey list in February 2024 and remains there. An earlier target of exiting by May 2026 was not met, and FATF's plenary of 30 October 2026 left Kenya on the list, with the next plenary scheduled for 22 to 26 February 2027. This article sets out Kenya's current status, what its reform programme covers, and what it means for transaction monitoring standards, particularly around mobile money.
Kenya's current FATF status
The Financial Action Task Force placed Kenya on its list of jurisdictions under increased monitoring in February 2024, citing gaps in the country's capacity to investigate, prosecute and address money laundering and terrorism financing risks. Kenya's National Treasury set a target of exiting the list by May 2026, but that date passed without delisting; by late August 2026, Kenya's Director of Public Prosecutions was chairing multi-agency meetings with the Financial Reporting Centre, the Directorate of Criminal Investigations, the Ethics and Anti-Corruption Commission and other bodies to assess progress ahead of the next stage of FATF engagement.
Kenya's continued grey-list status carries practical consequences beyond reputation: it has contributed to additional compliance requirements in international financial transactions involving Kenyan counterparties, which is a relevant factor for any institution assessing correspondent or cross-border risk involving the country.
What Kenya's reform programme covers
Kenya's action plan has centred on stronger supervision of banks, money remittance providers, virtual asset service providers and designated non-financial businesses and professions, alongside enhanced beneficial-ownership transparency to make it easier to identify the real owners of companies and other legal entities. Legislative milestones include the Anti-Money Laundering and Combating of Terrorism Financing (Amendment) Act, 2025 and the Virtual Asset Service Providers Act, 2025, both aimed at closing regulatory gaps FATF had identified.
Authorities have also pointed to improved risk-based customer due diligence practices and better suspicious transaction reporting quality as evidence of progress, though the continued grey-list status as of this writing indicates FATF has not yet assessed these reforms as sufficient for delisting.
Mobile money and the transaction monitoring gap
Kenya's Financial Reporting Centre has specifically flagged mobile money layering typologies as an area requiring stronger monitoring attention, reflecting the scale of mobile money flows in the Kenyan economy, reported at roughly $1.7 trillion moved in 2023. Where a large share of financial activity moves through mobile channels rather than traditional bank accounts, transaction monitoring built primarily around bank-account patterns risks missing the layering techniques that mobile money's speed and interoperability make possible.
The Central Bank of Kenya has pursued closer, more granular data integration across payment systems, including RTGS and PesaLink alongside mobile money, aimed at supporting more real-time supervisory technology oversight across channels rather than treating each payment rail as a separate monitoring silo.
What this means for institutions operating in or with Kenya
For banks and payment providers operating in Kenya, the practical priority is monitoring that treats mobile money and traditional account activity as part of the same customer risk picture, given how easily funds move between the two, rather than building separate, disconnected monitoring rules for each channel. For institutions elsewhere assessing Kenyan counterparty or correspondent risk, Kenya's continued grey-list status as of this writing should be factored into risk-based due diligence, alongside the genuine legislative progress the country has made, rather than either dismissed or treated as a blanket block.
