Kenya's Real Estate Sector Enters a New Era of AML Compliance
Kenya is charting its path out of the regulatory grey zone—and the real estate sector is leading the charge.
Following President Ruto's assent to the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Bill, 2025 in June, Kenya has taken decisive action to strengthen its compliance framework. Real estate agents now have clear legal requirements to carry out due diligence, report suspicious transactions, and keep detailed records—particularly for high-value or cash-based property deals.
To support this transition, Anqa Compliance is offering free AML training specifically tailored for Kenyan real estate professionals—practical tools designed around POCAMLA requirements, not theoretical lectures (links below).
The new law amends ten Acts of Parliament to fix technical gaps in Kenya's framework on anti-money laundering, combating terrorism financing, and addressing proliferation financing. It's part of a national effort to restore investor confidence and repair Kenya's standing on the global financial stage—transforming compliance from a burden into a competitive advantage.
The Stakes Couldn't Be Higher
Kenya is currently on the Financial Action Task Force (FATF) grey list—a designation that sounds bureaucratic but carries devastating real-world consequences. Kenya was placed under increased monitoring in February 2024, and the country remains under scrutiny as of the latest FATF review in June 2025.
This grey listing means Kenya is under increased monitoring for deficiencies in its anti-money laundering (AML) and counter-terrorism financing (CTF) frameworks. The impacts are immediate and expensive:
Reduced foreign investment: Research indicates a reduction in foreign direct investment (FDI) to GDP ratio by up to 2% for countries with low FATF scores
Higher transaction costs: An analysis of bank inflows between 2010 and 2015 shows a significant decrease in cross-border liabilities by about 16% for grey-listed countries
Banking relationship strain: International banks impose stricter requirements when dealing with grey-listed countries
The European Union has also added Kenya to its list of high-risk countries as of June 2025, requiring European banks to apply stricter checks to Kenyan transactions. For a country that relies heavily on international trade and investment, this double blow from both FATF and the EU creates serious headwinds for economic growth.
Why Real Estate Matters in This Fight
Kenya was grey-listed because the country lacks a clear strategy on the prosecution of money laundering offences, with FATF finding that Kenya could not demonstrate any successful investigation and prosecution of any money laundering offences.
But here's the thing—real estate has consistently appeared in global money laundering cases as a preferred vehicle for cleaning dirty money. It's not unique to Kenya. Whether you're talking about Isabel dos Santos's London mansions, Russian oligarchs parking wealth in Manhattan penthouses, or corrupt officials in any number of countries converting state funds into prime property, real estate offers attractive features for money launderers:
High values that can absorb large amounts of illicit funds quickly
Opacity through complex ownership structures and shell companies
Legitimacy that comes with owning "bricks and mortar"
Appreciation potential that can multiply stolen wealth over time
FATF specifically noted that most supervisory activities occur for banks and microfinance banks, but supervision of other Financial Institutions (FIs) or Designated Non-Financial Businesses and Professions (DNFBPs) is not carried out on a risk-sensitive basis. Real estate agents are DNFBPs—and they've been flying under the regulatory radar.
What's Changed for Real Estate Professionals
The law specifically targets real estate agents, accountants, casino operators, trust and company service providers, and dealers in precious metals and stones through amendments to the Estate Agents Act.
The new requirements aren't theoretical. Real estate agents must now:
Conduct customer due diligence before engaging in property transactions
Verify identity and understand the source of funds for high-value transactions
Monitor transactions for unusual patterns or suspicious activity
Report suspicious transactions to the Financial Reporting Centre
Maintain detailed records that can withstand regulatory scrutiny
Implement risk-based procedures that reflect the actual money laundering risks in their business
For many agents, this represents a fundamental shift from "show the property, close the deal" to "understand your client, verify the money, document everything."
The Business Case Beyond Compliance
The amendments are expected to attract more Foreign Direct Investment by improving confidence in sectors like real estate and mining. This isn't just government spin—there's real money at stake.
International property investors and funds increasingly demand evidence of robust compliance frameworks before deploying capital. They've learned from painful experiences in markets where weak oversight led to reputational damage, regulatory fines, or asset seizures.
By implementing strong AML controls, Kenyan real estate professionals can:
Access international capital that was previously off-limits
Command premium valuations from compliance-conscious investors
Reduce transaction friction with international counterparties
Build sustainable partnerships with global property firms
The law is also seen as critical to supporting the government's affordable housing programme, which relies heavily on private investment.
The Regional Context
Kenya isn't operating in isolation here. The February 2025 FATF plenary welcomed Kenya as the first guest non-member from the East and Southern Africa Anti-Money Laundering Group (ESAAMLG), recognizing the country's importance as a regional financial hub.
Looking at the broader East African context:
Tanzania was recently removed from the FATF grey list, demonstrating that escape is possible with sustained effort
South Africa is making positive progress and expecting removal soon
Nigeria remains under increased monitoring but is implementing reforms
Kenya's success in compliance reform doesn't just affect Kenya—it influences regional standards and sets precedents for other East African markets.
Free Training for Real Estate Professionals
At Anqa Compliance, we understand that implementing new compliance requirements can feel overwhelming—especially when your focus should be on serving clients and closing deals.
That's why we've developed two free courses specifically for real estate professionals navigating the new compliance landscape:
🇰🇪 For Kenyan Real Estate Agents: POCAMLA-Focused Training
AML & Sanctions Compliance for Kenya's Real Estate Sector
Your Practical Guide to POCAMLA for Real Estate Agents
This course is tailored specifically for Kenya's real estate sector, covering:
Your specific duties under POCAMLA as a 'Reporting Institution'
Customer Due Diligence using Kenyan documents and verification tools
Sanctions screening in the Kenyan context
How to spot and report red flags to the Financial Reporting Centre (FRC)
Building your compliance program around Kenyan requirements
Access Kenya-specific training here
🌍 For Real Estate Professionals Across Emerging Markets
AML & Sanctions Compliance for Real Estate in Emerging Economies
A Practical Guide for Designated Non-Financial Businesses & Professions (DNFBPs)
This broader course covers FATF standards and best practices for real estate professionals across Africa, Asia, and other emerging markets:
Understanding real estate risks in emerging markets and 'grey-listing' implications
DNFBP obligations based on FATF Recommendations
Customer Due Diligence for individuals and complex legal structures
Sanctions screening essentials for any jurisdiction
Building effective AML policies and culture
Access emerging markets training here
Both courses include:
🟢 No sign-up required
🟢 Free certificate of completion
🟢 Designed for working professionals
🟢 Practical tools, not theoretical lectures
Looking Forward: Building a Compliance Culture
The real opportunity here isn't just avoiding penalties—it's building a competitive advantage through compliance excellence. As Kenya works to exit the FATF grey list and restore its international reputation, real estate professionals who get ahead of the curve will be best positioned to benefit from the inevitable recovery in international investment.
The government also expects the new law to improve Kenya's credit ratings and lower the cost of borrowing by reducing the risks perceived by international lenders.
Compliance doesn't have to be complicated—or costly. With the right tools, training, and mindset, Kenya's real estate sector can lead the way in building a safer, more transparent economy that attracts rather than repels international capital.
The question isn't whether these changes are coming—they're already here. The question is whether you're ready to turn compliance from a cost center into a competitive advantage.
Ready to build compliance into your competitive advantage? Anqa Compliance provides affordable, accessible AML tools designed specifically for emerging markets. Because when compliance becomes accessible, finance becomes inclusive—and when finance becomes inclusive, everyone wins.