Kenyan DNFBPs: The Missing Link in AML Compliance
In the world of financial crime, it's not always the obvious suspects enabling illicit flows. As a recent U.S. government report reveals, some of Kenya's most respected professionals may be unintentionally—or deliberately—creating critical gaps in the country’s anti-money laundering (AML) framework
The Professional Gatekeepers: Lawyers, Real Estate Agents, and the Risk of Abuse
According to the March 2025 report from the U.S. Department of State Bureau of International Narcotics and Law Enforcement Affairs, Kenya has made important strides in fighting financial crime. But one key area remains dangerously under-regulated: Designated Non-Financial Businesses and Professions (DNFBPs).
Lawyers, estate agents, and notaries in Kenya continue to be used—knowingly or not—as entry points for illicit funds into the financial system.
"Designated non-financial businesses and professions (DNFBPs), such as lawyers, estate agents, and notaries, are another avenue for money laundering," the report states.
The methods are alarmingly simple:
Property transactions mask illegal funds, with legal professionals facilitating deals
Shell companies created with legal assistance obscure the real source of funds
Trust accounts managed by lawyers shield transactions from scrutiny
Court rulings have blocked efforts to require suspicious activity reporting from legal professionals
Kenya's geographic and economic position only adds complexity. Its proximity to Somalia creates risk from unregulated sectors like the khat and charcoal trades. Meanwhile, informal remittance systems used by refugees, diaspora communities, and ethnic Somalis often bypass formal oversight.
Digital Solutions for DNFBPs and Financial Institutions
This is exactly where Anqa Compliance can help.
Our all-in-one AML/CFT platform is built for emerging markets like East Africa and addresses the gaps exposed in the U.S. report:
Digital KYC and eOnboarding — onboard clients in minutes, not days
Risk assessments by nature and purpose — better understand your clients’ intentions
Real-time sanctions screening — catch risky names, even with spelling variations
Regional watchlists — tailored to East African cross-border risks
Automated audit trail — be ready when regulators ask
Microfinance & Remittance: Hidden Vulnerabilities
Kenya's dynamic microfinance and remittance sectors are especially vulnerable to abuse, particularly when informal money systems are involved. These sectors need compliance tools that are:
Streamlined for high-volume, low-value transactions
Affordable and practical for resource-limited institutions
Scalable to grow with expanding networks
Smart about false positives to avoid disruption to legitimate flows
Anqa Compliance meets all of the above—and more.
A Regional Problem Needs a Regional Solution
The issues highlighted in Kenya exist across East Africa, South Asia, and Southeast Asia, where DNFBPs often operate without adequate compliance infrastructure.
Anqa Compliance is designed with these regional realities in mind. Unlike enterprise solutions built for Western financial giants, our platform is:
Cost-effective
Mobile-friendly
Customisable to local compliance rules
Time to Take Action
Kenya has committed to strengthening its AML framework under FATF guidance in 2024. Financial institutions and DNFBPs have a key role to play.
Ask yourself:
Are our DNFBP clients properly vetted?
Can we detect the money laundering methods mentioned in the report?
Are our systems equipped for real regulatory scrutiny?
If the answer to any of these is "not yet," now is the time to act.
👉 Visit www.anqacompliance.com to learn more or request a demo.
Effective compliance protects more than your operations—it protects your reputation and your role in a healthier financial ecosystem.
This article references reporting by Christine Opanda published on March 19, 2025, regarding the U.S. Department of State Bureau for International Narcotics and Law Enforcement Affairs report on money laundering in Kenya.
