Published: November 2025
Authors: Jackson Oldfield, Lewis Kundai, Clara Czuppon
This paper was prepared by Jackson Oldfied, Lewis Kundai and Clara Czuppon, CiFAR and reviewed by Agatino Camarda, CiFAR in October 2025. The authors have made reasonable steps to ensure that the content is accurate.
This report maps Kenya’s real estate ecosystem to understand how illicit finance enters the property market—an issue highlighted by Kenya’s 2024 FATF grey listing. It analyses five groups of actors (sellers, intermediaries, buyers, influencers, and rule-makers) and shows how weak oversight, low compliance, and political influence create significant vulnerabilities. Using case analysis, interviews and available data, the study identifies key illicit investors—including politically exposed persons, organised criminal networks, and regional actors—and highlights systemic gaps such as poor reporting by lawyers and real estate agents. The report provides a clear foundation for strengthening policy and regulatory responses to money laundering risks in Kenya’s real estate sector.
