Published: December 2025
Authors: Jackson Oldfield, Lewis Kundai
Illicit finance continues to pose a significant threat to the integrity of Kenya’s real estate sector. Although Kenya has addressed gaps in its anti-money laundering and countering the financing of terrorism (AML/CFT) laws and deficiencies identified in the 2022 Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) Mutual Evaluation, the system still struggles in practice. The Financial Action Task Force (FATF) grey‑listed Kenya in February 2024, citing serious deficiencies in its ability to prosecute money‑laundering offenses and weaknesses in its anti‑money laundering and counter‑terrorism financing regime.
The real estate sector remains a high-risk area for money laundering and terrorist financing due to pervasive use of cash, the involvement of politically exposed persons (PEPs), as well as weaknesses in the regulatory ecosystem.
Addressing these challenges could substantially strengthen the ability of the ecosystem to respond to illicit finance. Yet it will require practical, targeted reforms that go beyond tightening rules. Solutions should focus on making AML/CFT compliance workable for the real estate market as it functions in practice, and on enabling cooperation across ecosystem actors, including statutory bodies, industry associations, and civil society.
