Following the publication of the FATF 4th Round Review and Report for Kenya, Financial Crime News has updated its Kenya Financial Crime Dashboard last published in February 2022, in its new 2023 format.
This new format includes, for example approx 150 data points which have been collected and are represented in the 2 page Financial Crime Dashboard. It informs as to the nature of the financial crime threats, the main vulnerabilities, how resilient Kenya is to these threats and its overall level of response, with more KRI and KPI data than ever before, all from publicly available sources albeit assessed and analysed for accuracy and relevance by FCN.
For a copy of the 2023 Kenya Financial Crime Dashboard see HERE: Kenya Dashboard 16:3:23 Pbd
For a copy of the 2022 Financial Crime Dashboard for Kenya see HERE.
FCN Country Risk Scores & Ratings: Kenya is rated 46/100 and having a Moderate to High Threat level, with a “Moderate” Response at 42/100, resulting in an overall Risk of Moderate – High at 44/100, using the FCN Methodology. Whilst there is significant room for improvement the rating is better for example than that for FATF Members, China, Mexico and India, which scored 34/100, 32/100 & 32/100 respectively.
Financial Crime Threats: The Highest rated threats are from: fraud, drug trafficking, organised crime, corruption & economic crimes. Medium rated threats are from: tax offences, environmental crimes including Illegal Wildlife trafficking, goods piracy, cybercrime & money laundering.
Whilst terrorism remains a threat, particularly from Al Shabaab, its rating in the Global Terrorism Index, which measures the direct and indirect impact of terrorism, has fallen somewhat from over 7/10 in 2014 and 2015 (where higher scores reflect a greater impact) to 6.166/10 in 2022, but with still a High rating and the 20th highest rating of over 170 countries assessed.
Sector Vulnerabilities: The banking sector has been assessed as the sector with the highest threat and with a medium high vulnerability, so overall has the highest impact on ML vulnerability. Other sectors with elevated vulnerabilities are real estate, money remittance providers, foreign exchange bureaus, car dealers, lawyers, certified secretaries, gaming and sacco’s (co -operatives).
Responses: Based on the results from the 4th Round MER, it’s hard to see anything other than Kenya’s future inclusion on the FATF Grey List, alongside recently added South Africa and Nigeria which would raise even more questions about Africa’s ability to respond as expected by FATF, and whether the relative threats from these Countries are being fully taken into account despite the obvious response weaknesses. Kenya is Compliant in just 2/40 Recommendations, Largely Compliant in just 1/40 Recommendations, Partially Compliant in 26/40 Recommendations and Non Compliant in 11/40 Recommendations. On Effectiveness, Kenya received 0/11 Highly Effective Ratings, 0/11 Substantially Effective Ratings & 2/11 Moderately Effective Ratings & 9/11 Low Effective Ratings. The ME ratings were for IO2 (International Co Operation),IO3 (Supervision), IO8 (Confiscations).
Key Outcomes Performance Data for Kenya:
FIU Staffing: Not Available
SARs Reported: 3,687 in 2021
SAR Conversion Rate: 3.6% average for 2017-20
NRA: Yes latest AML in 2021
ML Convictions: 6 in 2020
Human Trafficking Convictions: 32 in 2021
Foreign Bribery Convictions: Not Available
Assets Seized: US$51 Million (1.7% of estimated financial crime proceeds (ML) @ 2.7% of GDP) between 2017-20
Assets Confiscated: US$46 Million (1.5% of estimated financial crime proceeds (ML) @ 2.7% of GDP) between 2016-20
For the Kenya Financial Crime Dashboard see below and HERE: Kenya Dashboard 16:3:23 Pbd
These materials are owned and subject to copyright by Metriqa Ltd/Financial Crime News and should not be used for commercial purposes without the prior consent of the Editor FCN.
A copy of the full data set is set out below, and available from the Editor on request.