Kenya’s Anti-Money Laundering (AML) Amendment Act 2025 and EU’s High-Risk Listing

On 14 June 2025, President William Ruto signed the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act, 2025 into law. This marks a pivotal milestone in Kenya’s sustained effort to strengthen its Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), Counter-proliferation financing (CPF) legal framework. It also addresses critical gaps flagged in the country’s Second Round Mutual Evaluation Report (MER) issued by the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) in 2022.

This legislative development is the culmination of nearly two years of intense domestic and international pressure following Kenya’s placement on the Financial Action Task Force (FATF) grey list in February 2024, a designation that signals significant deficiencies in a country’s systems for combating money laundering, terrorism financing and proliferation financing.

It also follows Kenya’s inclusion on the European Union’s list of high-risk third countries in June 2025, which imposed flows and elevated the country’s risk profile among investors and correspondent banks.

In our previous digest, we explored the implications of Kenya’s grey listing and highlighted the draft AML Bill 2025 as a key component of the government’s response to the FATF Action Plan.

At the time the bill was under review and promised institutional and procedural reforms to address the gaps identified by ESAAMLG. With the enactment of the Amendment Act, that promise is now beginning to take shape in law.

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