Supple Consultants

Questions & answers

Frequently asked questions

Answers to common questions about AML/CFT obligations, our services and how we work with organisations in Kenya and beyond.

AML (Anti-Money Laundering) and CFT (Countering the Financing of Terrorism) are the controls that stop criminals from disguising illicit funds or financing terrorism through your business. In Kenya they are governed mainly by the Proceeds of Crime and Anti-Money Laundering Act (POCAMLA) and the Prevention of Terrorism Act. Getting them right protects you from heavy penalties and reputational harm.

POCAMLA and Financial Reporting Centre (FRC) guidance apply to a wide range of reporting institutions, banks, microfinance and payment providers, SACCOs, insurers and fintechs, as well as designated non-financial businesses and professions such as real estate agencies, lawyers and accountants. If you handle customer funds or high-value transactions, you are very likely in scope.

The FRC is Kenya’s financial intelligence unit. It receives and analyses suspicious transaction reports, issues guidance and directives, and works with regulators to enforce AML/CFT obligations. Reporting institutions must register with the FRC and file reports through its goAML system.

CDD is the process of identifying and verifying your customers, understanding the purpose of the relationship and assessing their risk. EDD applies stronger checks to higher-risk customers, including politically exposed persons (PEPs), such as establishing source of funds and closer ongoing monitoring.

An STR is a report you must submit when you know or suspect that funds are linked to crime or terrorism. In Kenya, STRs are filed to the FRC through the goAML portal within the timelines set by law. We help you build the internal escalation process and reporting workflow to get this right.

It is an independent assessment of your AML/CFT framework against POCAMLA, FRC guidance and global best practice. We review your policies, procedures, CDD, monitoring and reporting, then deliver a report of findings, a risk assessment and a prioritised, practical remediation roadmap.

At least annually, and whenever your business changes materially, new products, channels, customer segments or regulations. Regular independent reviews help you find and close gaps before regulators do.

Yes. We deliver role-based training for boards, senior management, frontline staff, agents and compliance teams, using sector-specific scenarios so people can recognise red flags and act with confidence. Training is documented and audit-ready.

Yes. Our advisory retainers give you on-call regulatory guidance, periodic policy reviews, reporting support and day-to-day compliance advice, so your framework stays current as regulations evolve.

Absolutely. A risk-based approach is central to Kenyan and international standards. We tailor frameworks to your size, sector and risk profile so controls are proportionate and practical, never off-the-shelf.

Book a consultation. We’ll discuss your obligations, current controls and priorities, and recommend the right starting point, often a health check or risk assessment, then agree a clear, practical plan.

Still have questions? We’re happy to help.

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