Countering terrorism financing
Understanding how terrorist organisations raise and move funds — and how NPOs can identify and mitigate abuse of charitable channels in Kenya.
Why NPOs matter in CFT
Non-profit organisations play a vital role in Kenya's social fabric. They also feature in global CFT standards because charitable channels can — in rare cases — be exploited to move or disguise funds intended for terrorism.
FATF Recommendation 8 requires countries to implement risk-based oversight of NPOs. This means focusing on organisations and activities with higher exposure — not imposing blanket restrictions that would disrupt legitimate humanitarian, advocacy, and community work.
Kenya's 2025 AML/CFT reforms strengthen NPO sector oversight under PBORA while emphasising that investigations and compliance measures should minimise disruption to service delivery.
Key principle
Terrorism financing prevention is about protecting civil society's integrity — not closing legitimate organisations. Awareness and proportionate controls are your best defence.
Red flags to watch for
Opaque funding requests
Donors insisting on cash disbursements, third-party transfers, or routing funds through unrelated jurisdictions without clear purpose.
Programme misalignment
Funding conditions that do not match your organisation's registered mandate, geographic focus, or stated charitable objectives.
Beneficiary verification gaps
Pressure to distribute resources without adequate identity checks, especially in conflict-affected or cross-border contexts.
Documentation anomalies
Incomplete invoices, duplicate receipts, or financial records that cannot withstand basic audit scrutiny.
Governance override
Individuals seeking to bypass board approval processes or internal financial controls for urgent disbursements.