Sanctions and PEP screening for Kenya: the Domestic List, the 24-hour freeze and regulation 26.
Screen customers, beneficial owners and counterparties against the UN Security Council lists and Kenya's Domestic List, and identify politically exposed persons under regulation 26 of the POCAML Regulations, 2023. Every list is versioned, so each decision can be traced to the list it used.
Kenya's rules in brief.
- Sanctions law
- Prevention of Terrorism Act and the 2026 targeted financial sanctions Regulations (Legal Notice 172 of 2026, made 7 September 2026); proliferation-financing Regulations, 2023, amended 2024
- Lists to screen
- The UN Security Council lists (1267, 1988, 1718 and the Consolidated List) and Kenya's Domestic List of designations under UN Resolution 1373, published by the FRC
- Freeze
- Without delay: within hours, and not later than 24 hours after a designation, covering all assets the designated person owns or controls
- Report
- Freezes and attempted transactions, within 24 hours, to the Counter Financing of Terrorism Inter-Ministerial Committee through the FRC
- Keep screening
- Ongoing screening against the Domestic List and the UN lists; unfreeze within 24 hours of a delisting or a confirmed false positive
- Who is a PEP
- Regulation 26(5): a prominent public function in Kenya or abroad, including State officers and senior public officers, plus immediate family and close business associates
- Enhanced due diligence
- Always for foreign PEPs; for domestic and international-organisation PEPs where the relationship is higher risk (regulation 26(1) and (2))
- Former PEPs
- No law sets a period. CBK's 2025 PEP guidance tells its licensees to keep PEP treatment for at least 12 months, then document a risk assessment
- Official PEP list
- None found
Checked against primary sources on 19 October 2026.
What Kenya requires, and how the module handles it
Kenya's screening duties come from the 2026 sanctions Regulations and regulation 26 of the POCAML Regulations. Each duty, where it sits, and the part of the screening module that carries it:
| What Kenya requires | Where it sits | How the module handles it |
|---|---|---|
| Screen customers, beneficial owners and transactions against the UN lists and the Domestic List, and keep screening | 2026 Regulations, regs 9, 18 and 36 | Lists synced from providers, plus manual upload for lists you maintain yourself, such as the Domestic List. Screening runs at onboarding and whenever a list changes. |
| Freeze within 24 hours of a designation, and report the freeze and any attempted transaction within 24 hours | 2026 Regulations, regs 2, 10, 11 and 18 | Versioned lists and freshness dashboards confirm screening ran against current data, and every decision on a match is kept in an append-only audit log. The freeze itself is applied in your core system. |
| Clear false positives consistently, and unfreeze within 24 hours of a confirmed false positive or delisting | 2026 Regulations, regs 14(5) and 15(5)–(6) | A structured false-positive workflow records why each look-alike name was cleared, and the match-scoring engine shows the top three reasons behind each hit. |
| Identify PEPs; apply enhanced measures to every foreign PEP, and to domestic PEPs where the risk is higher | POCAML Regulations 2023, reg 26 | A PEP match feeds the customer's risk rating and opens an enhanced due diligence review inside case management, with periodic reviews scheduled by risk band. |
| Cover family members, close associates and the people behind a company | Reg 26(5)(j); CBK's 2025 PEP and beneficial ownership guidance | Entity resolution and a beneficial-owner graph extend screening to the people behind a company, not just its name. |
Summaries of the primary texts as checked on 19 October 2026: the 2026 sanctions Regulations, the POCAML Regulations 2023 and CBK's 2025 guidance. Not legal advice.
Frequently asked questions.
Which sanctions lists must Kenyan institutions screen against?
The UN Security Council lists, including the 1267, 1988 and 1718 lists and the Consolidated List, and Kenya's Domestic List of designations under UN Resolution 1373, which the FRC publishes. The 2026 Regulations require ongoing screening against both.
How quickly must a Kenyan institution freeze funds after a designation?
Without delay, which the 2026 Regulations define as within hours and not later than 24 hours after the designation. The freeze, and any attempted transaction, is then reported within 24 hours to the Counter Financing of Terrorism Inter-Ministerial Committee through the FRC.
Who is a politically exposed person in Kenya?
Regulation 26(5) of the POCAML Regulations, 2023 covers people entrusted with a prominent public function in Kenya or abroad, such as Cabinet members, State officers, senior public officers, members of the Judiciary and senior officials of international organisations, plus their immediate family members and close business associates.
Do domestic PEPs always need enhanced due diligence?
No. Foreign PEPs always get enhanced measures; domestic PEPs and people with a prominent function at an international organisation get them where the relationship is higher risk (regulation 26(1) and (2)).
Is there an official PEP list in Kenya?
We found none. PEP data from commercial providers and lists you build yourself can both be screened, and each is versioned like a sanctions list.
Does the software freeze accounts?
No. The freeze is applied in your core banking or wallet system. The screening module finds the match, records how it was resolved and keeps every decision in an append-only audit log.
See it on your own data.
Bring your own customers and scenarios to a live demo of the AML compliance software, set up for the country you report in.