Transaction monitoring for Kenya: the two-day STR, the USD 15,000 cash report and the typologies behind them.
One rule engine over batch files and streaming transactions, cash-threshold rules set to Kenya's USD 15,000 line, and typology-aligned starter rules you tune and back-test. Alerts flow into case management, and suspicious and threshold reports go to the FRC through goAML.
Kenya's rules in brief.
- Monitoring duty
- Ongoing monitoring of all complex, unusual, suspicious, large or such other transactions (POCAMLA s.44(1))
- Suspicious transaction reports
- To the FRC within two days after the suspicion arose, including attempted transactions (s.44(2) and (3); reg 38(1))
- Cash transaction reports
- Cash of USD 15,000 or more, or the equivalent, by the Friday of the week the transaction took place (s.44(6); reg 40)
- Split cash
- Same-day cash below the line in one account is not added up for a cash report, but the pattern is assessed for an STR (FRC Circular No. 4 of 2023)
- Unusual transactions
- Written findings on complex or unusual transactions are kept for at least seven years (s.44(4) and (5))
- Records
- At least seven years from the transaction or the end of the relationship
- Tipping off
- An offence under POCAMLA s.8
- Systems
- No rule in force requires automated monitoring: CBK's 2025 guidance accepts manual or automated systems. CBK's draft Risk Management Guidelines 2026 would expect a monitoring system
- Volumes in 2024
- The FRC received 8,057 suspicious transaction and activity reports and 7,802 cash transaction reports covering 234,787 transactions (FRC Annual Report 2024)
Checked against primary sources on 19 October 2026.
What Kenya requires, and how the module handles it
Kenya's monitoring and reporting duties sit in section 44 of POCAMLA, the POCAML Regulations, 2023 and the FRC's circulars. Each duty, where it sits, and the part of the monitoring module that carries it:
| What Kenya requires | Where it sits | How the module handles it |
|---|---|---|
| Monitor complex, unusual, suspicious and large transactions on an ongoing basis | POCAMLA s.44(1) | A rule engine runs on overnight batches and on streaming transactions alike, so real-time channels and end-of-day files are monitored by the same rules. |
| Report suspicious transactions, including attempts, within two days after the suspicion arose | s.44(2) and (3); reg 38(1) | Alerts become owned cases with deadlines, and suspicious reports move through a draft, review, approve and submit lifecycle to the FRC through goAML. |
| Report cash of USD 15,000 or more by the Friday of that week | s.44(6); reg 40 | Cash-threshold rules are configured for Kenya's line, and threshold reports go to the FRC through goAML. |
| Look into cash split below the line, and record findings on unusual transactions | FRC Circular No. 4 of 2023; s.44(4) and (5) | Typology-aligned starter rules, such as structuring below a reporting line, to switch on and tune, with every decision kept in an append-only audit log. |
| Base monitoring on your risk assessment and the national risk findings | Regs 7 and 20(2) | Run a new or changed rule over historical data, compare alert volumes and outcomes, and promote it as a new version, with the old one kept for audit. |
| Never let a failed data feed become a monitoring gap | s.44(1) | REST, SFTP, Kafka, change data capture and ISO 20022 connectors with replay and a dead-letter queue, and a data-requirements service showing which rules have the attributes they need. |
Summaries of the primary texts as checked on 19 October 2026: POCAMLA, the POCAML Regulations 2023, FRC Circular No. 4 of 2023, CBK's guidance and drafts, and the FRC Annual Report 2024. Not legal advice.
Frequently asked questions.
What is the STR deadline in Kenya?
Two days after the suspicion arose, under POCAMLA s.44(2) and regulation 38(1) of the POCAML Regulations, 2023. Attempted transactions are reported too. Before 15 September 2023 the deadline was seven days from the transaction.
What is the cash transaction reporting threshold in Kenya?
Cash transactions of USD 15,000 or more, or the equivalent in any other currency, whether or not they look suspicious. The report is due by the Friday of the week the transaction took place. The line was USD 10,000 until 15 September 2023.
Do we add up split cash deposits for a cash report?
Not for the cash report itself: FRC Circular No. 4 of 2023 says same-day cash transactions below the threshold in one account are not aggregated. It also says to understand why the cash was split, and to file an STR if the pattern is unusual or suspicious.
Does CBK require automated transaction monitoring?
Not under the rules in force: POCAMLA requires ongoing monitoring, and CBK's 2025 guidance accepts manual or automated systems. CBK's draft Risk Management Guidelines 2026, published for comment in September 2026, would expect banks to have a monitoring system.
Which typologies should Kenyan monitoring rules cover?
Kenya's 2023 risk assessment update and the FRC's February 2025 guidance put corruption and economic crimes first by value (about USD 299 million of proceeds in 2021 to 2023), then fraud and forgery (about USD 104 million) and tax crimes (about USD 87 million). Fraud still leads by number of cases.
Can a rule be tested before it goes live?
Yes. A new or changed rule runs over historical data first, so you can compare alert volumes and outcomes, then promote it as a new version with the old one kept for audit.
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.