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Kenyan CSOs Mobilise to Combat Illicit Financial Flows

Published: August 1, 2025 | By Evans Muguna





In a country grappling with grey listing by the Financial Action Task Force (FATF), Kenya’s civil society is not taking a back seat.

Today, a critical conversation unfolded at the Heron Portico Hotel in Nairobi, where Transparency International Kenya (TI-Kenya) and members of the Kenya NPO Working Group on FATF hosted a transformative strategy meeting to address Illicit Financial Flows (IFFs) and safeguard civic space.

The session brought together voices from across the civil society ecosystem—advocacy groups, researchers, governance experts, and financial integrity advocates—with one shared goal: to strengthen internal systems, stay compliant, and protect civil liberties.


🔍 Why Now?

In February 2024, Kenya was added to the FATF grey list—a global watchlist for countries deemed to have strategic deficiencies in their anti-money laundering (AML) and counter-terrorism financing (CFT) regimes.

This status not only affects Kenya’s global financial reputation but also increases pressure on the government—and indirectly on CSOs and NPOs—to comply with strict standards. As one participant aptly put it:

“Grey listing is like an audit—it reveals your gaps. But it also gives you the opportunity to fix your systems and be better prepared.”


🧠 Key Themes from the Day


1. Confusion Over Terms: CSO vs NPO vs NGO

One of the first issues raised was around definitions. Several attendees sought clarity on the difference between CSOs, NPOs, and NGOs. The consensus? They are often used interchangeably, but for FATF compliance, “NPO” is the umbrella term adopted.

2. Grey List Anxiety and Reality

Who puts countries on the grey list? The FATF, through its regional bodies like ESAAMLG. While grey listing does prompt reform, there are fears that it can also be abused to unfairly target civil society under the guise of financial scrutiny—a phenomenon being called “grey list–induced panic.”

3. Risk Assessments are a Must

Organisations were urged to conduct internal risk assessments—not just to meet donor expectations, but to proactively detect and mitigate risks associated with illicit finance. One speaker asked pointedly:

“If you think your donors are being scrutinized, are you also scrutinizing them?”

4. Call for Unity in Diversity

Multiple speakers emphasized the need for solidarity across sectors. With elections on the horizon in 2027, and increasing concern over campaign financing, the room echoed a shared call: “Let’s not work in silos anymore.”


⚙️ What Success Looks Like

Success in this space, as outlined during the event, goes beyond Kenya simply exiting the grey list. It includes:

  • Evidence-based risk regulation of CSOs, not politically motivated actions.

  • CSOs leading internal reforms that enhance credibility and resilience.

  • Legal frameworks implemented fairly, with FATF compliance as a tool for growth, not repression.


🛠️ What’s Next?

As Kenya’s civil society works to validate the 2025–2028 Strategic Plan developed by the NPO Working Group, the emphasis now shifts to:

  • Training CSOs on risk management.

  • Advocacy against arbitrary enforcement.

  • Tracking and influencing beneficial ownership transparency, especially where public funds are involved.


🤝 Final Reflections

The spirit of the meeting was summed up in a simple truth: collaboration is survival.

“If we don’t come together, we remain fully at risk,” one panelist noted, challenging participants to think transformatively.

Indeed, Kenya’s civil society may be under pressure—but it’s far from powerless. Through strategic alignment, open dialogue, and mutual accountability, organizations are proving that compliance and civic freedom can coexist.

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