PLUGGING THE LOOPHOLES - Assessing Finance Act 2018 against Kenya’s Anti-Money Laundering and Counter-Terrorism Financing Obligations

"Plugging the Loopholes - Assessing Finance Act 2018 against Kenya's Anti-Money Laundering and Counter-Terrorism Financing Obligations" examines the implications of Section 37B (4) of the Tax Procedures Act 2015, introduced through the Finance Act 2018, in relation to Kenya's anti-money laundering and counter-terrorism financing obligations. The paper provides an overview of Kenya's domestic and international legal frameworks, including the Financial Action Task Force (FATF) recommendations. It highlights the legal, policy, and practical threats posed by the exemption created by Section 37B (4) and concludes with recommendations. The assessment aims to address potential gaps and ensure compliance with AML/CTF obligations.