FAQ

A Money Laundering Reporting Officer (MLRO) is a person responsible for implementing and overseeing a company's anti-money laundering (AML) systems and serves as a point of contact for related inquiries.

The role of an MLRO includes:

1. Coordinating the ML/TF risk assessment process.
2. Determining the overall ML/TF risk profile of the institution.
3. Ensuring that the institution complies with AML/CFT regulations.
4. Observing and planning for new legislation to develop AML policies, systems and procedures to ensure effective implementation.
5. Enforcing the implementation of KYC and KYB procedures.
6. Enforcing the implementation of Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD).
7. Preparing reports to senior management and the Board on the ML/TF risk assessment.
8. Processing requests for information from FRC.
9. Supporting the prevention of money laundering, terrorist financing and proliferation financing.
10. Filing Suspicious Transaction Reports (STR), Suspicious Activity Reports (SAR), Suspicious Transaction and Activity Reports (STAR) and Cash Transaction Reports (CTR) to FRC.
11. Creating awareness on AML/CFT/CPF risks for all staff in the organization.

1. A Suspicious Transaction Report (STR) is a confidential report filed by a reporting institution when it suspects that a transaction may be linked to money laundering, terrorist financing or any other criminal activity.
2. A Suspicious Activity Report (SAR) is a confidential report filed by a reporting institution when it suspects that an activity may be linked to money laundering, terrorist financing or any other criminal activity.
3. A Suspicious Transaction and Activity Report (STAR) is a confidential report filed by a reporting institution when it suspects that a transaction and activity may be linked to money laundering, terrorist financing or any other criminal activity.
4. STR, SAR and STAR reports are filed within two (2) days of forming the suspicion.

Suspicion may emanate from various indicators, including changes in behaviour, business and transaction profiles of individual identities, discrepancies in KYCs, adverse media mentions and listings on sanction lists.

FRC has developed indicators, trends and typologies of suspicious transactions and activities for various sectors. This information is available on the FRC website.

A Cash Transaction Report (CTR) is a mandatory report that must be filed for cash transactions that are or exceed US$15,000, or its equivalent in any other currency, whether suspicious or not.

The report is submitted at the end of the week (Friday) in which the transaction occurred.

Reports are filed through the goAML portal:

Yes. An individual can share information with FRC through the Contact Us page or by visiting the FRC offices at UAP Towers, 13th Floor.

Yes. As long as your business is designated as a reporting institution, you are required to register with FRC regardless of whether you deal in cash or not.

Yes. Section 47A of POCAMLA requires all reporting institutions, including Financial Institutions and Designated Non-Financial Businesses and Professions (DNFBPs), to register with FRC in the prescribed manner.

Registration with FRC is done online through the goAML portal.

For enquiries relating to:

• goAML: goamlhelpdesk@frc.go.ke
• Compliance: compliance@frc.go.ke
• Registration on goAML: registration@frc.go.ke
• Telephone: 0709 858 000

1. Go to https://goaml.frc.go.ke
2. Click on “LOGIN”.
3. Select “Forgot Password?”
4. Enter your username and e-mail address.
5. Enter the authentication code.
6. Click “Submit”.

All registrations must be completed and submitted electronically through FRC's online registration and reporting system, goAML.

The following should be provided as part of the registration:

1. Duly filled out, signed and commissioned FORM FRC RF 1-1, available on the goAML website .
2. Firm's organization structure clearly indicating the position of the MLRO (Clause 3.4 of the Guidance).
3. Copy of the relevant license, proof of registration or practicing license from your regulator, e.g. ICPAK, CBK, CMA, IRA, GRA, Ministry of Mining, Certified Public Secretaries Board or Law Society of Kenya.
4. Certified copy of the Certificate of Registration.
5. Copy of the firm's KRA PIN (Clause 3.1C of the Guidance).