(9)Kenya made a high-level political commitment in February 2024 to work with the FATF and the ESAAMLG, which is its FSRB, to strengthen the effectiveness of its AML/CFT regime. Since then, Kenya has taken steps towards improving its AML/CFT regime, including by completing a TF risk assessment and by bringing its TFS framework related to proliferation financing into compliance. Kenya will continue to work to implement its FATF action plan to address its strategic deficiencies, including by: presenting the results of its ML/TF national risk assessment and other risk assessments in a consistent manner to competent authorities and the private sector and updating the national AML/CFT strategies; improving risk-based AML/CFT supervision of financial institutions (FIs) and DNFBPs and adopting a legal framework for the licensing and supervision of virtual asset service providers; enhancing the understanding of preventive measures by FIs and DNFBPs, including to increase STR filing and implement TFS without delay; designating an authority for the regulation of trusts and collection of accurate and up-to-date beneficial ownership information and implementing remedial actions for breaches of compliance with transparency requirements for legal persons and arrangements; improving the use and quality of financial intelligence products; increasing ML and TF investigations and prosecutions in line with risks; bringing the TFS framework in line with FATF Recommendation 6 and ensuring its effective implementation; and revising the framework for NPO regulation and oversight to ensure that mitigating measures are risk-based and do not disrupt or discourage legitimate NPO activity. While recognising and welcoming the commitment and progress made by Kenya so far, and encouraging further efforts, the Commission concludes that Kenya has not yet fully addressed the concerns that led to its addition to the FATF’s list of ‘Jurisdictions under Increased Monitoring’. Kenya should therefore be considered a high-risk third country.