In our previous publication, we examined the Virtual Asset Service Providers Regulations, 2026 (the Regulations), which operationalise the Virtual Asset Service Providers Act, 2025 (the VASP Act). Most commentary has focused on licensing and market access.

The framework matters for another reason too: it closes one of the gaps that led the Financial Action Task Force (FATF) to place Kenya on its list of “Jurisdictions under Increased Monitoring”, commonly known as the “grey list”.

26 October 26

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