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FNJ Research

What the data says about risk and compliance in Kenya

FNJ Research distils the latest findings of Kenya's regulators and leading professional bodies into concise, evidence-based briefs. The emphasis is on implications: what the data means for boards, risk and compliance leaders, SACCO management and NGO finance teams.

Independent analysis of published data, with all figures linked to the original source.

The numbers that matter now

16.0%

Gross non-performing loans to gross loans, Kenyan banks, December 2025, down from 17.1%

Source: CBK Bank Supervision Annual Report 2025

23rd

Kenya's position among the highest-risk countries for money laundering, of 177 assessed

Source: Basel AML Index 2025

30%

Of banking institutions surveyed by the CBK have an AI strategy, although 50% have adopted AI

Source: CBK Survey on AI in the Banking Sector

73%

Of African internal audit leaders rank cybersecurity among their top five risks

Source: IIA Risk in Focus Africa 2026/2027

56%

Of occupational fraud cases in Sub-Saharan Africa involved corruption

Source: ACFE Occupational Fraud 2026

Six areas of focus

Our research is organised around the issues our clients face. It draws on the publications of regulators and professional bodies, complemented by proprietary FNJ trackers where no Kenyan dataset exists.

01

Financial sector supervision

Relevant to: Audit and internal audit of financial institutions, IFRS 9 expected credit losses, risk management

Sources: CBK, SASRA and CMA annual reports, including the FNJ enforcement tracker

02

AML/CFT

Relevant to: AML/CFT programmes, independent AML audits, AML training

Sources: FATF, Financial Reporting Centre, ESAAMLG, Basel AML Index

03

Fraud

Relevant to: Forensic investigations, fraud risk management, whistleblowing with Trigarc Ethics

Sources: ACFE Report to the Nations, ACFE Anti-Fraud Technology Benchmarking Report

04

Data protection and AI

Relevant to: Data protection gap assessments, AI governance, AI audits

Sources: Data Protection Commissioner determinations (FNJ tracker), CBK AI survey, ISACA, IAPP

05

Risk, governance and cybersecurity

Relevant to: Internal audit, ERM and RCSA, IT audit and cybersecurity, board advisory

Sources: IIA, World Economic Forum, ISACA, CMA governance report, Ibrahim Index

06

Tax and SME finance

Relevant to: Tax advisory and KRA compliance, eTIMS and Zoho Books, outsourced accounting

Sources: KRA, National Treasury, OECD Revenue Statistics in Africa, KNBS

Research briefs

Concise briefs setting out the key findings, FNJ's analysis and the implications for Kenyan institutions, with a direct link to the source report.

Featured brief · Financial sector

Kenya's banks in 2025: what the CBK supervision report shows

Balance sheets and earnings strengthened in 2025. Asset quality improved but remains weak, and the licensed digital lending market more than doubled. We set out the implications for boards and compliance functions.

Based on the CBK Bank Supervision Annual Report 2025 · Coming soon · 6 min read

KES 8.35tn

Total net assets, up 10.3%

KES 306bn

Profit before tax, up 17.7%

16.0%

Gross NPL ratio, from 17.1%

20.7%

Total capital adequacy, against a 14.5% minimum

AML/CFT Coming soon

Kenya and the FATF grey list: implications of the October 2026 plenary

Kenya has been under FATF increased monitoring since February 2024. We assess the plenary outcome and its implications for AML/CFT programmes and independent AML audits.

  • Feb 2024Kenya added to the FATF list of jurisdictions under increased monitoring
  • 23rdhighest money-laundering risk of 177 countries in the Basel AML Index 2025
  • 28-30 Octdates of the October 2026 FATF plenary

Based on FATF and the Basel AML Index 2025

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Data protection and AI Coming soon

AI in Kenyan banking: adoption is outpacing governance

Half of the 125 institutions surveyed by the CBK have adopted AI, yet fewer than a third have a strategy. We outline the governance boards should establish ahead of CBK guidance.

  • 50%of institutions surveyed had adopted AI
  • 30%had an AI strategy
  • 8.9%of working-age Kenyans use AI, against 18.8% worldwide (Microsoft)

Based on CBK Survey on AI in the Banking Sector

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Risk and governance Coming soon

Cybersecurity remains the top risk for African audit leaders

Findings from the IIA survey of African internal audit leaders, and the implications of the IIA Cybersecurity Topical Requirement, effective 5 February 2026, for Kenyan audit plans.

  • 73%rank cybersecurity in their top five risks, the fastest-rising risk this year
  • 50%rank digital disruption, including AI, in their top five
  • 816survey responses from 34 African countries

Based on IIA Risk in Focus Africa 2026/2027

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FNJ analysis · Data protection Coming soon

Kenya Data Protection Enforcement Tracker

A quarterly analysis of the Data Protection Commissioner's published determinations by subsector, issue, outcome and remedy. Organisations are described rather than named.

  • 23determinations listed by the Commissioner for 2026 so far
  • 4 of 23were against digital lenders, the largest single group
  • KES 525klargest award among the 2026 determinations coded so far

Based on the Data Protection Commissioner's published determinations

Preview the tracker
Fraud Coming soon

Occupational fraud in Africa: corruption leads and tip-offs detect most cases

Drawing on 2,402 cases worldwide, including 397 in Sub-Saharan Africa and 33 in Kenya, we examine the schemes, losses and detection methods most relevant to Kenyan organisations.

  • 56%of Sub-Saharan African cases involved corruption
  • USD 97kmedian loss per case in the region
  • 45%of cases in the region were detected by a tip

Based on ACFE Occupational Fraud 2026: A Report to the Nations

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Risk and governance Coming soon

Kenya's top risks for 2027

How Kenyan business leaders rank their top risks in the WEF Executive Opinion Survey, benchmarked against the global findings of the WEF Global Risks Perception Survey.

  • 18%of WEF survey experts name geoeconomic confrontation the likeliest trigger of a global crisis in 2026
  • 50%expect a turbulent or stormy global outlook over the next two years
  • 11,000+business leaders in 116 economies answered the WEF survey

Based on WEF Global Risks Report 2026

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Financial sector Coming soon

Kenya Financial Sector Supervision Digest 2026

A consolidated view of the latest findings of the CBK, SASRA, CMA and FRC.

  • KES 1.21tnSACCO sector assets in 2025, across 357 regulated SACCOs
  • 7.87mSACCO members in 2025
  • KES 833bnSACCO member deposits in 2025, up from KES 749bn

Based on SASRA and other regulator reports

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FNJ analysis · Financial sector Coming soon

Kenya Financial Regulator Enforcement Tracker

Breaches, penalties and other supervisory action disclosed in the annual reports of the CBK, SASRA and CMA. Institutions are counted by type rather than named.

  • 35banks in breach of the Banking Act or Prudential Guidelines at end-2025, up from 11 (CBK)
  • 33banks penalised over loan pricing after CBK inspections in 2025 (CBK)
  • 39deposit-taking SACCOs on conditional licences or other interventions in 2025 (SASRA)

Based on CBK and SASRA annual supervision reports; CMA annual report

Preview the tracker

Research pipeline

The publications we monitor and the FNJ briefs in preparation.

ReportPublisherLatest editionFNJ brief
FATF plenary outcomesFATFJune 2026; next plenary 28-30 October 2026Coming soon
Financial Regulator Enforcement Tracker (FNJ)Drawn from CBK, SASRA and CMA annual reportsUpdated as new annual reports are releasedComing soon
Bank Supervision Annual ReportCentral Bank of Kenya2025, published 2026Coming soon
Risk in Focus: AfricaInstitute of Internal Auditors2026/2027, September 2026Coming soon
Survey on AI in the Banking SectorCentral Bank of Kenya2025Coming soon
Data Protection Enforcement Tracker (FNJ)Office of the Data Protection CommissionerDeterminations published on a rolling basisComing soon
Occupational Fraud: A Report to the NationsAssociation of Certified Fraud Examiners2026, May 2026 (biennial)Coming soon
Basel AML IndexBasel Institute on Governance2025, December 2025Coming soon
Global Risks ReportWorld Economic Forum2026, January 2026Coming soon
Sacco Supervision Annual ReportSASRA2025, September 2026Coming soon
Quarterly Statistical BulletinCapital Markets AuthorityQ3 2026Coming soon
Annual revenue performanceKenya Revenue Authority2025/26, July 2026Coming soon

Our approach

Grounded in source data

Figures are taken from the published report, verified against it and referenced to the relevant page or section.

A Kenyan perspective

We concentrate on Kenyan and African data and interpret the findings against the requirements of the CBK, SASRA, CMA, FRC, ODPC and PBORA.

Independent analysis

Our briefs analyse published data and are not FNJ surveys. We link to the original reports rather than host copies.

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Questions about FNJ Research

Are these FNJ surveys?

No. Our briefs analyse reports published by regulators and professional bodies, which are cited in full. Where FNJ offers its own view, this is clearly stated.

Where can I access the original report?

On the publisher's website. Our briefs link directly to the official source, so readers always reach the current edition.

How often do you publish?

Shortly after new editions of the reports we monitor are released, together with an annual supervision digest.

Can FNJ present the findings to our board?

Yes. We brief boards and audit committees on the findings and their implications for the institution.

Translate the findings into action for your institution

Speak to FNJ & Associates about the risks these findings raise for your organisation. The first 15-minute call is complimentary.

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Disclaimer. FNJ Research briefs are general information based on published reports. They are not legal, tax or financial advice. Figures are as published by the original source; confirm the current position in the original report before acting.