Sanctions screening and partner vetting training for NGOs
NGOs that move money through partners must show donors and banks that funds do not reach designated persons or groups, without blocking legitimate work. This course teaches proportionate, risk-based partner vetting and sanctions screening in line with FATF Recommendation 8 and Kenya's sanctions rules.
Choose how your team takes the course
On demand suits people joining through the year and annual refreshers. Live sessions use your own policies, products and cases.
KES 8,000per learner
- Start as soon as payment is confirmed
- Certificate of completion
- Completion report for donors and auditors
KES 10,000per learner per hour
- From 1 hour; you choose the length
- On Zoom or Teams
- Tailored to your operations
KES 10,000per learner per hour, minimum 5-hour session
- At your premises
- Combine with other courses to fill the session
- Case exercises in groups
From the 5th hour, each extra hour is half price. Live and in-person prices are calculated on a minimum of 5 learners; smaller groups are welcome and are priced as 5. For more than 75 learners or more than 16 hours we prepare a custom proposal. All prices include taxes; travel outside Nairobi is charged at cost.
What the rules expect
Donors and banks ask NGOs to show documented, proportionate checks. These are the rules the course is built around.
| Rule or standard | What it requires | Applies to |
|---|---|---|
| Kenya's targeted financial sanctions rules | Screen against the lists, freeze within 24 hours and report. | Everyone in Kenya |
| FATF Recommendation 8 | Focused, proportionate measures for non-profit organisations at higher risk of terrorist financing. | Non-profit organisations |
| Donor due diligence (for example FCDO) | Documented partner checks, including sanctions screening. | Donor-funded NGOs and partners |
Recent developments and emerging issues
The course is updated as rules change. These are the developments it currently covers. Last reviewed: October 2026.
NPO oversight remains an open FATF item
Kenya's exit from the grey list is targeted for April 2027.
Multi-agency working group on NPOs
The group includes the PBO Authority and the FRC, and its mandate includes sensitising the sector.
Kenya's Domestic List
Screening must cover Kenyan as well as UN lists. Replacement sanctions regulations, including humanitarian exemptions, were before Parliament in October 2026.
Humanitarian carve-out made permanent
UN Resolution 2761 made the humanitarian carve-out permanent for the ISIL/Al-Qaida regime. The Al-Shabaab regime was renewed in December 2025.
FATF procedure on unintended consequences
Countries, the IMF and the World Bank can raise cases where the standards are misapplied against legitimate NPOs.
What your staff will learn
Each section ends with a short knowledge check. Learners who finish every section receive a certificate of completion.
How terrorist financing risk reaches NGOs
The typologies that donors and regulators worry about.
Kenya's sanctions framework and lists
UN lists, Kenya's Domestic List and what each requires.
Risk-rating partners
A simple, defensible risk rating.
Proportionate due diligence
What to check and document for each risk level.
Screening tools and false positives
How to screen and clear common false matches.
What to do on a match
Freezing, escalation and reporting within 24 hours.
Humanitarian exemptions
What the carve-outs allow and their limits.
Donor and bank questions
How to answer due diligence questionnaires.
Records donors and auditors can check
The evidence pack shows donors, auditors and the PBO Authority who was trained, on what and when.
- 1Certificates of completionOne per learner who completes the course, with a unique number, the course, date and hours.
- 2Completion or attendance reportWho completed or attended, when, and in which edition.
- 3Knowledge check resultsScores from the checks at the end of each section.
- 4Course outlineThe content and the rules it addresses.
FNJ's forensics, compliance and audit teams
The same teams run AML/CFT programme audits, integrity due diligence and donor-mandated investigations.
CFE, CAMS and CPA(K)
Certified Fraud Examiners, Certified Anti-Money Laundering Specialists and Certified Public Accountants.
Built around your organisation
Before each live or in-person session we send a short questionnaire, so the cases come from your own policies, operations and findings.
AML compliance for NGOs
ML/TF risks, due diligence, beneficiary screening and PBO rules.
AML compliance for NGOsOften taken together
NGO Integrity Essentials combines this course with related courses at 10% off when booked live or in person.
NGO Integrity Essentials
Code of conduct, ABAC, sanctions and partner vetting, and whistleblowing.
On demand KES 32,000 per learner · 10% off live or in person
AML/CFT training for employees
Red flags, due diligence and reporting for all staff.
Course detailsPrice your training
Sanctions screening and partner vetting training is already ticked. Add other courses if you need them, then submit the form to see the payment details.
Questions about sanctions screening and partner vetting training
Do small NGOs need sanctions screening?
Every organisation in Kenya must not make funds available to designated persons. FATF Recommendation 8 calls for proportionate measures, so a small NGO with low-risk partners needs simpler checks than one working in high-risk areas.
Which lists apply in Kenya?
The UN Security Council lists and Kenya's Domestic List. Donors may also require their own lists, for example UK, EU or US lists, under the grant agreement.
What happens on a possible match?
Stop the transaction, check whether it is a true match, escalate internally and, for a confirmed match, freeze the funds and report within 24 hours as Kenya's rules require.
How much due diligence is enough?
Enough to match the partner's risk: basic identity and list checks for low-risk partners, and deeper checks on ownership, governance and use of funds for higher-risk partners, all documented.
Is there a certificate?
Yes. Every learner who completes the course receives a certificate of completion, and the organisation receives a completion report.
Show donors and banks your partner checks hold up
Tell us how many staff need training and by when. We reply within one working day.