This paper looks at the challenges the ecosystem faces in addressing illicit finance. Illicit finance continues to pose a significant threat to the integrity of Kenya’s real estate sector. Although Kenya has addressed gaps in its anti-money laundering and countering the financing of terrorism (AML/CFT) laws and deficiencies identified in the 2022 Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) Mutual Evaluation, the system still struggles in practice.
Our report describes the key architecture current to 2025 that operates to prevent money laundering in the real estate sector in Kenya. It discusses the major players across five different categories of actors, the ways they work and the challenges they face. In doing so, it lays out the network that seeks to prevent and address money laundering into real estate in Kenya, as well as those actors seeking to introduce illicit finance into the sector or make it easier to do so.
This paper explores AML/CFT controls relevant to the real estate sector after three years of revision since the 2022 assessment. It outlines the supervisory roles and reporting obligations that apply to buyers, sellers and key intermediaries in real estate transactions.
This paper presents the results of a survey conducted in 2025 with members of the UNCAC Coalition Asset Recovery Working Group, which assessed the availability and accessibility of asset recovery data across 15 jurisdictions, covering both major asset-returning states and countries involved in efforts to return stolen funds to their jurisdiction.
This research paper describes the human rights obligations States have with respect to victim participation in asset recovery processes, from confiscation all the way through to return.
Citizen involvement through non-governmental and community-based organizations is a key feature in the recovery and reuse of recovered assets. The non-governmental organizations Associação Mãos Livres, Associação OMUNGA, Associação Pro Bono Angola and UYELE-Associação Cívica, dedicated to the defense of human rights and the exercise of citizenship, established the Working Group for Transparency and Truth in the Recovery and Reuse of Recovered Assets with the aim of supporting authorities in managing and ensuring the social reuse of returned assets.
This report is intended as a snapshot of the legislative landscape surrounding breaches of international sanctions in these jurisdictions, the innovations that have been put in place, and the shortcomings that still need to be addressed. It presents a mixed picture in terms of frameworks and penalties applied: some countries considering breaches as administrative offences, others having the possibility to impose prison sentences. It also demonstrates discrepancies between sanctioning jurisdictions in how frozen assets and enforcement actions are publicly reported – making it harder for journalists, civil society and citizens to monitor sanctions implementation.
Hoy nos complace presentar seis evaluaciones de la aplicación nacional de la Posición Común Africana sobre Recuperación de Activos.
Aujourd'hui, nous avons le plaisir de lancer six évaluations de mise en œuvre nationale de la Position africaine commune sur le recouvrement des avoirs (CAPAR).
Today we are pleased to launch six assessments of national implementation of the Common African Position on Asset Recovery.
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