Licence and model definition
Distinguish dealing, non-dealing, money-management and technology roles and identify the applicable licensing route.
CMA licensing requires more than incorporation and minimum capital. The applicant’s platform, execution model, governance, key personnel, client journey, risk disclosures, complaints process, AML/CFT controls and third-party agreements must form a credible operating whole.
Discuss your routeWho this is for
Built around the proposed activity.
- Dealing and non-dealing online foreign-exchange brokers
- Online foreign-exchange money managers
- Foreign brokers assessing a Kenyan subsidiary or regulated partnership
- Technology, liquidity and platform providers supporting the local model
Typical work sequence
From legal perimeter to operating evidence.
Corporate and personnel readiness
Review ownership, capital, directors, key officers, fit-and-proper evidence, local substance and governance responsibilities.
Operating framework
Align platform and liquidity arrangements, onboarding, appropriateness, disclosures, order handling, complaints, AML/CFT, information security and business continuity.
Application and supervision
Coordinate the checklist, online filing, supporting evidence, regulatory queries and post-licensing compliance calendar.
Core readiness areas
What the work normally needs.
- Kenyan incorporation, suitable objects and ownership disclosures
- Prescribed capital and financial evidence for the selected licence
- Qualified directors, management and key control functions
- Platform, liquidity, pricing, execution and service-provider arrangements
- Business plan, financial projections and client-acquisition strategy
- Client onboarding, appropriateness, complaints, AML/CFT, risk and continuity controls
Common pressure points
Problems to resolve before they become delays.
- 01
Selecting a licence label before documenting whether the firm acts as principal, intermediary or portfolio manager
- 02
Treating minimum capital as the complete prudential and operational readiness test
- 03
Using offshore agreements, disclosures or policies without adapting them to the Kenyan entity and regulatory framework
- 04
Failing to evidence fit-and-proper status, local accountability and effective oversight of outsourced functions
How the firm assists
A defined mandate, not a generic package.
We support licence-route analysis, checklist management, corporate and governance documentation, key-personnel readiness, policy suites, platform and liquidity agreements, application review, regulatory correspondence and continuing compliance.
Send a non-confidential enquiryFrequently asked questions
Useful starting answers.
What is the difference between dealing and non-dealing online forex brokers?+
A dealing broker trades as principal and market maker; a non-dealing broker links the client to the foreign-exchange market and does not engage in market making. The actual execution and revenue model must support the selected category.
Is an offshore broker licence sufficient for Kenyan clients?+
No. Marketing or providing regulated online-forex services in Kenya must be assessed under the Kenyan framework, irrespective of an offshore group licence.
Does the licence application end the compliance project?+
No. Capital, client-money, conduct, complaints, reporting, governance and AML/CFT obligations require continuing evidence and oversight after licensing.
info@snnyagaadvocates.co.ke+254 728 852 448Westpark Towers, 11th Floor, Mpesi Lane, Westlands, Nairobi