Perimeter and funds-flow review
Map each participant, account, instruction, settlement step and revenue line against the National Payment System framework.
A payment authorisation project begins with the product and funds flow—not the application form. We help founders and established payment businesses determine the relevant perimeter, structure the Kenyan operation and build an application record that is consistent with the proposed service.
Discuss your routeWho this is for
Built around the proposed activity.
- Payment gateways, merchant acquirers and payment aggregators
- Mobile, wallet, remittance and money-transfer propositions
- Foreign fintechs entering Kenya through a subsidiary or partnership
- Platforms adding collection, disbursement or stored-value functionality
Defined first engagement
Fintech & PSP Regulatory Scope and Readiness Review
Establish the regulatory route, preparation gaps and next steps for one Kenyan entity or proposed entity and one payment product.
What you receive
- One scoping session and a product, contractual-role and funds-flow map.
- A written regulatory-route assessment stating the material assumptions and unresolved questions.
- A readiness gap matrix across the agreed corporate, governance, finance, policy, technology and partner workstreams.
- A prioritised action plan with document owners and dependencies.
- One findings discussion and one consolidated clarification round.
What we need from you
A product overview, customer journey, funds-flow diagram, entity and ownership outline, partner arrangements and intended launch date. Supporting documents follow after the engagement is agreed.
Typical work sequence
From legal perimeter to operating evidence.
Structure and readiness plan
Confirm the local entity, ownership, governance, capital, safeguarding, technology and outsourcing position.
Application evidence
Coordinate the business plan, programme of operations, policies, financial information, fit-and-proper material and supporting agreements.
Engagement and implementation
Support preliminary engagement, submission, regulatory questions, remediation and the transition from application documents to operating controls.
Core readiness areas
What the work normally needs.
- A clearly defined service and end-to-end funds flow
- Kenyan corporate, ownership and governance documentation
- Capital and financial projections appropriate to the proposed PSP class
- Business plan and programme of operations
- Risk, AML/CFT, consumer-protection, information-security and continuity controls
- Material bank, safeguarding, technology, agent and outsourcing arrangements
Free PSP application resource
Build one controlled index for the complete CBK application record.
Use the editable PSP Licensing Readiness Document Index to assign ownership, track evidence and expose gaps across the product, funds flow, governance, finance, policies, technology and partner workstreams.
Common pressure points
Problems to resolve before they become delays.
- 01
Describing the product differently across the business plan, contracts, financial model and policies
- 02
Treating a technology platform or licensed partner as automatically removing the applicant from the regulatory perimeter
- 03
Leaving bank, safeguarding, settlement or outsourcing arrangements unresolved until late in the process
- 04
Submitting generic policies that do not match the customer journey, risk model or system controls
How the firm assists
A defined mandate, not a generic package.
We can deliver a preliminary route opinion, readiness gap assessment, application workplan, document drafting and review, counterparty-contract support, submission coordination and regulatory follow-up.
Send a non-confidential enquiryFrequently asked questions
Useful starting answers.
Does every fintech handling payments require its own PSP authorisation?+
Not necessarily. The answer depends on the service, control of funds or payment instructions, customer relationship, contractual role and use of licensed partners. A perimeter review should precede structural conclusions.
Can a foreign licence be relied on in Kenya?+
A foreign authorisation may support credibility and group controls, but it does not by itself authorise regulated payment activity in Kenya.
Does incorporating a company authorise payment services?+
No. Incorporation and CBK authorisation are separate steps. The applicable permissions and operating requirements depend on the proposed activities, including a foreign group’s Kenyan business model.
Are professional fees the total PSP establishment cost?+
No. Budget separately for the agreed legal scope, statutory application, authorisation and renewal fees, regulatory capital and operating expenditure. Regulatory capital is not a legal fee or a payment to CBK. Requirements depend on the authorisation category.
How are international-client quotations presented?+
We show professional fees in KES and an indicative USD equivalent using a stated, dated exchange rate. The quotation identifies the controlling currency, agreed scope, applicable taxes and disbursements. An indicative conversion is not a guaranteed settlement rate.
Can an authorisation be held without operations for later resale?+
Plan for an operating business rather than a dormant licence. Under regulation 10(1)(a)–(b) of the National Payment System Regulations, 2014, CBK may suspend or revoke authorisation if business does not commence within six months of issue, or operations cease or are not continued. This is not automatic expiry at six months, and token activity does not establish compliance.
What continuing obligations should an applicant plan for?+
Compliance continues after authorisation, including applicable capital, governance, customer-protection and reporting duties. Regulation 29 requires monthly returns within ten days after month-end, and annual audited financial statements and an independent system-security audit report within three months after 31 December. Check category-specific requirements, lawful exemptions and licence conditions.
Can the business or its ownership be sold later?+
A sale does not automatically transfer regulatory permission. Regulations 8 and 10(1)(j) address significant-shareholder approval and CBK consent for mergers or sales or transfers of the PSP business. Assess the actual transaction and authorisation conditions before completion; not every share transfer is the same transaction.
Can the firm guarantee approval or a fixed approval date?+
No. Approval remains a regulatory decision. The firm can improve readiness, consistency and responsiveness but cannot guarantee the outcome or regulator timetable.
info@snnyagaadvocates.co.ke+254 728 852 448WhatsApp the firm ↗Westpark Towers, 11th Floor, Mpesi Lane, Westlands, Nairobi