Activity and perimeter map
Identify each virtual-asset service, customer touchpoint, custody or control feature, token function and cross-border dependency.
Kenya now has a dedicated statutory and regulatory framework for virtual-asset services. The first task is to identify the regulated service, responsible Kenyan regulator and transitional or licensing obligations—not to assume that every blockchain or digital-asset business follows the same route.
Discuss your routeWho this is for
Built around the proposed activity.
- Virtual-asset exchanges, brokers and transfer providers
- Custody, wallet and safekeeping providers
- Token, stablecoin and payment-related virtual-asset businesses
- Foreign VASPs serving or entering the Kenyan market
Typical work sequence
From legal perimeter to operating evidence.
Regulator and route
Determine the competent regulator, local establishment position, transitional obligations and application sequence.
Governance and controls
Build the ownership, key-personnel, safeguarding, technology, cyber, market-conduct, consumer-protection, AML/CFT and travel-rule position.
Application and operationalisation
Coordinate evidence, application materials, regulatory engagement and implementation of approved controls.
Core readiness areas
What the work normally needs.
- A documented classification of the services and virtual assets involved
- Corporate, ownership, governance and fit-and-proper information
- Capital, custody, safeguarding and financial-resilience evidence where applicable
- AML/CFT, sanctions, transaction-monitoring and recordkeeping arrangements
- Technology, cybersecurity, key management, incident and continuity controls
- Customer disclosures, complaints, conflicts, market-conduct and outsourcing arrangements
Common pressure points
Problems to resolve before they become delays.
- 01
Relying on a broad label such as “crypto platform” instead of classifying each actual service
- 02
Assuming decentralisation, offshore incorporation or technology-only wording removes regulatory responsibility
- 03
Leaving custody, key control, safeguarding, travel-rule or sanctions implementation unresolved
- 04
Treating AML/CFT documentation as separate from wallets, monitoring tools and transaction operations
How the firm assists
A defined mandate, not a generic package.
We provide activity classification, regulator-route advice, transitional assessment, readiness audits, governance and policy development, contract review, application coordination and implementation support.
Send a non-confidential enquiryFrequently asked questions
Useful starting answers.
Which regulator handles a Kenyan VASP application?+
The answer depends on the regulated virtual-asset service and the allocation of functions under the Act and Regulations. The activity should be classified before a regulator route is selected.
Do foreign VASPs fall outside the Kenyan framework?+
Not automatically. Offering virtual-asset services in Kenya can engage the Act even where the provider is incorporated elsewhere.
Can an existing AML policy be reused?+
It may provide a starting point, but it must be tested against the virtual-asset risk profile, wallet and transaction controls, sanctions exposure, travel-rule requirements and the actual systems used.
info@snnyagaadvocates.co.ke+254 728 852 448Westpark Towers, 11th Floor, Mpesi Lane, Westlands, Nairobi