What a Compliant Kenya Property Transaction File Looks Like in 2026
For Kenya property advocates and real estate professionals, the combination of POCAMLA 2025, LSK AML/CFT Guidelines 2025, and the post-Sehmi due diligence standard has created specific file documentation requirements that were not in place before 2024.
This checklist defines what a compliant file should contain for a standard residential property purchase transaction in Kenya in 2026.
Tab 1: Client Identification and CDD
Individual client:
- Certified copy of national ID or passport
- Proof of address (utility bill, bank statement)
- Source of funds documentation (bank statements, payslips, employment letter)
- KRA PIN certificate
- Risk assessment: Low / Medium / High (with basis documented)
- AML/PEP/sanctions screening result
Company client:
- Certificate of incorporation
- CR12 (register of directors)
- List of shareholders (beneficial ownership)
- Certified ID of beneficial owner(s) holding 25%+
- Board resolution authorising the transaction
- Company PIN certificate
- Risk assessment
Tab 2: Title and Property
- Official search (Ardhisasa or physical), dated within 30 days of signing
- Independent verification report (Litmus CVP or equivalent):
- Physical registry file review (root-of-title trace)
- Court process search
- Gazette search
- Named verifier attestation
- Section 106B certificate
- Survey plan (certified copy)
- All encumbrances noted and status confirmed
- For matrimonial property: spousal consent obtained
- For agricultural land: LCB consent application filed and received
- For inherited land: succession documents confirmed (grant, confirmation, transmission)
Tab 3: Transaction Documents
- Sale agreement (signed by all parties, properly stamped)
- Any conditions precedent and how they were satisfied
- Stamp duty self-assessment (KRA iTax)
- Stamp duty payment receipt
- Transfer form (Form RL 1, signed)
- Discharge of any prior charges (signed and stamped)
- All payment receipts (confirmed bank transfers, M-Pesa records)
- Completion statement
Tab 4: Clearances
- Rates clearance certificate (county government)
- Land rent clearance certificate (KRA, leaseholds only)
- LCB consent certificate (agricultural land)
Tab 5: Registration
- Registry receipt (confirmation of submission)
- Title deed in the buyer's name (post-registration)
- Fresh official search confirming registration
Tab 6: Compliance Records
- STR filed? Yes / No (if yes, retain separately in compliance file with reason)
- Any declined actions and reasons
- Training records for staff involved (retained separately in firm compliance files)
Notes
Seven-year retention requirement: All files must be retained for 7 years from completion.
Section 106B certificates: The Litmus verification report includes a Section 106B certificate. This makes the electronic verification records admissible in court without additional authentication.
The FRC examination standard: In an FRC examination, an examiner can request any file from the last 7 years. The above structure ensures the file can be produced quickly and demonstrates the full compliance process.
Litmus CVP (for Tab 2): KSh 3,000 per parcel (institutional). Includes Section 106B certificate.
This article is for general information only. It does not constitute legal advice. For AML/CFT compliance advice specific to your practice, consult a Kenya advocate specialising in financial crime and regulatory compliance.
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