The March 2026 DNFBP Compliance Deadline: What Kenya Property Firms Must Do Now
The Financial Reporting Centre (FRC) set March 2026 as the deadline for Designated Non-Financial Businesses and Professions (DNFBPs) to register with the FRC and implement their anti-money laundering and counter-terrorism financing compliance programmes.
If your law firm, real estate agency, or property development company has not yet registered and implemented, you are now behind the deadline. The FRC has been issuing penalty notices.
Here is what you need to do.
Who Is a DNFBP in Kenya?
Under the Proceeds of Crime and Anti-Money Laundering (Amendment) Act 2025 (POCAMLA 2025), the following categories are designated:
Law firms and advocates handling conveyancing, property transfers, company formation, trust management, or client fund management.
Real estate agents and developers involved in buying, selling, leasing, or developing property on behalf of clients or investors.
Accountants providing audit, tax, or financial management services involving real estate or significant asset transactions.
Dealers in precious metals and stones.
Trust and company service providers.
If your business handles property transactions in any of these capacities, you are a DNFBP reporting entity.
What Registration With the FRC Involves
Step 1: Create an FRC portal account. Register your firm at the FRC's compliance portal (frc.or.ke). You will need:
Your firm's registration certificate.
Details of the compliance officer appointed for the firm.
Step 2: Complete your firm profile. Fill in information about your firm's business activities, client types, and transaction volumes.
Step 3: File your risk assessment. As a DNFBP, you must conduct and document a business-wide risk assessment, identifying where your firm is exposed to money laundering risks and what controls you have in place.
Step 4: Submit your compliance programme. Your AML/CFT compliance programme includes:
Written policies and procedures.
Client due diligence procedures.
Record-keeping procedures.
Suspicious transaction reporting procedures.
Staff training programme.
The compliance programme does not need to be elaborate, but it must exist in writing and must reflect your actual operations.
The Penalty Level
FRC penalty notices issued in early 2026 have been in the range of KES 200,000 to KES 250,000 per non-compliant firm.
For a solo advocate's firm, this is significant. For a small real estate agency, it is significant. For larger firms, it is manageable in monetary terms but damaging in reputational and regulatory terms.
The FRC also has the power to refer serious non-compliance to prosecuting authorities for criminal action under POCAMLA 2025.
The Post-Sehmi Connection
The DNFBP compliance deadline coincides with the post-Sehmi requirement for advocates to conduct independent root-of-title verification.
Both requirements point in the same direction: property professionals in Kenya must now verify more, document more, and demonstrate that verification through matter file records.
A property advocate who has implemented their DNFBP compliance programme and who uses Litmus verifications as their independent title verification tool has:
A registered FRC compliance programme covering client due diligence and source-of-funds verification.
Matter files containing documented root-of-title verification (the Litmus report) and court process and gazette searches.
Section 106B-certified electronic records in the verification report.
This is what a professionally compliant property law practice looks like in post-March 2026 Kenya.
What If You Have Already Been Issued a Penalty Notice?
If you have received an FRC penalty notice:
Do not ignore it. Non-response to an FRC penalty notice can escalate the matter.
Pay the penalty within the specified period.
Simultaneously, implement your compliance programme. The penalty notice should come with guidance on what the FRC found deficient.
File your registration and compliance programme as quickly as possible.
If you believe the penalty was issued in error or the amount is disproportionate, consult a Kenya advocate specialising in regulatory compliance for advice on any available appeals process.
This article is for general information only. It does not constitute legal advice. For DNFBP compliance advice specific to your firm, consult a Kenya advocate specialising in financial crime and regulatory compliance.
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