Illicit financial flows (IFFs) cost Africa at least USD 50 billion annually, and Uganda, Kenya and Ghana each show a different side of this problem. Ghana ranks third in sub-Saharan Africa for IFF losses, with an estimated USD 54.1 billion lost between 2013 and 2022. Kenya is not far behind in fifth place, with an estimated USD 47.5 billion lost over the same period. Uganda’s exposure is smaller in absolute terms but no less structurally significant: trade misinvoicing alone produced an estimated USD 6.6 billion value gap between 2006 and 2015, and annual losses continue at an estimated more than UGX 2 trillion. Behind nearly every significant movement of illicit capital across all three countries stands a professional enabler. It may be a lawyer who structures the vehicle, an accountant who certifies the accounts, a real estate agent who closes the deal, or a trust and company service provider who maintains anonymity. This report examines efforts to regulate professional enablers of IFFs across Uganda, Kenya and Ghana.
For each country, the report sets out the national context and the categories of professional enablers involved. It then assesses the existing legal, policy and institutional frameworks, from international and regional conventions to domestic anti-money laundering legislation and the mandates of financial intelligence units and sector regulators. Documented case studies of professional enablement are presented for each country, including the Crane Bank and Golden Laundromat cases in Uganda and the Agyapa Royalties transaction in Ghana. The report further highlights key initiatives to regulate professional enablers and the legislative and regulatory gaps in each country, and pairs them with specific recommendations and conclusions. It also addresses emerging global perspectives on artificial intelligence, virtual assets and RegTech, both as risks and as tools in combating professional enablers.
All three countries have made legislative and institutional progress, though at different paces. Ghana has enacted the Anti-Money Laundering Act, 2020 (Act 1044), the Real Estate Agency Act, 2020 (Act 1047) and the Gold Board Act, 2025 (Act 1140). It has also completed its 2024 National Risk Assessment and exited the FATF grey list in 2021. Kenya has built a comparatively wide institutional framework anchored in the Proceeds of Crime and Anti-Money Laundering Act, 2009, spanning the Financial Reporting Centre, the Central Bank of Kenya, the Capital Markets Authority and the Ethics and Anti-Corruption Commission. Even so, Kenya remains on the FATF grey list as of the most recent 2026 plenary. Uganda was delisted from the FATF grey list in 2025 on the strength of reforms centred on the Anti-Money Laundering Act, Cap. 118 and the Financial Intelligence Authority, though its supervisory regime for designated non-financial businesses and professions (DNFBPs) remains comparatively underdeveloped.
Despite this uneven progress, significant gaps persist in all three countries, and the same structural weaknesses recur in each. DNFBPs remain under-supervised relative to banks, and suspicious transaction reporting from professional sectors is minimal; Ghana’s Financial Intelligence Centre recorded only two suspicious transaction reports from all DNFBP categories combined between 2016 and 2019. Licensing regimes for trust and company service providers are absent or incomplete, and enforcement capacity has not kept pace with legislative ambition. Digital and AI-enabled typologies are an emerging area barely addressed by current law in any of the three countries. Kenya’s continued presence on the FATF grey list is the clearest evidence that technical compliance on paper does not yet translate into effectiveness on the ground, and this caution applies equally to Ghana and Uganda, even where grey-list status has been resolved.
To address these gaps, the report recommends that:
- Governments enact dedicated licensing and regulation regimes for trust and company service providers. These should set mandatory fit-and-proper criteria, AML/CFT obligations covering customer due diligence, suspicious transaction reporting and record-keeping, and beneficial ownership transparency for all trust arrangements.
- Governments put beneficial ownership rules into effect through centralised, publicly accessible registries, with strict penalties for false or incomplete filings.
- Financial intelligence units run sector-by-sector compliance campaigns with professional associations, publish annual suspicious transaction reporting statistics by DNFBP sector, and link administrative sanctions, including licence suspensions, to non-compliance.
- Professional bodies amend their disciplinary rules to make wilful AML/CFT non-compliance a ground for professional misconduct proceedings.
- Governments establish dedicated, sustainably funded AML/CFT supervisory capacity, supported by technical assistance from ESAAMLG, GIABA, FATF and development partners.
- Financial intelligence, tax, company registry, central bank and law enforcement agencies are connected on a fully integrated platform, replacing slow, request-based tracking with proactive, data-driven oversight.
- Governments institute an ex ante corruption and IFF risk assessment mechanism for major government transactions involving offshore vehicles, special purpose vehicles or complex cross-border structures, before parliamentary approval.
- Each country develops a national SupTech strategy for its financial intelligence unit and DNFBP supervisors, and includes AI-facilitated and virtual-asset laundering typologies in its national risk assessments.
- Kenya strengthens supervision and enforcement, raises public awareness of the risks of grey-listing, and deepens international cooperation against cross-border financial crime.