Tuesday, April 14, 2015


It appears that the controversy surrounding Dahabshill Money Transfer Company Limited is not over; the Government of Kenya has ordered its Kenyan branches, and a dozen other forex/money transfer company/MSBs, closed, under the authority of the Proceeds of Crime and Money Laundering Act of 2009. Additionally, there are charges of piracy-related activities against some of these companies; Al-Shabaab, an SDGT, conducts a lucrative piracy operation in the Indian Ocean, earning many millions of dollars in ransom payments annually.

The other companies named, according to published reports, are:

(1)  Amal Express Money Transfer Ltd.
(2)  Amana Money transfer Limited
(3)  Bakaal Express Money Transfer Ltd.
(4)  Continental Money Transfer Ltd.
(5)  Flex Money Transfer Limited
(6)  Hodan Global Money Remittance and Exchange Limited
(7)  Iftin Express Money Transfer Limited
(8)  Juba Express Money Transfer Limited
(9)  Kaah Express Money transfer
(10) Kendy Money Transfer Limited
(11) Tawakal Money Transfer Limited
(12) UAE Exchange Money Remittance Limited

All the accounts accounts of these MSBs, in Kenyan banks and micro-finance institutions, have reportedly been frozen, with the Kenyan banks warned to forthwith deny the provision of financial services, and to render transaction reports to the Central Bank, within 48 hours.

We have previously reported on a recent court decision, handed down in the Netherlands, which found there was no factual basis for the allegations that Dahabshiil was connected to Al-Shabaab. It is not known what evidence the Government of Kenya relied upon in taking this action, but we are most anxious to review it.

Compliance officers should be aware that the Kenyan action was administrative, and that there have been no findings of fact, conclusions of law, or adjudication, by a court of competent jurisdiction, of the guilt or innocence of these entities. That being said, consider carefully whether any continued relationship with any of the above entities should be suspended, pending a definitive court decision, for risk management purposes.

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