Policy commentary | 8 October 2026
Review our recommendations for risk-based fraud prevention, financial-crime controls and consumer protection across Kenya’s national payment system.
Fortifiy supports the objectives of the Draft National Payment System Policy and the Proposed National Payment System Bill, 2026. Our comments recommend treating fraud and financial crime as a distinct, measurable priority alongside cybersecurity, operational resilience and consumer protection.
For your payment operations, the recommendations emphasise risk-based transaction monitoring, AML/CFT/CPF screening, investigation and case management, auditable reporting, and periodic testing of control effectiveness. Instant or irrevocable payments call for proportionate real-time or near real-time controls, beneficiary verification and recovery procedures.
We also propose secure industry fraud-intelligence sharing with data-protection safeguards, standardised fraud reporting, and proportionate oversight of critical RegTech and ancillary service providers. The downloads set out the proposed revisions and the rationale for each recommendation. These are Fortifiy’s recommendations on the drafts, not statements of enacted requirements.
Read the proposed revisions and supporting rationale in each PDF. No registration is required.
Policy commentary · PDF
Six recommendations covering fraud and financial-crime management, intelligence sharing, consumer protection, RegTech adoption and measurable outcomes.
Download: Comments on the Draft National Payment System Policy, 2026Bill commentary · PDF
Eight recommendations covering operational controls, fraud reporting, payment pre-validation, system audits and proportionate oversight of ancillary providers.
Download: Comments on the National Payment System Bill, 2026For financial institutions, PSPs and fintechs looking to strengthen transaction monitoring, screening, investigations and regulatory readiness.