DRAFT

THE CENTRAL BANK OF KENYA ACT

(Cap 491)

IN EXERCISE of the powers conferred by sections 2, 33B and 57 of the Central

Bank of Kenya Act, the Central Bank of Kenya makes the following Regulations:

THE MONEY REMITTANCE REGULATIONS, 2012

PART I- PRELIMINARY

1. Citation
These Regulations may be cited as the Money Remittance Regulations, 2012.

2. Policy Statement
The purpose of the regulation is to:
1) Specify conditions for licensing and supervision of persons licensed to transact
money remittance business;
2) To encourage the increased use of formal funds transfer systems through the
facilitation of foreign exchange transfers and remittances that are timely,
accessible, cost effective, and reliable;
3) Require money remittance providers to observe anti-money laundering and
combating of the financing of terrorism measures.

3. Scope
These Regulations apply to all money remittance providers licensed to operate within
Kenya.

4. Interpretations
In these Regulations unless the context otherwise requires:
‚Act‛ means the Central Bank of Kenya Act, Cap 491.
‚Agent‛ means an entity that has been contracted by a money remittance provider
and approved by the Central Bank to provide the services of the money remittance
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on behalf of the money remittance provider in the manner specified in these
Regulations.
‚Licensing‛ means approval granted in accordance with these Regulations to allow
the holder to carry on money remittance business.
‚Bank‛ means Central Bank of Kenya.
‚Core capital‛ means permanent shareholders’ equity in form of issued and fully
paid- up shares of common stock plus all disclosed reserves, less goodwill and
any other intangible assets.
‚Foreign currency‛ means foreign currency as defined under the Central Bank of
Kenya Act.
‚Money Laundering‛ is an offence as defined in the Proceeds of Crime and Anti-
Money Laundering Act, 2009.
‚Money remittance business‛ means the acceptance of monies for the purposes of
transmitting them to persons resident in Kenya or another country.
‚Money remittance provider‛ means a person licensed to undertake money
remittance business.
‚Non- resident‛ means a person or body of persons other than a resident.
‚Officer‛ means a director, chief executive officer or any other senior officer of a
money remittance provider who has been vetted and approved by the Central Bank
of Kenya.
‚Outlet‛ means a place of business of a money remittance provider that has been
approved by the Central Bank of Kenya.
‚Payment‛ means the transfer of currency for the purpose of discharging a liability,
making a gift or donation or for creating a balance at a bank of financial institution
which can be drawn upon.
‚Payment for current transaction‛ means a payment other than a payment for
transferring capital and includes:
(a) A payment due in connection with trade;
(b) A payment due as interest or as net income or return from other investments;
(c) A payment for amortization of a loan or for depreciation of direct investment;
or
(d) A remittance for family living expenses.
‚Resident‛ means:-

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 (a) An individual who has been present in Kenya continuously for a period of at
least one year or who has declared his intention to reside in Kenya for a
period of at least one year to Kenyan immigration authorities;

(b) The Government of Kenya or any accredited official of its diplomatic missions
residing outside Kenya;

(c) A company or other body of persons whose principle place of business is

located in Kenya and branches of such company or body located in Kenya;

(d) Branches of a company or other body of persons carrying on business in

Kenya whose principal place of business is located outside Kenya excluding
any foreign diplomatic mission or any of its accredited officials or any
organization established in or outside Kenya by international treaty or any of its
accredited officials.

PART II- ESTABLISHMENT AND LICENSING OF MONEY REMITTANCE PROVIDERS

5. Licensing of Money Remittance Providers (MRPs)

(1) A person shall not provide money remittance services in Kenya unless such
person is:
(a) Established and incorporated as a limited liability company under the
Companies Act whose business name incorporates the words ‚Money
Remittance Provider‛; and

(b) Licensed to provide money remittance services under these Regulations.

(2) A person who wishes to transact the business of money remittance in Kenya
shall:
(a) seek the Bank’s approval for the proposed business name before
incorporation;

(b) have a minimum core capital of not less than Kshs.20,000,000 before
commencement of operations which should be maintained at all times;

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 (c) have a fixed and identifiable place of business that is accessible to the
public and suitable in all respects for the business of money remittance as
may be determined by the Bank ;

(3) The Bank shall consider the following factors in making a decision to grant a
licence:
(a) the applicant’s statement of financial affairs;

(b) the competence and integrity of the applicant’s proposed management;

(c) the adequacy of the applicant’s capital structure, earning prospects,

business and financial plans;

(d) whether the public interest will be served by the granting of the licence to
the applicant;

(e) the history, character and integrity of the applicant’s shareholders and
proposed directors.

6. Application and Granting of a Licence

(1) An application for money remittance licence shall be submitted to the Bank and
addressed to the office responsible for licensing and supervision of money
remittance services at the Central Bank of Kenya in a duly completed
FORM/CBK/MRB/1 as set out in the First Schedule in these Regulations
accompanied by the following information:

(a) non-refundable application fee of Kshs.20,000 payable by bankers cheque

to the Central Bank of Kenya;

(b) a certified copy of the applicant’s certificate of incorporation;

(c) a certified copy of the applicant’s memorandum and articles of association;

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(d) feasibility study by the applicant indicating the nature of the planned
business, organization structure and internal control systems and monitoring
procedures of the company, covering inter-alia the following aspects:

i) The name and location of proposed business premises.

ii) Ownership structure.
iii) Governance and management structure.
iv) Market analysis (competition and demand analysis).
v) Products.
vi) Three year projected financial statements (statement of financial
position, statement of comprehensive income; and cash flow
statement).
vii) Business continuity plan

(e) bank statements of the applicant, shareholders and directors of the

proposed money remittance provider for a period of six months prior to
the date of application;

(f) duly completed fit and proper forms FORM/CBK/MRB/2 as set out in the
Second Schedule in these Regulations for the shareholders, directors, chief
executive officer and any other senior officers of the money remittance
provider as may be determined by the Bank;

(g) credit reports from a credit reference bureau for the applicant,
shareholders, directors, the chief executive officer and any other senior
officers of the money remittance provider as may be determined by the
Bank;

(h) a declaration by the applicant that none of its directors and/or

shareholders has ever been declared bankrupt, participated in the
management of a collapsed institution, convicted by any court of competent
jurisdiction in Kenya or elsewhere of a criminal offence involving fraud,
money laundering, tax evasion, or any other act of dishonesty;

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 (i) a declaration by the applicant that none of its directors and/or
shareholders holds a similar position or role in another money remittance
provider;

(j) an undertaking by the applicant to comply with the provisions of the

Central Bank of Kenya Act, the Proceeds of Crime and Anti Money
Laundering Act, 2009, Prevention of Terrorism Act, 2012 or any
directives issued by the Bank; and

(k) any other information as may be required by the Bank.

(2) The following factors shall at a minimum be considered in determining whether

or not a person is fit and proper to own or control a money remittance
provider:

(a) conviction of an offence of fraud or any other offence of which dishonesty

is an element;

(b) contravention of the provisions of any law designed to safeguard the

integrity of the financial system and for the protection of members of the
public against financial loss due to dishonesty or incompetence or
malpractices by persons engaged in provision of financial services;

(c) being a past director or senior officer of an institution licensed by the

Bank of Kenya that has been liquidated, placed under statutory
management or whose licence has been revoked;

(d) past engagement in any business practices that, in the opinion of the
Bank of Kenya, were fraudulent, prejudicial or otherwise improper (whether
lawful or not) or which otherwise discredited his/her methods of
conducting business;

(e) participation or association with any other business practices as would, or

otherwise conducted himself/herself in such manner as to cast doubt on
his competence and soundness of judgment;
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 (f) defaulting in repayment of any credit facility made to him by any
institution;

(g) evasion of taxes;

(h) removal from an office of trust on account of misconduct, abuse of office,

corruption or incompetence in the immediately preceding ten years;

(i) legal disability; and

(j) any other factors as may be determined by the Bank.

(3) The Bank shall license a money remittance provider if the applicant meets the
requirements set out in these regulations and shall within 90 days of the date
of lodging the application:

(a) request for any additional information that it may require; and

(b) where it is satisfied that all the necessary requirements have been met,
issue a letter of intent to the applicant advising the applicant to fulfill the
following:

i) Pay the licence fee of Kshs.100,000.

ii) Obtain a security bond from a commercial bank equivalent to 10%
of the total business turnover for the preceding 12 months to 30th
September of each year subject to a minimum of Kshs.10,000,000
whichever is higher. Where a money remittance provider ceases to
carry out money transfer business, the Bank will utilize the security
bond to offset any claims against it by customers for unremitted
funds.
iii) Prepare the premises for inspection by the Bank prior to
commencement of business.

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 (c) Inform the applicant in writing that the application has been declined and
advise the unsuccessful applicant that an appeal to the Bank for review of
the decision to decline may be lodged within 30 days from the date
thereof.

(4) Where a money remittance provider is licensed by the Bank;

(a) there shall be no refund of the licence fee paid to the Bank in the event
that licence is cancelled or revoked or a money remittance provider
ceases to carry on business at any time before expiry of the licence;

(b) there shall be no proration of the licence fee paid in the course of the
year;

(c) the Bank may in conformity with the regulations add, vary or substitute
any condition to the licence;

(d) the licence is valid for a period of one calendar year i.e. January 1 to
December 31 or the remaining period to December 31 for new licence
granted in the course of the year;

(e) the licence granted shall not be transferred, assigned or encumbered in

any way;

(f) the licence shall be revoked if the money remittance provider fails to
conduct the service of money remittance within twelve (12) months of
the date of issue of the licence without the written consent of the Bank
or at any other time as provided under Regulation 28 on suspension and
revocation of licence;

(5) A money remittance provider shall be licensed on condition that it shall not
engage in any business operation other than as authorized under these
regulations.

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7. Renewal of Licence
(1) An application for renewal of licence to provide money remittance services shall
be submitted to the Bank in FORM/CBK/MRB/1 as set out in the First
schedule in these Regulations at least one month before the expiry of the
licence.

(2) The Bank may renew a licence where;

(a) it is satisfied that the money remittance provider has been operating in
conformity with these regulations;

(b) the money remittance provider has paid the prescribed licence fee and all
outstanding penalties imposed or levied on the money remittance provider
under the regulations;

(c) the money remittance provider has met its tax obligations and submitted
current certified copy of tax compliance certificate or its equivalent as
issued by the Kenya Revenue Authority;

(d) the money remittance provider, its shareholders and directors have not
defaulted in repayment of any credit facilities granted to them by any
institution as indicated in their individual credit reports or any other source
as the Bank may from time to time determine;

(e) Where a money remittance provider submits an application for renewal of

licence as provided under subsection (1) above, it shall be deemed to
be operating with a valid licence during the period commencing from the
date of expiry of the previous licence until the date on which the licence
is renewed or the application for renewal is declined.

(3) Where a money remittance provider fails to fulfill any of the conditions set by
the Bank for the purpose of renewal of its licence within ninety (90) days
from the date of expiry of licence, the licence shall not be renewed and shall
be revoked.

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8. Prescribed Fees
(1) The prescribed fees payable by money remittance providers in respect of
various applications shall be as set out in table 1:

Table 1: Prescribed Fees

Type Fees
(Kshs)
1. Annual licence fee per outlet 100,000
2. Application fee for a new licence 20,000
3. Application fee for a new outlet 10,000

(2) Fees payable under subsection (1) above shall be paid by bankers cheque
payable to the Bank or by any other means prescribed by the Bank.

9. Ownership and Management

(1) No person shall become a shareholder of a money remittance provider unless
such a person is deemed ‘fit and proper’ and approved by the Bank.

(2) A money remittance provider shall not transfer its share capital without prior
written approval of the Bank.

(3) Directors, chief executive officers and other senior officers of money remittance
providers as may be determined by the Bank shall be vetted and approved by
the Bank prior to assuming office.

(4) Money remittance providers shall appoint:

(a) at least two directors;
(b) a chief executive officer and other senior officers responsible for all the
operations of the money remittance business as may be determined by the
Bank; and

(5) Application for approval of officers under subsection (3) above shall be
forwarded to the Bank accompanied by the following documents:

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 (a) duly completed fit and proper form, FORM/CBK/MRB/2, as set out in
the Second Schedule of these Regulations;

(b) certified copy of Identity Card or Passport;

(c) certified copy of academic and school leaving certificate;

(d) curriculum vitae;

(e) two passport size photographs;

(f) certificate of good conduct;

(g) credit reports of the officers from a credit reference bureau;

(h) any other documents as may be required by the Central Bank of Kenya
from time to time.

(6) The chief executive officer and all senior officers approved by the Bank shall
be full time employees of the money remittance provider.

(7) The directors, chief executive officer and all senior officers of a money
remittance provider shall have minimum educational qualification of ordinary
level certificate or its equivalent and have adequate knowledge of money
remittance operations, these regulations, the Central Bank of Kenya Act, the
Proceeds of Crime and the Anti-Money Laundering Act, 2009 and any other
relevant legislation.

(8) No person shall become a shareholder or an officer in more than one money
remittance provider.

(9) Money remittance providers shall ensure that all staff are adequately trained in
the operations of the money remittance business and regulatory requirements.

(10) The directors and management of a money remittance provider shall:

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 (a) Ensure the activities conducted by the money remittance providers are in
full conformity with these Regulations;

(b) Ensure the money remittance provider maintains, at all times, an effective
system of internal controls; and

(c) Develop appropriate policies and procedures to guide all areas of its
operations including accounting, human resources and information
technology.

10. Disqualification of Shareholders and Senior Officers

(1) The Bank may disqualify approved shareholders, directors or senior officers of
a money remittance provider who:

(a) fail to adhere to these Regulations, the Central Bank of Kenya Act or
any directives issued by the Bank;

(b) fail to meet vetting requirements on an on-going basis;

(2) A money remittance provider shall ensure that no person shall be an officer or
an employee of the money remittance provider, or if already in employment,
shall be disqualified and shall not thereafter be eligible to hold office or be in
the employment of any money remittance provider if such person is:

(a) An undischarged bankrupt or enters into a composition or scheme of

arrangement with his creditors;

(b) Convicted of an offence involving fraud or dishonesty; or

(c) Removed from office under the provisions of these Regulations.

PART III- OPERATIONS OF MONEY REMITTANCE PROVIDERS

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11. Authorized Business Activities
(1) Money remittance providers shall deal in inbound and outbound international
money transfer business. The following conditions shall apply in the transaction:

(a) A payment transaction must be executed in the currency agreed between

the parties;

(b) Where a currency conversion service is offered before initiation of payment

transaction, the money remittance provider must disclose all charges as
well as the exchange rate to be used for converting the payment
transaction.

(2) Money remittance business shall be conducted through partnership with

International Money Transfer Operators or acquisition of franchise by local
money remittance provider from a International Money Remittance Operators.

(3) Money remittance providers may conduct money transfer as agents of mobile
phone companies subject to prior approval of the Bank and shall:

(a) submit to the Bank a signed copy of the contract/agreement between the
money remittance provider and the telecoms company or the agent;

(b) Money remittance provider shall provide a list of all locations of

International Money Remittance Operator in the world that are duly
authorized entities according to the laws on money remittance in those
countries.

(c) The Bank in deciding whether to approve an international agent may

request information or opinion from the host countries.

(d) submit any other additional information as may be required by the Bank ;

(e) conduct business in compliance with both the applicable laws and
regulations of the Agency and these regulations.

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(4) A money remittance provider may be allowed to conduct money remittance
business through agents such as commercial banks, forex bureaus, telecoms
and Kenya Post Office Savings Bank or any other company or organization
that the Bank may approve.

(5) The contract between a money remittance provider and an agent shall contain
as a minimum, the following information:

(a) The money remittance provider is wholly responsible for and liable for all
actions or omissions of the agent. The responsibility extends to actions of
the agent even if not authorized in the contract so long as they relate to
money remittance business or matters connected therewith;

(b) Measures to mitigate risks associated with agent business including, limits,
customer transactions, cash management, cash security, security of agent
premises and insurance policies;

(c) Specific services to be rendered by the agent;

(d) The rights, expectations, responsibilities and liabilities of both parties;

(e) The Bank shall have free, full, unfettered and timely access to the
internal systems, documents, reports, records, staff and premises of the
agents in so far as money remittance business is concerned and shall
exercise such powers as it may deem necessary;

(f) AML/CFT requirements;

(g) Duty by the agent to deliver transaction support documents;

(h) A statement that all information or data that the agent collects in relation
to agent money remittance services, whether from the customers, the
money remittance provider or from other sources, is the property of the
money remittance provider;

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 (i) Adequate oversight safeguards for the money remittance provider to
address instances of non-compliance by the agent with the stipulated
obligations;

(j) Prohibition from charging the customer any fees;

(k) Business hours of the agent;

(l) Suitable limits on cash holding by the agent and also limits on individual
customer payments and receipts;

(m) Confidentiality of customer and user information;

(n) Remuneration for the agent;

(o) A statement that the Bank can at any time terminate the contract in the
exercise of its powers under these Regulations or any other law;

(p) A transition clause on the rights and obligations of the money remittance
provider and the agent upon termination or cessation of the agency
contract;

(q) A requirement for the money remittance provider’s prior approval to be

obtained when an agent is seeking to transfer the agency business.

(6) Money remittance providers shall be allowed to be appointed as agents of

commercial banks under Agency Banking Guidelines.

12. Unauthorised Business Activities

(1) Money remittance providers shall not be permitted to:

(a) act as authorized dealers in gold;

(b) engage in lending money;

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 (c) engage in deposit taking;

(d) Cheque cashing;

(e) maintain current accounts on behalf of customers;

(f) establish letters of credit;

(g) act as custodians of funds on behalf of customers; and

(h) engage in such other activity as the Bank may prescribe.

(2) Money remittance providers shall not allow or process transactions that are or
appear to have been deliberately split into small amounts equivalent to
US$10,000 or below to avoid the requirement of reporting to the Bank.

(3) Money remittance providers may carry out any other activity that the Bank may
approve from time to time.

13. Place of business

(1) A money remittance provider may be permitted to open outlets and shall
designate one of the outlets as its head office.

(2) The Bank shall carry-out an onsite inspection of the applicant’s premises to
determine:

(a) Suitability of the premises for money remittance business;

(b) Adequacy of the management information system, administrative and

operational processes and the internal control system;

(3) A money remittance provider shall seek prior written approval from the Bank
before opening a new outlet by submitting an application accompanied by a
duly completed FORM CBK/MRB/4 as set out in the fourth Schedule of these

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 Regulations; the prescribed application fees and other documents as may be
determined by the Bank .

(4) An approval to operate an outlet may be granted by the Bank upon fulfillment
of all requirements including inspection of the business premises and payment
of the prescribed fees.

(5) A money remittance provider shall notify the Bank of the business hours for
each of its outlets.

(6) No money remittance provider shall change its business hours without notifying
the Bank.

(7) The approved business hours should be displayed prominently at each of the
money remittance provider’s business premises.

(8) A money remittance provider shall display prominently at each of its business
premises:

(a) the current licence to engage in money remittance;

(b) details of levies/tariffs to be charged;

(c) a notice informing the customers that they are entitled to be issued with
a receipt for any money remittance transactions; and

(d) a notice to the effect that the money remittance provider is not allowed to
maintain current accounts on behalf of the clients.

(9) A money remittance provider shall not relocate its business from approved
premises without prior written approval of the Bank.

(10) A money remittance provider shall ensure that it seeks prior written approval
of the Bank for temporary closure of any of its places of business.

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(11) A money remittance provider shall not be allowed to sublet, lease or
authorize any other person to undertake any other business or offer any
other product(s) or services in its business premises other than as
approved by the Bank.

(12) The business premises of a money remittance provider shall be accessible to

the general public and the Bank.

(13) The Bank shall before granting any approval under these regulations in
respect of opening an outlet, satisfy itself that:

(a) the money remittance provider is financially sound;

(b) the management of the money remittance provider has been certified as
fit and proper by the Bank ;

(c) the capital structure and earning prospects, business and financial plans
of the money remittance provider are adequate;

(d) the public interest will be served by the opening of a new place of
business in that location;

(e) the outlet will enhance the operations and performance of the money
remittance provider;

(f) the money remittance provider has the capacity to process information of
all its outlets on-line; and

(g) the money remittance is fully compliant with these regulations and the
Central Bank of Kenya Act.

(14) The Bank may, in granting approval under sub section (11), impose such
other conditions as it deems fit.

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 (15) A money remittance provider facing operational challenges, disclosure of which
shall be made to the Bank, will be required to seek prior written approval
from the Bank to close or suspend the operations of the money remittance
provider temporarily.

14. Equipment
(1) A money remittance provider shall have the necessary equipment to;

(a) detect counterfeit currency;

(b) determine the appropriate levies and tariffs;

(c) communicate effectively; and

(d) process data and generate reports that meet regulatory requirements.

15. Bank accounts

(1) Every person granted licence to conduct money remittance business shall
maintain an account in the name of the money remittance provider at a
commercial bank licensed pursuant to the Banking Act in Kenya entitled
‚customers’ account‛.

(2) Every money remittance provider carrying on money remittance business shall
pay into the account all amounts that are received from its customers for
remittance purposes not later than the next business day following the day on
which the moneys were received.

(3) No money shall be withdrawn from the customers’ account except:-

(a) Money that has been paid into the account by the money remittance
provider for the purposes of opening or maintaining the account;

(b) Money properly required for payment to or on behalf of a customer;

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 (c) Money properly required for payment of the charges for rendering services
to a customer and the customer has notified that any money held on
their behalf will be applied towards or in satisfaction of such fees and
charges.

(4) No money other than money which a money remittance provider has paid into
a customers’ account for the purposes of opening the account and money
required to be paid under sub regulation (2) above shall be paid into such
an account.

(5) It shall be the duty of the money remittance provider to withdraw any money
paid into the customers’ account in contravention of the sub regulation (4)
above upon discovery of the mistake.

(6) The money in a customers’ account maintained by a money remittance provider

at a bank is not liable to be attached in respect of any debt.

16. Foreign Exchange inflows and outflows

(1) All foreign exchange inflows and outflows of money remittance providers shall
be received through commercial banks, documented and advised to the Bank in
the prescribed format.

17. Records of Transactions and Documentations

(1) A money remittance provider shall maintain a sound management information
system that facilitates efficient collection and processing of statistical data and
information required to provide audit trails for use by internal auditors, external
auditors and the Bank.

(2) A money remittance provider is required to maintain accurate and meaningful

originator and beneficiary information for a period not less than seven years on
funds received/remitted by requiring the sender/recipient to fill up and sign an
application form, which shall contain the following minimum data and
information:-

(a) Date.
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 (b) Printed name and signature of remitter or beneficiary.

(c) Identity card / passport number of customer.

(d) Present address.

(e) Permanent Address.

(f) Date and place of birth.

(g) Telephone number (If applicable).

(h) Nationality.

(i) Amount and currency to be remitted or received.

(j) The principal activity of the customer conducting the transaction.

(k) Purpose of remittance.

(l) Source of Funds.

(3) A money remittance provider shall, for every transaction, issue an accurate
receipt which should contain the following information as a minimum;

(a) full names of the customer;

(b) identity card/ passport number of customer;

(c) the type and amount of currency (send or receive);

(d) the transaction number;

(e) the nature, time and date of the transaction;

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 (f) name and address of the money remittance provider and name of the
employee who served the customer;

(g) a brief statement on source or purpose of the funds;

(h) customer signature; and

(i) commission charged.

(4) All transactions generated by the money remittance provider in the course of
its business activities must be posted to its books of accounts.

(5) A money remittance provider shall maintain the following records:

(a) list of all transactions;

(b) a daily summary of all monies received and sent;

(c) fixed assets list; and

(d) any other records applicable to the money remittance provider or as may
be specified by the Bank .

(6) A money remittance provider shall keep all records up to date, cross-checked
and verified on a daily basis.

(7) A money remittance provider shall retain all relevant records obtained by them
during the course of their operations and keep them for at least 7 years from
the date on which the record was created. The records should at a minimum
include the following details:

(a) transaction receipts;

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 (b) a copy of documentary evidence used to verify the identity of the
customer; and

(c) dully completed application forms for all money remittance transactions.

(8) The retention of the relevant records under subsection (7) may be effected
by electronic means.

(9) A money remittance provider shall maintain such books of accounts and
records so as to enable timely preparation of audited annual financial
statements and generation of reports.

(10) Correspondences, registers, books of accounts and financial statements relating

to the operations of the money remittance business shall be properly
maintained.

18. Submissions to the Bank

(1) A money remittance provider shall submit the following returns to the Bank
on-line or as directed in the prescribed format;

(a) daily returns of money sent and received equivalent to or above

US$10,000 including customers who transact repeat transactions in a day
amounting to US$10,000;

(b) weekly returns of money remittance transactions not later than 3.00 p.m.
on the first working day of the following week;

(c) quarterly balance sheet and profit and loss account within thirty days after
the end of every quarter;

(d) audited balance sheet and profit and loss accounts within three months
after the end of the financial year;

(e) any other return as may be prescribed by the Bank from time to time.

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 (2) The financial year for all money remittance providers shall be January 1 to
December 31.

(3) A money remittance provider should ensure that accurate returns are submitted
to the Bank as required.

PART IV- Anti-Money Laundering

19. Policies and procedures

(1) The board of directors and management of money remittance provider shall
formulate, adopt and apply appropriate policies and procedures to detect,
prevent, report or otherwise deal with incidences of money laundering.

(2) Customer Due Diligence:

(a) A money remittance provider should have a customer identification program
that delineates the procedures for identifying customers and documentation
to be obtained from the customer in this regard;

(b) Customer due diligence measures are to be applied prior to the

commencement of a transaction and appropriate documentation used to
establish a customer’s identity. Such documentation should be verified by
the money remittance provider;

(c) The following information shall be the minimum acceptable for determining
the true identity of customers wishing to make transactions:

(i) In the case of an individual;

I. a birth certificate;
II. a national identity card;
III. a driver’s licence;
IV. a passport; or
V. any other official means of identification as may be prescribed;
and

(ii) In the case of a body corporate;

24
 I. evidence of registration or incorporation (such as a certified copy
of Certificate of Registration or Certificate of Incorporation,
Partnership Deed or Memorandum and Articles of Association);
II. the Act establishing the body corporate (in case of a state
corporation);
III. a corporate resolution authorising a person to act on behalf of
the body corporate together with a copy of the latest annual
return submitted in respect of the body corporate in accordance
with the law under which it is established; and
IV. or any other item as may be prescribed.

(d) In the case of a government department, a letter from the accounting

officer.

(e) In instances where it appears that a customer is acting on behalf of

another person, money remittance providers will be required to take
reasonable measures to establish the true identity of the person on whose
behalf or for whose ultimate benefit the customer may be acting in the
proposed transaction, whether as a trustee, nominee, agent or otherwise.

(f) Money remittance providers should ensure that their customers do not use
fictitious names when transacting.

(g) Money remittance providers should have adequate system in place to

enable them verify whether the customer is on the United Nations’ terror
watch list.

20. Training
(1) Directors of money remittance providers must ensure that all their employees
are trained to recognise and deal with transactions which may be related to
money laundering and ensure that they are aware of the provisions relating to
anti- money laundering under the money remittance regulations and the
Proceeds of Crime and Anti-Money Laundering Act 2009.

25
21. Suspicious Transactions
(1) Money remittance provider shall submit to the Financial Reporting Centre, a
report of any suspicious transactions or any activities which may indicate
suspected money laundering or other attempts to conceal the true identity of
customers or ownership of assets in the prescribed FORM/ CBK/MRB/3.
(2) Money remittance providers shall be guided by the examples of Suspicious
Transactions provided under the Fifth Schedule of these Regulations.

22. Tipping Off

(1) The directors and management of money remittance providers must ensure that
persons suspected of engaging in money laundering or are under investigations
are not tipped off.

PART V – CUSTOMER PROTECTION

23. Disclosure
(1) Money remittance providers shall disclose the following information in writing to
their clients:

(a) The fees, charges or commissions, if any, and other conditions applicable
to the money remittance services rendered;

(b) That money remittance provider is neither a deposit taking nor lending
institution within the meaning of the Banking Act, the Microfinance Act or
the SACCO Societies Act and is not subject to any deposit protection;
and

(c) Available customer care procedures for complaints together with the
address, customer care contact number and other contact details for the
money remittance provider.

24. Consumer redress

(1) Money remittance provider shall, within six months after commencing business
establish a customer care system to address the complaints of clients.

26
(2) Money remittance providers shall provide easily understood information about the
customer care system, including the customer care contact number, at its head
office, outlets as well as the premises of agents.

(3) Complaints may be lodged orally or in writing, but in each case must be
lodged within a period of 30 days from the date of occurrence.

(4) Money remittance providers shall acknowledge all complaints filed with them.

(5) At the time of making a complaint the complainant shall be advised of the
expected actions and timing for investigating and resolving the complaint,
provided that all complaints shall be resolved within sixty days of being lodged.

(6) Money remittance providers shall put in place processes to provide complainants
with sufficient information and the means to inquire on the progress of
complaints and such processes may include complaint reference numbers or
other identifiers in order to facilitate timely and accurate responses to
subsequent inquiries by complainants.

(7) Complainants shall be advised of the outcome of the investigation of their

complaint, and any resulting decision by the money remittance providers.

(8) Where a complainant is not satisfied with a decision reached pursuant to a

complaint, the money remittance provider shall give the complainant the option
of pursuing an identified escalation process by which the decision may be
examined by a suitably qualified person in the organization.

(9) Complaint handling processes shall be provided free of charge but a money
remittance provider may impose a reasonable charge for complaint handling
processes where investigation of the complaint requires the retrieval of records
more than three months old, and where the retrieval results in an incremental
expense or significant inconvenience to the money remittance providers. Any
such charges shall be identified and agreed to by the complainant.

(10) Money remittance providers shall make adequate provision to ensure that
people with disabilities are able to access their complaint handling processes,
including ensuring that such complainants can be easily represented by their
27
 authorised representatives in order to make a complaint. In cases where such
complainants specifically request assistance in lodging complaints, money
remittance providers shall be obliged to provide reasonable assistance.

PART VI - INSPECTIONS, SUPERVISION AND AUDITORS

25. Inspection of a Money Remittance Provider
(1) The Bank may inspect the books of accounts and other documents of a
money remittance providers at any time in its premises in order to ensure
compliance with the laws of Kenya, licensing terms and conditions, operating
instructions and guidelines, and may institute an audit of the money remittance
provider, call for an investigation of the money remittance provider, or impose
a financial penalty on the money remittance provider.

(2) The Bank may require an officer of the money remittance provider to produce
to the Bank officer making an examination, and within a reasonable time, such
books of accounts and any other documents in the, money remittance
provider’s custody or power, and furnish such statements or information relating
to the affairs of the money remittance provider as may be required by the
examining officer.

(3) The Bank may, by notice in writing, require a money remittance provider to
provide information to it, in such manner and form as may be specified by the
Bank for purposes of assessing compliance with these Regulations.

(4) The Bank may, at any time, enter any premises where a money remittance
provider is carrying on business, or any premises where it is reasonably
suspected that any business is being carried on in contravention of these
regulations.

(5) A money remittance provider which fails to produce books, accounts, records,
documents, correspondence, statements or other specified information without
any reason shall be issued with a fourteen (14) days notice to show cause
why licence to carry on a money remittance business under these regulations
should not be revoked.

28
 (6) The Bank may require a money remittance provider to put in place remedial
measures as the Bank may consider necessary after an inspection or
investigation under these Regulations.

26. Auditors
(1) Every money remittance provider shall, at its own expense, appoint an external
auditor who shall be a member of good standing of the institute of Certified
Public Accountants of Kenya to carry out an audit of the transactions in its
business.

(2) The Bank may require an auditor appointed under subsection (1) above:

(a) To submit to the Bank such information as it may require in relation to

the audit carried out by the auditor;

(b) To extend the scope of an audit of the business and affairs of the
business and to submit a report to the Bank ;

(c) To carry out any examination or establish any procedure in any particular
case;

(d) To submit a report to the Bank on any matter referred to in paragraph

(a) or (b); and

(e) The money remittance provider shall be responsible for the remuneration of
the auditor for the audit services.

PART VII - REMEDIAL MEASURES AND GENERAL PROVISIONS

27. Penalties
(1) The Bank may levy monetary penalties for failure to comply with any of these
regulations or non - compliance with any other directives of the Bank not
exceeding five hundred thousand shillings.

29
(2) The Bank, after reviewing all available information and determining the
existence of the contravention of these regulations, shall notify the money
remittance provider in writing advising on the findings and the following
enforcement actions:

(a) Issue a 14 days’ notice of the Bank’s intention to assess penalties for
non-compliance; or
(b) Give a timeframe within which to rectify the violation after assessment of
the gravity of the violation.

(3) Where a notice to asses penalties is issued under sub-section (2)(a) above
and upon expiry of the notice, or sooner if advised by the money remittance
provider of the correction of the violation, the Bank shall instruct the money
remittance provider, in writing, on the amount of monetary penalties assessed
and the manner in which such monies shall be paid to the Bank.

(4) In addition to the notification under sub-section (3) above, the money
remittance provider shall be advised on a reasonable timeframe within which
the violation shall be rectified.

(5) The following shall constitute specific violations by a money remittance provider
or a person of directions of the Bank which shall be subject to assessment of
monetary penalties-

(a) Failure by a money remittance provider to:-

(i) Comply with the Regulations, or such other guidelines or directions

as the Bank may issue from time to time;

(ii) Furnish, at such time and in such manner as the Bank, may direct
any information in an accurate and complete manner as the Bank
may require to properly discharge its functions under the Act;

(iii) Remit funds to customers.

30
 (b) Conducting business in a manner, which in the view of the Bank is
unsafe or unsound;

(c) Failure to adhere to the reporting obligations as stipulated in Sections 44

to 46 of the Proceeds of Crime and Anti-Money Laundering Act 2009;

(d) Tipping off a person suspected of money laundering that a disclosure has
been made or otherwise prejudice an investigation.

28. Suspension and Revocation

(1) The Bank may suspend the licence of a money remittance provider for such
period as it may specify if the money remittance provider fails to comply with
the provisions of these regulations or any conditions attached to the licence.

(2) The Bank may revoke licence of a money remittance provider in cases where:

(a) without the written consent of the Bank , the money remittance provider
fails to conduct money remittance business within twelve (12) months of
the date of the issue of the licence;
(b) the money remittance provider is found to have ceased to conduct the
operations authorized by the licence;

(c) owing to the bankruptcy of the director(s), a company is incapable of

existing in law or of carrying on its operations or of meeting capital
requirements or fulfilling any other provisions of these regulations;

(d) the money remittance provider fails to pay the required licence fees by
the stipulated date;

(e) the beneficial owners of the money remittance provider, or the money
remittance provider itself, is convicted by any court of competent
jurisdiction, in Kenya or elsewhere, of an offense related to the use or
laundering, in any manner, of illegal proceeds, or is an affiliate or

31
 subsidiary of a company that has been so convicted, and such conviction
is not overturned on appeal;

(f) the money remittance provider has supplied the Bank with false or
misleading information as part of its application for a licence, or during
the course of operation.

(g) the money remittance provider is undercapitalized;

(h) the money remittance provider fails to pay a penalty as directed by the
Bank within fourteen (14) days;

(i) the money remittance provider fails to rectify violations within the specified
time frame or persistently being non-compliant with regulations.

(j) the money remittance provider submits in writing a request for the
revocation of its licence.

(k) Where the Bank intends to revoke or suspend the licence of a money
remittance provider, the Bank shall immediately inform the money
remittance provider of its decision in writing.

(3) Before revoking or suspending licence, the Bank shall give the money
remittance provider not less than fourteen (14) days notice in writing and may
consider any representations made in writing by the money remittance provider
within that period.

29. GENERAL PROVISIONS

(1) All foreign exchange transactions shall be subject to the requirements stipulated
in the Guidelines on Foreign Exchange issued under the Central Bank of
Kenya Act.

PART VIII - EFFECTIVE DATE

Effective Date: To Be Advised.
ENQUIRIES
32
Enquiries on any aspects of this guideline should be referred to:-
The Director,
Bank Supervision Department,
Central Bank of Kenya,
P.O. Box 60000-00200
NAIROBI
TEL: 2860000
email: [email protected]

SCHEDULES

FIRST SCHEDULE

APPLICATION FOR OR RENEWAL OF LICENCE TO TRANSACT MONEY REMITTANCE

BUSINESS - FORM / CBK /MRB/1

Application (Tick as appropriate):

Grant of new Licence Renewal of Licence Year

Please use Block (Capitals) Letters

1. Name of Money Remittance Provider…………………………………………………………....
2. Physical and postal address of head office/ proposed new outlet:
(a) City/Town…………………………….........................................................
(b) L.R.No….....................................................................................
(c) Street….………………….....................................................................
(d) Building…………………………………….........................................................
(e) P.O Box No..………………………...........………………….…………….................
(f) Telephone Numbers.………………………………………..…………………………………...
(g) E-mail Address…………………………………………..……………………….………….....
3. Date of incorporation …………....…..........................................................
4. Certificate of incorporation No…………….……………………………………..................
5. Number and date of issue of previous licence ……………………….…………………….
6. Details of existing outlets:
33
 Name of County City/Town Street Building Date
outlet opened
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

7. Particulars of shareholders:

Name Nationality Date of Amount of % of

acquisition shareholding shareholding
1.
2.
3.
4.
5.
6.
7.

8. Particulars of directors:

Name Nationality Date of Level of

appointment education
1.
2.
3.
4.
34
 5.
6.
7.

9. Particulars of the officers in the order of seniority:

Name Designation Nationality Date of

appointment
1.
2.
3.
4.
5.
6.
7.

10. Declaration (by Director/Secretary):

I, the undersigned, hereby declare:-

(a) THAT the particulars set out herein are true and correct to the best of my
knowledge and belief;
(b) THAT if licensed, I shall transact money remittance business in accordance
with the provisions of the Central Bank of Kenya Act, CAP 491 and of any
regulations, guidelines or directive as may from time to time be issued by the
Central Bank of Kenya.

Name……………………………...............................
Signature……………….......................................…...
Date………………………………….........................

SECOND SCHEDULE

35
SHAREHOLDERS’, DIRECTORS’ AND SENIOR OFFICERS’ FIT & PROPER FORM –
FORM/CBK/MRB/2

Criteria for determining Professional and Moral suitability of persons in Control of a Money
Remittance Business licensed under the Central Bank of Kenya Act, CAP 491

NB:
(a) Read the declaration on Section 6 below before completing this form.
(b) In case the space provided is inadequate, use additional paper.

1. NAME OF MONEY REMITTANCE PROVIDER………………………………………………..

2. PERSONAL INFORMATION
a) Surname:
...............................................................................................................
Other Names: .........................................................................................
b) Proposed position: …………………….………………………………………………………………

c) Previous Names (if any) by which you have been Known:

…………………………………………………………………………………………………………………..

d) Year and Place of birth:

..............................................................................................................
e) Nationality and how acquired:
..............................................................................................................
f) Personal Identification Number:
..............................................................................................................
g) Identification Card number and date of issue:
..............................................................................................................
h) Passport number and date of issue: …………………………………………………………
i) Postal Address: ………………………………………………………...............................

j) Previous Postal Addresses (if any):

.............................................................................................................
k) Physical address: ................................................................................
36
I) Email Address:.....................................................................................
m) Telephone number:
a) Office..............................................................................................
b) Mobile.............................................................................................
n) Educational qualifications:........................................................................
o) Professional qualifications and years obtained: ...........................................

p) Name(s) of your bankers during the last 5 years:

……………………………………………………………................................................

3. EMPLOYMENT/BUSINESS RECORD
Period Name of Positions held Responsibilities Reasons for
Employer/Business and dates leaving
and address (where
applicable)

4. DESCRIPTION OF YOUR PAST AND CURRENT ACTIVITIES IN KENYA AND

ABROAD

4.1 SHAREHOLDING (DIRECTLY OWNED OR THROUGH NOMINESS)

Company’s Date of Amount of % of Past Remarks
Name incorporation shareholding shareholding shareholding
A B

37
A: Refers to date of sell, transfer, closure or surrender of shares
B: Refers to reasons for sell, transfer, closure or surrender

4.2 DIRECTORSHIP
Company’s Date of Executive or Position held in Past Remarks
Name appointment Non-Executive case of Directorships
Executive
C D

C: Refers to date of retirement, resignation or dismissal

D: Refers to reasons for retirement, resignation or dismissal

4.3 PROFESSIONAL BODIES

Name of Membership Position held Past membership Remarks
body No. (if any)
E F

38
E: Refers to date of retirement, resignation or dismissal
F: Refers to reasons for retirement, resignation or dismissal

4.4 SOCIAL CLUBS

Name of Membership Position held Past club membership Remarks
club No. (if any)
G H

G: Refers to date of retirement, resignation or dismissal

H: Refers to reasons for retirement, resignation or dismissal

4.5 BORROWINGS
Name Name of Type Amount Date Terms Security Value Current Remarks
of lending of borrowed of of offered of outstanding
borrower institution facility offer offer security balance

*Borrower to indicate both individually and the company where he holds more than
5% of the shareholding

39
5. QUESTIONNAIRE
5.1 Have you or any entity with which you are associated as director, shareholder or
manager, ever held or applied for a licence or equivalent authorization to carry on any
business activity in any country? If so, give particulars. If any such application was
rejected or withdrawn after it was made or any licence revoked, give particulars.
………………………………………...........................................................................
………………………………………...........................................................................
5.2 Have you at any time been convicted of any criminal offence in any jurisdiction?
If so, give particulars of the court in which you were convicted, the offence, the
penalty imposed and the date of conviction.
………………………………………..........................................................................
………………………………………...........................................................................
5.3 Have you, or any entity with which you have been involved, been censured,
disciplined, warned as to future conduct, or publicly criticized by any regulatory
authority or any professional body in any country? If so, give particulars.
………………………………………............................................................................
………………………………………............................................................................
5.4 Have you, or has any entity with which you are, or have been associated as a
director, shareholder or manager, been the subject of an investigation, in any country,
by a government department or agency, professional association or other regulatory
body? If so, give particulars.
………………………………………...........................................................................
………………………………………...........................................................................
.5 Have you, in any country, ever been dismissed from any office or employment,
been subject to disciplinary proceedings by your employer or barred from entry of any
profession or occupation? If so, give particulars.
……………………………………….......................................................................
……………………………………….......................................................................
5.6 Have you failed to satisfy debt adjudged due and payable by you on order of
court, in any country, or have you made any compromise arrangement with your
creditors within the last 10 years? If so, give particulars.
……………………………………............................................................................
………………………………………..........................................................................

40
5.7 Have you ever been declared bankrupt by a court in any country or has a
bankruptcy petition ever been served on you? If so, give particulars.
………………………………………......................................................................
……………………………………….........................................................................
5.8 Have you ever been held liable by a court, in any country, for any fraud or
other misconduct? If so, give particulars.
………………………………………........................................................................
………………………………………........................................................................
5.9 Has any entity with which you were associated as a director, shareholder or
manager in any country made any compromise or arrangement with its creditors, been
wound up or otherwise ceased business either while you were associated with it or
within one year after you ceased to be associated with it? If so, give particulars.
………………………………………............................................................................
....………………………………………..................................................................
5.10 Are you presently, or do you, other than in a professional capacity, expect to
be engaged in any litigation in any country? If so, give particulars.
……………………………………….........................................................................
……………………………………….........................................................................
5.11 Indicate the names, addresses, telephone numbers and positions of three
individuals of good standing who would be able to provide a reference on your
personal and professional integrity. The referees must not be related to you, and
should have known you for at least five years.
……………………………………….........................................................................
………………………………………..........................................................................
5.12 Is there any additional information which you consider relevant for the
consideration of your suitability or otherwise for the position(s) held/to he held? The
omission of material facts may represent the provision of misleading information.
……………………………………….........................................................................
……………………………………….........................................................................

N.B. The information given in response to this questionnaire shall be kept confidential
by the supervisory authorities, except in cases provided for by law.
6. DECLARATION
I am aware that it is an offence to knowingly or recklessly provide any information,
which is false or misleading in connection with an application for a licence.
41
I am also aware that omitting material information intentionally or un-intentionally shall
be construed to be an offence and may lead to rejection of my application.

I certify that the information given above is complete and accurate to the best of my
knowledge and that there are no other facts relevant to this application of which the
supervisory authority should be aware.

I undertake to inform the supervisory authority of any changes material to the

applications which arise while the application is under consideration.

NAME ........………................................ POSITION

HELD.....................................
DATED........……......….AT......…….......THIS DAY OF........………….................

WITNESSED BEFORE ME:

SIGNED........…………............................................ (Applicant)
COMMISSIONER FOR OATHS/MAGISTRATE
Name: …............................................................................................
Signature: ..........................................................................................
Address: ........………….....................................................................

THIRD SCHEDULE
SUSPICIOUS TRANSACTION REPORT - FORM / CBK /MRB/3

Suspicious Activities or Transactions Report (SATR)

To be submitted to: Director, Financial Reporting Centre

Always complete the entire report, attach additional pages if necessary to explain
situation fully,
42
1. Tick appropriate box

a. Initial Report  b. Correct Report  c. Supplemental Report 

Part I: Information About Money remittance Provider Submitting This Report

2. Name of money remittance provider: …………………………………………………………

3. Address of Head Office……………………………………………………………………….……

4. Address of outlet(s) where activity/transaction occurred………………….……………

Part II: Information about Person or Entity Engaging In Suspicious Activity or

Transaction
5. Surname (or Name of Entity)………………………………………………….………………

6. First Name………………………………………………………………………..…………

7. Middle/Name……………………………………………………………………………….
8. Address………………………………………………………………………………………
9. Occupation ……………………………………………………………………….……….

10. Identity verified by: (Tick appropriate box)

a. Passport No………………………. Date and Place of issue……………………..…

b. National ID Card No.............. Date and Place of issue…………………..…

c. Other ……………………………Serial No…………….……………………………………

Date and Place of issue…………………………………………………………………..…

11. Is suspect affiliated with the money remittance provider? a. Yes b. No  If no,
specify
43
 c. Resigned d. Suspended e. Terminated

12. Date of Resignation, Suspension, Termination (DDMMYY)

............../………....../.......

13. Admission/Confession: a. Yes b. No. 

PART III: Information about Suspicious Activity or Transaction

14. Date of suspicious activity or transaction (DDMMYY)………..

........./................./......

15. Transaction Number………………………………………………………………

16. Amount involved (Kshs. equivalent)

............................................................................

17. General description of suspicion transaction:

……………………………………………………………………………………

………………..………………………………………………………………………
(Attach copies of documentation if available)

18. Has suspicious activity or transaction had material impact on or otherwise

adversely affected the financial soundness of the money remittance provider? a.
Yes b. No
If yes, describe impact:

…………………………………………………………………………………….

…………………………………………………………………………………….

44
 ……………………………………………………………………………………

19. Has the insurer of the money remittance provider been notified a. Yes  b.  No.
If yes, when & how?
20. Has any law enforcement authority been notified in any manner? If so, indicate
the following:

a.
Authority.............................................................................................
............

b. Specific person notified: …………………………………………………………

c. Date and place of notification……………………………………………………

d. How notified
................................……………………………...………………

e. Details provided:
............................................................................................
PART IV: Information about Officer Making the Report

21. Name:
..................................................................................................................
...

22. Position/Title in the MRT

……………..............................................................

23. Signature ................................................

Date...............................................

45
FOURTH SCHEDULE
APPLICATION TO OPEN AN OUTLET TO FORM / CBK /MRB /4

The Central Bank f Kenya Act, CAP 491

1. Name of the Money remittance provider……………………………...........................

2. Names/locations of existing outlets and dates of establishment…………………………..
3. Proposed name of outlet……………………………………………………………………………..
4.a) Name of the proposed location of outlet …………………............................
b) Postal address and telephone number(s) ………………………………............
c) Physical address: - L.R.NO...................Building……...……..Street…………..

Town..................................................................................................
5. a) Officers of the proposed outlet………………………………………………………
b) Number and designation of non-management staff…………………………………..
6. Business hours …………………………………………..........................................……
7. Is the new place of business:-
a) Self-owned? ……………Yes/No* …………
If yes, cost of purchase or construction……………b) Leased? ………………… Yes/No*
………… If yes, terms of lease……………………….
8. Proposed date of commencing operations
…………………………..................................
9. Declaration (by Director/Secretary):
I, the undersigned, hereby declare:-
a) THAT the particulars set out herein are true and correct to the best of my
knowledge and belief;
b) THAT if licensed, I shall transact money remittance business in accordance with
the provisions of the Central Bank of Kenya Act and of any regulations, guidelines
or directive as may from time to time be issued by the Central Bank of Kenya.

Name……………………………...............................
Signature……………….......................................…...
Date………………………………….........................

46
FIFTH SCHEDULE
EXAMPLES OF TRANSACTIONS THAT MAY TRIGGER SUSPICION
i. Customer is evasive or unwilling to provide information when requested,
especially a customer who is sending or receiving an amount equivalent to
US$10,000 and above.
ii. Transactions conducted are out of character with the usual conduct or profile of
customers carrying out such transactions.
iv. Customer using different identifications each time conducting a transaction.
v. A group of customers trying to break up a large cash transaction into multiple
small transactions.
vii. The same customer conducting a few small transactions in a day or at different
outlets/locations.
viii. There are sudden or inconsistent changes in remittance sent/received
transactions.
ix. Remittances from different customers/jurisdiction being sent to the same
customer.
x. Customer frequently remitting money to non-cooperative countries/jurisdictions.
xi. Customer frequently exchanging large amount of foreign currency but not
exceeding the equivalent of US$10,000 for each transaction.

47