Kenya has sought to apply this according to international best practices. As mentioned, Kenya’s AML/CFT framework is aligned to international best parctices and it is embedded in several complementary elements. 4  Cash monitoring is essential, as criminals performing illicit activities prefer using cash. 5   Majority of suspicious transactions are triggered by unusually large cash transactions.
 CBK Circular No 1 of 2016 reminded banks of the requirements under POCAMLA on large cash transactions e.g. to determine the legitimacy of funds. The Circular was informed by:  Findings from target inspections had revealed that corruption proceeds had been transacted through large cash transactions.  Failure by institutions to obtain information to determine legitimacy of customer transactions.