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Kenya: President Signs the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act 2023

Kenya: President Signs the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act 2023

In a significant move to enhance financial security and combat illicit activities, the President of Kenya officially signed into law the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act 2023 on September 1, 2023. This Amendment Act underscores Kenya’s commitment to strengthening its financial regulatory framework, fostering international cooperation, and aligning with global standards in the fight against money laundering, terrorism financing, and related illicit financial activities.

Prior to the enactment of the Amendment Act, the Law Society of Kenya (LSK) sought a court repeal of amendments compelling lawyers to disclose suspicious financial deals involving their clients. Consequently, the LSK agreed with the State to be designated as a self-regulating body in line with the Financial Action Task Force (FATF) standards, protecting client-attorney privileges.

Key Highlights of the Amendment Act

Beneficial Ownership

Limited Liability Partnership Act, 2011 (No. 42 of 2011):

  • Definition: The Amendment Act defines a Beneficial Owner as “the natural person who ultimately owns or controls a legal person or arrangement or the natural person on whose behalf a transaction is conducted, including those who exercise ultimate effective control over a legal person or arrangement.”
  • Register Requirements: Section 31B requires every limited liability partnership (LLP) to maintain a register of its beneficial owners and lodge a copy with the Registrar, both for proposed LLPs and existing LLPs within 60 days of the section coming into force.
  • Update and Record Maintenance: LLPs must update the Registrar with any amendments to the register within 14 days and keep records for at least 10 years.
  • Penalties: Penalties range from KES 100 for each day of default to a maximum of KES 500,000. The Registrar may also issue directives for compliance.

Foreign Limited Liability Partnership:

Section 34B(1)(b)(iv) mandates that applicants for foreign LLP registration submit a notarized copy of a list of beneficial owners and their particulars, along with other requirements.

Companies Act, 2015 (No. 17 of 2015):

  • Register Requirements: Section 16A requires applicants for company registration to ensure compliance with beneficial ownership particulars. Section 93A mandates every company to maintain a register of its beneficial owners and lodge a copy with the Registrar, both for proposed and existing companies within specified time frames.
  • Update and Record Maintenance: Companies must update the Registrar with any amendments within 14 days (30 days for public listed companies) and keep records for at least 10 years.
  • Penalties: Similar to LLPs, penalties range from KES 100 per day of default to a maximum of KES 500,000, with additional directives for compliance.

Additional Highlights of the Amendment Act

  1. Consensual Extradition: Fugitive criminals can now consent to extradition without formal proceedings, facilitated through Mutual Legal Assistance, streamlining international cooperation in combating cross-border crimes, including terrorism.
  2. Enhanced Regulatory Authority: The Capital Markets Authority (CMA) and Insurance Regulatory Authority (IRA) have expanded powers to ensure licensee compliance with anti-money laundering and terrorism financing laws.
  3. Operational Independence for the Financial Reporting Centre (FRC): The FRC gains operational independence, exempting it from the definition of a State Corporation, to strengthen its capacity to combat money laundering.
  4. Strengthened Reporting Obligations: Reporting entities must promptly report suspicious transactions to the FRC, which will analyze these reports and coordinate with law enforcement agencies for appropriate action.
  5. Central Bank Supervision: The Central Bank of Kenya (CBK) will oversee financial institutions and agents of reporting institutions to ensure compliance with anti-money laundering regulations.
  6. Expanded Scope and Coverage: The Act broadens the definition of money laundering offenses to include proceeds from domestic and international criminal activities, terrorism financing, and corruption, addressing emerging threats in digital and cryptocurrency spaces.
  7. Increased Penalties and Deterrents: The amendments introduce more severe penalties, including higher fines and extended prison terms, to deter illicit financial activities.
  8. Enhanced Customer Due Diligence: Financial institutions and designated non-financial businesses must conduct thorough customer due diligence according to Know Your Customer (KYC) standards, promoting transparency.
  9. Harmonization with FATF Standards: The legislation aligns Kenya’s licensing regime with FATF standards, establishing global standards to combat money laundering, terrorism financing, and financing of weapons of mass destruction.

Conclusion

We hope this information is helpful in understanding the key benefits of the Anti-Money Laundering and Combating of Terrorism Financing Laws (Amendment) Act 2023. Please note that this newsletter provides a general guide and should not be relied upon without legal advice.

For further information or legal assistance on compliance or any other legal issue, contact us at info@wka.co.ke, visit wakilihub.co.ke/, or call +254 798 03 580. Our Nairobi Hub is located at Parklands, Valley View Business Park, 6th Floor, City Park Drive, Off Limuru Road.

Authors:

  • William Karoki, Founding Partner
  • Florence Mwende, Lawyer
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Kenya Cabinet Approves Splitting of NHIF (National Health Insurance Fund)

Kenya Cabinet Approves Splitting of NHIF (National Health Insurance Fund)

In honor of the President’s pledge to accelerate Kenya’s attainment of Universal Health Coverage (UHC), the Cabinet has considered and approved four crucial bills that promote healthcare, to be transmitted to Parliament. These are:

  1. The Primary HealthCare Bill, 2023
  2. The Digital Health Bill, 2023
  3. The Facility Improvement Financing Bill, 2023
  4. The Social Health Insurance Bill, 2023

These four bills usher in a new paradigm in the legal and institutional framework for healthcare in Kenya by repealing the current NHIF and establishing the following three funds in its place:

  • Primary Healthcare Fund
  • Social Health Insurance Fund
  • Emergency, Chronic, and Critical Illness Fund

The NHIF has experienced a steady decline in fulfilling its mandate in recent years. The Kenya Association of Private Hospitals (KAPH) had even banned the use of the NHIF card due to nonpayment by the insurer. This situation left many Kenyans in distress because the NHIF is the most popular health insurance in the country and is relied upon by the majority. Patients have had to pay in cash or go untreated. While public hospitals still accept the NHIF card as a mode of payment, the insurer only covers limited services, prompting patients to seek assistance from private hospitals. The Cabinet’s decision to repeal the current NHIF is a significant relief for Kenyans.

We will be updating the public on the provisions of these bills as they are published. We hope this information helps in understanding the current developments regarding the repeal of the National Health Insurance Fund and the establishment of the Primary Healthcare Fund, Social Health Insurance Fund, and Emergency, Chronic, and Critical Illness Fund.

Please note that the contents of this newsletter are intended to provide a general guide to the subject matter. It should not be relied upon without legal advice on its contents.

For further information or legal assistance on compliance or any other legal issue, please contact us at info@wka.co.ke, wakilihub.co.ke/, +254 798 03 580, Nairobi Hub: Parklands, Valley View Business Park, 6th Floor, City Park Drive, Off Limuru Road.

Authors:

  • Founding Partner: William Karoki
  • Lawyer: Florence Mwende
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A NEW DAWN FOR FOREIGN INVESTORS IN THE ICT SECTOR IN KENYA

A NEW DAWN FOR FOREIGN INVESTORS IN THE ICT SECTOR IN KENYA

The Information and Communications Technology (ICT) Sector Policy Guidelines 2020 in Kenya introduced a requirement for foreign firms licensed to provide telecommunications services to have at least 30% of their shares held by locals within a three-year grace period.

The rationale behind the 30% local shareholding requirement was to ensure national security, attract foreign investment, and create employment for Kenyans. The policy aimed to equip Kenyans with sufficient knowledge to help local ICT firms flourish. However, it did not achieve its mandate as the number of foreign investors in the ICT sector declined significantly. Foreign companies found the policy prohibitive and were reluctant to find local partners, making it harder for existing startups to increase their stake beyond the 30% equity threshold.

Consequently, President William Ruto proposed the removal of the mandatory local shareholding requirement as part of the fiscal policy changes expected in the Finance Bill 2023 and the Budget Policy Statement. This proposal was made during the American Chamber of Commerce (AmCHAM) Summit held on March 29th and 30th, 2023, in Nairobi. In a Cabinet dispatch dated July 18th, 2023, the Kenyan Cabinet approved the President’s proposal. The dispatch stated that the rationale for scrapping the 30% requirement is “part of the reforms to enhance Kenya’s overall ease of doing business index while also fortifying legislative consistency in the governance framework for foreign investments. The policy shift is geared towards facilitating technology and knowledge transfer as well as aiding the expansion of the digital economy by positioning the country for increased foreign investments in technology as envisioned in the Administration’s Bottom-Up Economic Transformation Agenda (BETA).”

Following Kenya’s Cabinet approval of abolishing the mandatory local shareholding requirement in the ICT sector, Elon Musk launched his satellite Internet firm, Starlink, in Kenya on July 19th, 2023. Starlink partnered with a local internet company, Karibu Connect, as its first authorized distributor in Kenya. The launch made Kenya the sixth African country to be explored for business by Starlink after Nigeria, Mozambique, Mauritius, Rwanda, and Comoros. Shortly after the launch of Starlink, United States (US) Ambassador Meg Whitman attended the 8th Devolution Conference in Eldoret. In her address, she strongly pitched Kenya as Africa’s best investment destination for the international community. The envoy did not hide her enthusiasm about Kenya’s investment prospects and climate, describing the country as the region’s ICT Hub and gateway to East Africa.

Local Shareholding Requirements in Other Sectors:

  • Engineering: The Engineering Technology Act No. 23 of 2016 requires a foreign firm to be incorporated in Kenya and have a minimum local shareholding of 51% to be registered as an engineering consulting firm.
  • Aviation: Regulations 5 and 12 of the Civil Aviation (Licensing) require a prospective licensee to be a Kenyan citizen or, if a body corporate or a partnership, to have at least 51% of its voting rights held by the Kenyan government, a Kenyan citizen, or both.
  • Private Security: The Private Security Regulation Act, 2016 mandates a prospective license holder to have a minimum of 25% local shareholding.
  • Pension Funds/Schemes: The Retirement Benefits Act, 1997 requires at least 60% of the paid-up share capital of a scheme administrator to be held by Kenyan citizens unless the administrator is a bank or an insurance company.
  • Shipping: The Merchant Shipping (Maritime Service Providers) Regulations, 2011 require an applicant for a license to be a Kenyan citizen or, if a body corporate, to have at least 51% of its share capital held by Kenyan citizens.
  • Insurance: The Insurance Act (CAP 487) stipulates that not less than one-third of the paid-up share capital of an insurance company must be owned by citizens of the states forming the East African Community or wholly owned by the Kenyan government.
  • Mining: Under the previous Mining Act, a mining license applicant needed 35% local shareholding for a mineral right. The 2016 Mining Act allows the Cabinet Secretary to set capital expenditure limits. If a licensee’s planned spending surpasses this limit, they must list 20% of equity on a local stock exchange within three years of production start. Small-scale operations tied to mineral rights are limited to Kenyan citizens or bodies corporate with 60% local shareholding.
  • Capital Markets: The Capital Markets (Foreign Investors) Regulations require every legal entity that offers securities to the public or a listed company to reserve at least 25% of its ordinary shares for investment by Kenyan citizens.
  • Financial Institutions: The Banking Act (CAP 488) also imposes specific local shareholding requirements.

We hope this information is helpful in understanding the 30% local shareholding requirement in the ICT sector and the effects of its abolishment in Kenya. Please note that the contents of this newsletter are intended to provide a general guide to the subject matter and should not be relied upon without legal advice on its contents.

For further information or legal assistance on compliance or any other legal issue, please contact us at info@wka.co.ke, wakilihub.co.ke/, +254 798 03 580, Nairobi Hub: Parklands, Valley View Business Park, 6th Floor, City Park Drive, Off Limuru Road.

Authors:

  • Founding Partner: William Karoki
  • Lawyer: Florence Mwende
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Dispute Resolution Services Kenya

Dispute Resolution Services Kenya

We handle diverse commercial litigation Kenya and alternative dispute resolution Kenya matters, specializing in debt recovery services Kenya, security enforcement legal services, regulatory compliance disputes, employment law disputes Kenya, employee benefits litigation, public procurement disputes, intellectual property disputes Kenya, election petitions Kenya, constitutional petitions Kenya, judicial review Kenya, competition law disputes, construction disputes resolution, civil and criminal litigation Kenya before tribunals such as the Political Parties Tribunal cases, Environment Appeal Tribunal representation, Cooperative Tribunal legal services, Public Procurement Administrative Review Board, and other tribunals, as well as the Magistrate’s Courts litigation, High Court litigation Kenya, Court of Appeal representation, and Supreme Court cases Kenya.

Global Arbitration Services

We are adept at concluding global arbitration services, swiftly mobilizing teams to manage major disputes and regularly working across our extensive network. Our experience in arbitration spans all sectors of the economy. In line with the growing need for mediation of commercial disputes, we have developed a niche practice and have successfully mediated several disputes in the construction industry mediation, manufacturing sector dispute resolution, and ICT industry dispute mediation.

Litigation Management Services

We provide litigation management services, including keeping a record of all litigation, providing regular updates, follow-ups, and representation in courts and tribunals.

Employment Matters

Our firm offers representation and advice on employment claims representation and employment matters, handling claims arising from employment-related issues.

Civil Litigation Advice Kenya

We offer representation and advice for civil litigation advice Kenya, addressing a wide range of civil matters.

Commercial Litigation Kenya

We handle commercial litigation Kenya, including representation and advice arising from contract disputes Kenya and insurance claims litigation.

Criminal Case Representation Kenya

Our firm provides representation and advice in relation to criminal cases Kenya through effective handling of criminal matters.

Debt Recovery Services

We offer debt recovery services, including drafting and serving demand letters upon defaulters and pursuing debtors through Acknowledgment of Debt agreements and settlement agreements preparation. We charge a collection fee of 10% to 30% of the amount collected, depending on the complexity and duration of the recovery process. This fee is exclusive of court filing fees if the matter is referred to a court process.

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Corporate and Commercial Law  kenya

Corporate and Commercial Law

Our Corporate and Commercial Law department provides clients with comprehensive, up-to-date advice on both local and international laws and practices, covering all aspects of corporate and commercial law.

We offer guidance on company formation, optimal setup options for international investors looking to invest in Kenya, corporate restructuring, regulatory and licensing requirements, compliance, drafting standard form documentation, completing regulatory questionnaires, and preparing bank security documents such as debentures, mortgages, charges, and registrations. With our expertise in product development, we have also advised on innovative product structures for Kenya’s financial services intermediaries.

Banking & Finance

We specialize in negotiating, preparing, and reviewing loan facility agreements, including the preparation of affidavits, ensuring that our clients’ financial transactions are legally sound and effectively structured.

Mergers and Acquisitions

Our extensive experience in mergers and acquisitions allows us to execute cross-border deals seamlessly, supporting clients through all stages of the transaction and providing cost-effective, pragmatic business solutions.

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ESG & REGULATORY COMPLIANCE

ESG & REGULATORY COMPLIANCE

Regulated public and corporate entities in Kenya are required to conduct their business affairs full compliance with the Constitution, all applicable sector legislation, regulations and processes. The ramifications of non-compliance are far reaching both for the institutions and officers involved.

The firm has built strategic capacity in this area to assist both public sector clients as well as private sector players that have engagements with public bodies. The practice area is one of the fastest growing components of the firm’s practice and is overseen by a highly experienced team of lawyers with expertise in various aspects of public sector administration including policy formulation, different categories of compliance audits as well as legislative drafting.

Building on the unique advantage that the firm enjoys as one of the few firms with an elaborate offering in the area, the team continues to add to the firm’s market leadership status. The categories of clients that frequently engage the firm in relation to this practice area include State Corporations, National Government Ministries, County Governments and Assemblies, investors and public listed companies.

Legal, Environmental, Social, and Governance (ESG) & Regulatory Compliance

We guide  companies to prepare for a decarbonized and carbon neutral future by assessing their current Environmental, Social, and Governance (ESG) impacts, creating Science-Based Targets, and engaging effectively with key stakeholders.

Our lawyers advise clients across all sectors on ESG risks and compliance measures, helping businesses manage their risks more effectively while becoming more competitive in the market. We have extensive knowledge of sustainable performance-related laws and regulations, standards and initiatives and are able to advise clients on fulfilling their corporate ESG commitments.

We also conduct:

a) Training & Sensitization Seminars

We train the management on corporate governance practices, and publicize legislative and regulatory changes an affecting the industry.

b) Developing and Monitoring Compliance with Policies

We assist corporates, NGOs and public bodies to develop policies and monitor compliance with the procedure and policies (i.e. the employment handbook, sexual harassment policy, the disciplinary policy etc.)

We further assist in developing, maintaining and regularly update RISK MANAGEMENT Policies and procedures through LEGAL AUDITS for all functionalities such as procurement and review the SOPs (Standard Operating Procedures).

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Real Estate Law in Kenya

Real Estate Law in Kenya: Real Estate, Conveyancing & Construction

At WKA Advocates, we specialize in real estate law in Kenya, offering services that include negotiating, preparing, reviewing, and stamping Sale, Lease & Tenancy Agreements, Joint Venture Agreements, and JBCC & FIDIC Building Contracts.

In Kenya, the process of buying and selling land is fraught with risks. Without proper due diligence, buyers risk acquiring property with multiple title allocations or a chain of ownership tainted by fraud or illegality.

WKA Advocates has in-depth knowledge of Kenya’s land laws, providing practical guidance throughout the entire process. We understand that even minor errors or misjudgments can lead to significant losses or deal breakdowns. Therefore, we ensure our clients enter transactions fully aware of all potential outcomes.

We also cater to a robust clientele in the Diaspora, assisting them in locating properties, making investments, and conducting thorough due diligence. From negotiating the letter of offer to handing over the keys at completion, we guide clients through every step of their property transactions.

In our experience, the biggest challenges in Kenya’s real estate industry today are the lack of integrity and widespread misinformation. At WKA, we bridge this gap by continuously educating our clients on the law and recent developments. For example, as of December 2021, purchasers of apartments now receive a Sectional Title Deed instead of a Long Term Lease, thanks to the Sectional Properties Act No. 21 of 2020. This change makes owning an apartment akin to owning land, with a Title Deed that can be used as collateral for loans.

Our expertise extends to high net worth real estate developments in Kenya, including notable projects like Tatu City, Purple Haze, Siaya Park, and Diamond Homes.

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Leading Intellectual Property Law Firm in Kenya

Leading Intellectual Property Law Firm in Kenya

WKA Advocates is a premier intellectual property law firm in Kenya. Our team of specialized intellectual property and franchising lawyers works closely with clients to develop, protect, promote, and enforce their intellectual property rights.

What is Intellectual Property?

According to the World Intellectual Property Organization (WIPO), Intellectual Property (IP) refers to creations of the mind, such as inventions used in commerce. The key difference between innovation and invention is that innovation involves translating an idea or invention into a product or service that provides value or that customers are willing to pay for. An invention, on the other hand, is a new scientific or technical idea and the means of its embodiment.

Kenya’s Intellectual Property Landscape

In 2020, the Government of Kenya introduced the Intellectual Property Bill, which aimed to strengthen policy control around IP enforcement. This bill merged three key IP-related agencies—the Kenya Copyright Board (KECOBO), Kenya Industrial Property Institute (KIPI), and the Anti-Counterfeiting Agency (ACA)—to establish a unified Intellectual Property Office of Kenya (IPOK).

Article 40(5) of the Constitution of Kenya, 2010, mandates the government to support, promote, and protect the intellectual property rights of its citizens. Kenya’s legislative framework is designed to safeguard the ownership of intellectual property, fully complying with international standards as outlined by the Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS).

Key Government Agencies in Intellectual Property Rights

Several government agencies play critical roles in protecting intellectual property rights in Kenya:

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Conveyancing and Real Estate

Conveyancing Law and Practice in Kenya

With years of experience in land law and property transactions across Kenya and the broader Eastern Africa region, our firm is well-equipped to handle all aspects of property law. Our expertise covers land and property acquisition, management, and disposal, ensuring our clients receive strategic and practical advice tailored to their specific needs.

Expertise in Conveyancing & Real Estate in Kenya

Our Conveyancing & Real Estate practice group has extensive experience in advising both local and international clients on various property-related matters. We specialize in:

  • Land Acquisition and Disposal: Providing expert guidance on acquiring and selling land in Kenya.
  • Conveyancing: Handling the entire conveyancing process, including drafting conveyancing documents and managing the legal transfer of property.
  • Commercial & Residential Development: Advising on development projects, including project financing and joint ventures.
  • Leases and Licenses: Structuring and drafting lease agreements for both commercial and residential properties.
  • Project Financing: Offering solutions for financing real estate projects, ensuring compliance with legal requirements.

Understanding the Conveyancing Process in Kenya

Navigating the conveyancing process in Kenya requires careful attention to detail. We assist clients with:

  • Conveyancing Documents: Drafting and reviewing all necessary documents to ensure a smooth transaction.
  • Completion Documents: Ensuring that all required documents are completed and properly executed.
  • Off-Plan Conveyancing: Managing transactions for properties that are yet to be fully developed, ensuring that clients’ interests are protected.

Avoiding Pitfalls in Land and Property Transactions in Kenya

Our guide helps you avoid common mistakes when buying land or property in Kenya:

Don’ts:

  • Avoid Sending Money Directly to the Seller: Always route payments through your advocate to ensure a proper money trail.
  • Don’t Bypass Legal Advice: Involve a qualified advocate in all transactions to avoid legal pitfalls.
  • Don’t Rely Solely on Adverts: Conduct thorough due diligence, including background checks on sellers.

Do’s:

  • Conduct a Site Visit: Verify the land’s condition with a physical visit or through your power of attorney.
  • Engage a Surveyor: Have a qualified surveyor mark the land boundaries.
  • Keep Written Records: Document all agreements and conversations in writing for future reference.
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President Uhuru Kenyatta Signs the Military Veterans Bill into Law

President Uhuru Kenyatta Signs the Military Veterans Bill into Law

On June 15, 2022, President Uhuru Kenyatta signed into law the Military Veterans Bill, 2022 (Military Veterans Act, 2022). This legislation comes at a critical time when the world is grappling with a global mental health crisis. Many retired servicemen have reported suffering from physical and mental trauma, including post-traumatic stress disorder (PTSD), due to the challenging conditions faced during their service. Concerns have been raised over the lack of a comprehensive legal framework to address the special needs of these veterans after retirement. The most publicized mental health challenges facing veteran service members are PTSD and depression. Research suggests that approximately 14% to 16% of U.S. service members deployed to Afghanistan and Iraq have PTSD or depression, and the situation is similar in Kenya.

Key Features of the Military Veterans Act, 2022

Comprehensive Support for Veterans

Proposed by the Leader of the Majority, Hon. Amos Kimunya, this newly signed law aims to improve the quality of life for military veterans (vets) and their dependents. The law covers all those who retired after serving in the Kenya Defence Forces (KDF) and its precursor, the pre-colonial unit named Kenya African Rifles. It applies to those who receive a military pension and were not dishonorably discharged from military service. Veterans discharged on medical grounds will also receive benefits under the Act.

Regulatory and Institutional Framework

The Act establishes a regulatory and institutional framework for managing military veterans’ affairs, including the creation of the Dependants’ Education Fund (DEF) by the Defence Council. The Defence Council, chaired by the Defence Cabinet Secretary, includes the Chief of the Kenya Defence Forces, the commanders of the Air Force, Navy, and Army, and the Defence Principal Secretary. This council is the primary decision-making body for veterans’ affairs.

Defence Forces Retirement Home

The Act also establishes the Defence Forces Retirement Home (the Home), where the Defence Council will determine eligibility for accommodation, services provided, and required contributions. Serving members will contribute to the establishment and maintenance of the Home.

Director of Military Veterans

A Director of Military Veterans, appointed by the Defence Council, will oversee the administrative duties of the DEF and the Home, operating under the Chief of Defence Forces.

Advisory Committee on Military Veterans

An Advisory Committee on Military Veterans will be established to advise and make recommendations to the Defence Council, Cabinet Secretary, or Director of Military Veterans on matters related to veterans and their dependents.

Policy Development and Implementation

The Defence Council is empowered to develop policies on military veterans and consider proposals from the Cabinet Secretary, Chief of Defence Forces, or Director of Military Veterans regarding funding and budgeting for veterans’ affairs. Clause 23 of the Act grants the Cabinet Secretary the authority to make regulations for the enactment and implementation of the Act’s provisions.

Conclusion

The Military Veterans Act, 2022, is a significant step toward recognizing and addressing the needs of Kenya’s retired servicemen and their families. Viva to our soldiers and decorated veterans! The rewards of patriotism are within reach.

For further information or legal assistance on compliance or any other legal issue, please contact us at info@wka.co.ke or visit wakilihub.co.ke/. Our Nairobi hub is located at Parklands, Valley View Business Park, 6th Floor, City Park Drive, Off Limuru Road.

Please note that the contents of this newsletter are intended to provide a general guide to the subject matter and should not be relied upon without legal advice.