Perimeter and funds-flow review
Map each participant, account, instruction, settlement step and revenue line against the National Payment System framework.
A payment authorisation project begins with the product and funds flow—not the application form. We help founders and established payment businesses determine the relevant perimeter, structure the Kenyan operation and build an application record that is consistent with the proposed service.
Discuss your routeWho this is for
Built around the proposed activity.
- Payment gateways, merchant acquirers and payment aggregators
- Mobile, wallet, remittance and money-transfer propositions
- Foreign fintechs entering Kenya through a subsidiary or partnership
- Platforms adding collection, disbursement or stored-value functionality
Typical work sequence
From legal perimeter to operating evidence.
Structure and readiness plan
Confirm the local entity, ownership, governance, capital, safeguarding, technology and outsourcing position.
Application evidence
Coordinate the business plan, programme of operations, policies, financial information, fit-and-proper material and supporting agreements.
Engagement and implementation
Support preliminary engagement, submission, regulatory questions, remediation and the transition from application documents to operating controls.
Core readiness areas
What the work normally needs.
- A clearly defined service and end-to-end funds flow
- Kenyan corporate, ownership and governance documentation
- Capital and financial projections appropriate to the proposed PSP class
- Business plan and programme of operations
- Risk, AML/CFT, consumer-protection, information-security and continuity controls
- Material bank, safeguarding, technology, agent and outsourcing arrangements
Common pressure points
Problems to resolve before they become delays.
- 01
Describing the product differently across the business plan, contracts, financial model and policies
- 02
Treating a technology platform or licensed partner as automatically removing the applicant from the regulatory perimeter
- 03
Leaving bank, safeguarding, settlement or outsourcing arrangements unresolved until late in the process
- 04
Submitting generic policies that do not match the customer journey, risk model or system controls
How the firm assists
A defined mandate, not a generic package.
We can deliver a preliminary route opinion, readiness gap assessment, application workplan, document drafting and review, counterparty-contract support, submission coordination and regulatory follow-up.
Send a non-confidential enquiryFrequently asked questions
Useful starting answers.
Does every fintech handling payments require its own PSP authorisation?+
Not necessarily. The answer depends on the service, control of funds or payment instructions, customer relationship, contractual role and use of licensed partners. A perimeter review should precede structural conclusions.
Can a foreign licence be relied on in Kenya?+
A foreign authorisation may support credibility and group controls, but it does not by itself authorise regulated payment activity in Kenya.
Can the firm guarantee approval or a fixed approval date?+
No. Approval remains a regulatory decision. The firm can improve readiness, consistency and responsiveness but cannot guarantee the outcome or regulator timetable.
info@snnyagaadvocates.co.ke+254 728 852 448Westpark Towers, 11th Floor, Mpesi Lane, Westlands, Nairobi