Inasmuch as Shabaab elements are currently positioned on the Somali-Kenyan border, compliance officers at international banks doing business with ethnic Somali entities in Kenya would do well to ensure that they are not merely fronts for ICU or the Shabaab. Raising the risk level on all funds transfers into Kenya may be appropriate until further notice. Since Al-Qaeda is suspected of rendered financial assistance, Middle Eastern transfers into Kenya, or into Dubai-based MSBs are also probable.

Financial institutions discovered having connections with Somali rebel groups expose themselves to being associated with some of the most serious terrorist acts committed in the East African region. Somewhere in southern Somalia are the three high-profile ICU leaders linked to the two US Embassy and Kenyan hotel bombings. They are amongst the most-wanted specially designated terrorists in Africa, and you can be certain that US special operations forces and intelligence services are searching for them. There are also reports of US naval forces concentrated offshore to interdict or capture fleeing rebel groups. This is a mix a banker simply does not wish his institution to fall into.