By Japhet Gana, Group Head, Transaction Risk & Financial Crimes, Yellow Card
I recently spent five days in Nairobi watching investigators, regulators, and virtual asset providers work through the same simulated scenarios in the same room, at a training run by the United Nations Office on Drugs and Crime. I walked in expecting a policy conversation. I walked out convinced of something more specific: the fix for most stalled virtual asset investigations isn’t better technology. It’s training regulators and providers jointly, before a crisis forces the issue, rather than after one exposes the gap.
That gap is not hypothetical. FATF’s most recent global review, published in July 2026, found that 83% of surveyed jurisdictions have now passed Travel Rule legislation, up from 73% the year before – real progress. But it also found organised crime groups actively exploiting the jurisdictions still catching up, moving billions in illicit proceeds through exactly the space between a rule existing on paper and investigators knowing how to use it. Kenya, where I was training, is one of the jurisdictions actively working to close that gap. Most are not there yet.
A Bridge, Not a Black Box
A licensed virtual asset service provider sits at an unusual point in the financial system: where identity-linked, real-world evidence, the kind a bank produces through know-your-customer records, meets the on-chain trail a blockchain explorer produces through public ledger data. Neither side can supply that link alone. A bank loses visibility once funds convert to crypto. A blockchain explorer cannot say who controls a wallet unless a regulated entity named it first.
That is the bridge, and it matters more than most policy conversations give it credit for. Virtual assets are not the opaque, untraceable instrument they’re often described as. Chainalysis’s 2026 Crypto Crime Report puts illicit activity at under 1% of all on-chain transaction volume in 2025, essentially unchanged from the year before, despite crypto adoption growing considerably in that time. Technology is not the barrier. What’s missing is the bridge between the people holding that evidence and the people trained to ask for it correctly.
The moment that stood out in Nairobi was watching that realization land in real time: a virtual asset provider is not a wall between an investigator and their evidence, but often one of the richest sources of it, if the request is built correctly.
A request naming the wrong entity, or asking for everything instead of one specific record, fails before it reaches the facts of the case. A request built around a clear hypothesis – did the subject control this account, is the asset still recoverable?- moves fast, because it gives the provider something concrete to act on.
That clarity depends on treating preservation, disclosure, and freezing as three distinct actions, not synonyms for “help us.” Preservation protects a record from alteration while formal process catches up. Disclosure is its lawful release to an authorised recipient. Freezing restricts the asset itself, under its own separate legal basis. Blurring these is how urgent requests lose time they cannot afford to lose.
The Same Gap, Everywhere
Whether the setting is Nairobi, Accra, London, Singapore, Dubai, Toronto, Lagos, or São Paulo, investigators run into the same question: how does on-chain activity get connected to reliable, identity-linked evidence, through cooperation that is lawful and fast enough to matter. Kenya is not unique in this respect. It happens to be further ahead than many of its neighbors, having passed its Virtual Asset Service Providers Act in 2025 and stood up licensing and supervisory obligations aligned with the Financial Action Task Force’s Recommendation 15. But the underlying gap between what a virtual asset provider can offer an investigation and what investigators are actually trained to ask for exists in almost every jurisdiction currently building out its virtual asset framework, whether that framework is a year old or still in draft.
I will be carrying this same conversation to West Africa later this month, at a workshop convened for GIABA member states on implementing Recommendation 15 across eleven countries at very different stages of building their own regulatory capacity. The pattern will look familiar: policymakers and supervisors working through what a licensing regime should require, while investigators in the next room are still working out what a lawful, actionable request to a virtual asset provider actually looks like. These two conversations are almost always happening in parallel rather than together, and that separation is exactly where the bridge collapses.
Training Before the Crisis, Not After
The lesson from Nairobi, and the one worth taking seriously well beyond Kenya, is that capacity building for virtual asset investigations cannot wait for a headline case to force the issue. By the time a major fraud or laundering scheme forces a jurisdiction to confront what it does not know about virtual asset evidence, the damage and the precedent for how badly that first case gets handled is already done.
The alternative is straightforward, if not always easy to fund or prioritize: bring regulators, law enforcement, and licensed virtual asset providers into the same room before the volume of cases makes that coordination urgent. Teach investigators what a provider actually holds, and just as importantly, what it does not, so expectations are realistic on both sides. Use real investigative scenarios rather than abstract terminology, and walk participants through the full lifecycle of a request: identifying the right provider, articulating the hypothesis behind the ask, and knowing precisely which of preservation, disclosure, or freezing that hypothesis actually calls for. Do this jointly, rather than training one side on policy and leaving the other to work out the practical mechanics on their own.
This works only if the obligation runs in both directions. The private sector cannot be treated as a passive recipient of rules it had no hand in shaping, and public authorities cannot be expected to understand how a provider actually operates without sitting down with the people who run one. Investigators need a realistic sense of what information exists and how it is held. Providers need a clear sense of the urgency and legal context behind a given request. Cooperation built on that mutual understanding does not soften enforcement. It sharpens it.
None of this requires waiting for perfect regulatory clarity. Kenya’s framework, like most in the region, is still maturing. What made Nairobi work was not a finished rulebook. It was a room full of people willing to compare notes on what actually happens when a request lands on a compliance desk, and what needs to be true for that request to succeed.
The Opportunity in Front of Us
Africa’s virtual asset ecosystem is still young enough to get this right before the gaps calcify into the same adversarial dynamic that has characterized virtual asset regulation elsewhere. That is a genuine advantage, one built not on having fewer problems, but on having the chance to build the bridge deliberately rather than by accident, one hard case at a time. At Yellow Card, this is precisely what we are pushing for: proactive, joint capacity-building that aligns the private sector with regulators before a crisis forces our hand.
That advantage points to a broader shift worth naming directly. Africa should not be viewed only as a recipient of global financial crime expertise. It is increasingly a source of practical lessons for the international community, precisely because jurisdictions here are building this cooperation from scratch, in the open, rather than retrofitting it onto decades of adversarial habit. The most useful models are likely to come from wherever people are willing to learn across regions, rather than assuming the flow of expertise only ever moves in one direction.
Virtual asset providers are not the barrier standing between investigators and the evidence they need. Treated as partners, trained alongside the regulators and law enforcement agencies they answer to, they are very often the fastest, most reliable route to it. The bridge already exists in outline. The task now is to strengthen it deliberately, across borders, before the next major case tests whether we did.
