Charterhouse Bank Limited

🔴 High Risk

Charterhouse Bank in Kenya epitomizes a grave failure of banking integrity, having operated as a conduit for massive money laundering and tax evasion schemes. Despite being a small entity, the bank orchestrated the movement of billions of shillings through fake, temporary, and nameless accounts, often layering illicit funds under the guise of legitimate business activities. Whistleblower revelations uncovered how the bank enabled major retail chains like Nakumatt to evade billions in taxes, exploiting regulatory gaps in a country then lacking robust anti-money laundering laws. This scandal not only caused significant economic losses but also exposed systemic weaknesses in financial oversight and governance, marking Charterhouse as a symbol of corruption and financial crime in Kenya’s banking history.

Charterhouse Bank in Kenya was at the center of one of the country’s largest money laundering and tax evasion scandals, involving the laundering of over $573 million (Sh64.2 billion) through fake and nameless accounts. Whistleblower Peter Odhiambo revealed a network that included major retail chains like Nakumatt and Tuskys, which used the bank to evade billions in taxes over several years. The scandal exposed serious regulatory failures by the Central Bank of Kenya, which overlooked suspicious activities for years despite numerous warning signs. Following regulatory action, the bank was placed under statutory management and eventually liquidated in 2006. The case highlights major lapses in governance, insider corruption, and the exploitation of weak AML laws in Kenya at the time, with lasting implications for financial crime enforcement in the region.

Country of Incorporation

Kenya (for the Kenyan Charterhouse Bank under investigation related to money laundering)
Also originally a British entity incorporated in the UK as Charterhouse Bank (founded 1920, later absorbed into HSBC) but the focus here is on the Kenyan bank involved in laundering allegations.

Kenya
Former UK entity headquartered in London (historical, defunct since 2000)

Banking / Financial Services

  • For the Kenyan Charterhouse Bank implicated in laundering: Local commercial bank, not a shell company but ran local banking operations with a complex layering of accounts facilitating laundering activities.

  • Historically the UK Charterhouse Bank was an investment bank, later part of HSBC.

  • Layering through multiple temporary and nameless accounts.

  • Trade-based laundering connected with large retail chains (notably Nakumatt and Tuskys) that had suspicious transactions to evade tax and launder money.

  • Use of fake accounts and large deposits beyond account holder balances for layering illicit funds.

  • Tax evasion schemes integrated with laundering, moving billions without paper trails.

  • Sanjay Shah, former Managing Director of Kenyan Charterhouse Bank (involved in whistleblowing and litigation related to bank management).

  • Peter Odhiambo, the whistleblower and internal auditor who exposed the laundering operations.

  • Other undisclosed individuals involved in ownership and management linked through complex accounts.

  • Retail chains Nakumatt and Tuskys were key clients involved in suspicious transactions.

  • No direct publicly named PEPs linked but likely politically exposed due to the nature of the fraud and bank regulatory involvement.

Yes, suspected

  • Due to interlinkages with high-level regulatory and management figures.

  • Whistleblower refers to involvement or cover-up with key government agencies.

  • Some reports mention influence or failure by regulatory officials during the investigation.

  • Kenya Revenue Authority (KRA) investigations into tax evasion linked with Charterhouse Bank operations.

  • Central Bank of Kenya statutory management and subsequent investigations.

  • Whistleblower reports submitted to Ethics and Anti-Corruption Commission.

  • Media investigations by Africog and other watchdogs in Kenya.

  • No direct Panama Papers or FinCEN Files linkage found specifically for Charterhouse Bank, but involved in significant national-level investigations exposing laundering.

High

  • Kenya ranked as medium to high risk in AML terms due to weak enforcement, past laundering cases, and regulatory gaps.

  • The bank’s operations exploited the regulatory weaknesses and limited AML laws at the time.

  • Placed under statutory management by the Central Bank of Kenya (CBK) on June 23, 2006.

  • CBK classified it as a small bank with significant irregularities before liquidation.

  • Multiple court cases initiated by former management (Sanjay Shah and others) fighting CBK and Deposit Protection Fund management.

  • Investigations uncovered lapses in KYC (Know Your Customer) policies and direct breaches of the Banking Act.

  • Bank liquidation and closure in 2006 following exposure of laundering and tax evasion network.

  • Regulatory scrutiny intensified following whistleblower leaks and forensic audits revealing billions of shillings moved through fake accounts.

Dissolved (since 2006) with ongoing legal and regulatory repercussions involving former management and depositors.

  • 2001–2006: Operation of Charterhouse Bank in Kenya with alleged money laundering and tax evasion through complex account manipulations.

  • 2003: Large retail clients (Nakumatt and Tuskys) involved in suspicious undeclared transactions through the bank.

  • 2005: Internal auditor Peter Odhiambo exposes the laundering and tax evasion network, handing over evidence to authorities including KRA and Ethics & Anti-Corruption Commission.

  • June 2006: Central Bank of Kenya places Charterhouse Bank under statutory management.

  • 2006-2007: Deposit Protection Fund (later KDIC) manages bank affairs; controversy over legal authority to manage the bank.

  • 2009: Legal disputes over management control of Charterhouse Bank post-closure, including litigation by former managing directors.

  • 2010 onwards: Bank officially liquidated; former directors and depositors remain embroiled in legal battles.

  • Multiple investigations and reports by media and governance watchdogs reveal extensive tax evasion and money laundering totaling billions of Kenyan shillings.

Layering, Trade-Based Laundering, Shell Layering, Invoice Fraud, Tax Evasion

MENA (Middle East and North Africa, partial due to retail chains’ operations), East Africa (Kenya)

High Risk Country, Emerging Market AML Risk

Charterhouse Bank Limited

Charterhouse Bank Limited
Country of Registration:
Kenya
Headquarters:
Nairobi, Kenya (Longonot Place, Kijabe Street)
Jurisdiction Risk:
High
Industry/Sector:
Banking / Financial Services
Laundering Method Used:

Layering via fake/nameless accounts; trade-based laundering; invoice fraud; tax evasion and insider lending

Linked Individuals:

Sanjay Shah (former Managing Director), Peter Odhiambo (whistleblower), Manish Shah, Manoj Shah, Artur Shah, related retail clients Nakumatt and Tuskys

Known Shell Companies:

None publicly documented

Offshore Links:
1
Estimated Amount Laundered:
Billions of Kenyan Shillings
🔴 High Risk