In a judgment delivered on 30 September 2022 in Kenya Commerce Exchange Service Bureau Limited (KENEX) v Central Bank of Kenya, Petition No. E 181 of 2021, the High Court clarified on who a Payment Service Provider (PSP) is, within the meaning of the National Payment Systems Act 2011 and the National Payment System Regulations 2014. This finding is important as it determines who will be under the regulatory ambit of the Central Bank of Kenya, and serves to ensure that any risks within the national payment system are mitigated. A further consequence of the judgment was that financial institutions may now be able to connect directly onto SWIFT without relying on a third party that offers a platform such as KENEX.