Role: The Central Bank of Haiti.
Can specific business models operate in Haiti? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.
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AI · Unreviewed| Law / Regulation | Year | Scope |
|---|---|---|
| Law of May 11, 2005, on Money Laundering and Terrorist Financing | 2005 | Loi du 11 mai 2005 relative au blanchiment d'avoirs et au financement du terrorisme (Law of May 11, 2005, on Money Laundering and Terrorist Financing) |
Loi du 11 novembre 2013 relative à la Lutte Contre le Blanchiment d'Argent et le Financement du Terrorisme (Law of November 11, 2013, relating to the Fight Against Money Laundering and the Financing of Terrorism): This is the cornerstone of Haiti's AML/CFT framework. It defines money laundering and terrorist financing offenses, sets out reporting obligations for designated non-financial businesses and professions (DNFBPs) and financial institutions, and establishes the powers of the UCREF.
Décret du 10 mars 2005 instituant l'Unité de Lutte Contre le Blanchiment d'Argent (Decree of March 10, 2005, instituting the Unit for the Fight Against Money Laundering): This decree established the UCREF as Haiti's Financial Intelligence Unit (FIU) and outlined its structure and functions.
Obtaining and verifying the identity of legal persons (name, legal form, address, proof of incorporation/existence, names of directors/senior management).
Using reliable, independent source documents, data, or information for verification.
Beneficial Ownership (BO): Identifying and taking reasonable measures to verify the identity of the beneficial owner(s) of customers, including understanding the ownership and control structure of legal persons. This typically involves identifying individuals who own or control more than a certain percentage (e.g., 25%) of the entity, or who exercise control through other means.
Purpose and Nature of Business Relationship: Understanding the purpose and intended nature of the business relationship or transaction.
Ongoing Monitoring: Continuously monitoring the business relationship and transactions undertaken by customers to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile, including the source of funds where necessary.
Enhanced Due Diligence (EDD): For higher-risk customers or transactions (e.g., Politically Exposed Persons (PEPs), complex or unusually large transactions, customers from high-risk jurisdictions, or transactions involving privacy-enhancing virtual assets), VASPs must apply EDD measures, such as
Obtaining additional information on the customer and BO.
Obtaining information on the source of funds or wealth.
Obtaining approval from senior management for establishing or continuing the business relationship.
Obligation to Report: Reporting any transaction (or attempted transaction) where there are reasonable grounds to suspect that funds are the proceeds of a criminal activity or are related to terrorist financing, regardless of the amount.
"No Tipping-Off": Prohibiting the VASP or its employees from disclosing to the customer or any third party that an STR is being or has been filed.
Red Flags: Developing internal procedures to identify "red flags" specific to virtual assets that may indicate money laundering or terrorist financing (e.g., unusual transaction patterns, rapid transfers of large sums, use of mixers/tumblers, unexplained sources of funds, attempts to avoid CDD).
Customer Identification Records: All records obtained through CDD, including copies of identification documents.
Transaction Records: Details of all domestic and international transactions, including the amount, currency (both fiat and virtual asset type), date, method of payment, and the identities of the originator and beneficiary (including wallet addresses).
Analysis and STRs: Records of any analysis undertaken concerning suspicious transactions and copies of all STRs filed.
Retention Period: Records must generally be kept for a minimum of five (5) years after the business relationship ends or after the date of the transaction.
Role: Haiti's Financial Intelligence Unit (FIU). It is the central authority for receiving, analyzing, and disseminating suspicious transaction reports (STRs) and other relevant information to competent authorities (e.g., law enforcement) for the investigation and prosecution of money laundering and terrorist financing.
Role: The Central Bank of Haiti. While not explicitly stated for "VASPs" currently, the BRH is the prudential regulator and supervisor for traditional financial institutions. Should Haiti introduce specific regulation or licensing for VASPs, it is highly probable that the BRH would be designated as the primary supervisory authority for their AML/CFT compliance, or at least play a significant role in their oversight. The BRH has previously issued warnings regarding the risks of cryptocurrencies.
Lack of Specific Regulation: The absence of specific VASP regulations in Haiti means that VASPs should proactively align themselves with international best practices (e.g., FATF recommendations for VAs and VASPs) and interpret Haiti's existing AML/CFT laws broadly to cover their operations.
Travel Rule: While not explicitly legislated for VAs in Haiti, FATF Recommendation 16 (the "Travel Rule") applies to VASPs. This means VASPs should gather and transmit originator and beneficiary information for virtual asset transfers above a certain threshold (e.g., $1,000/€1,000).
Sanctions Compliance: VASPs must screen customers and transactions against national and international sanctions lists (e.g., UN Security Council sanctions).
Internal Controls: VASPs should establish robust internal AML/CFT programs, including the appointment of a compliance officer, employee training, internal audit functions, and risk assessment procedures.
Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Obligations: This is the most significant area where virtual asset businesses operating in Haiti, or serving Haitian customers, must be compliant. Haiti is a member of the Caribbean Financial Action Task Force (CFATF), which is an associate member of the Financial Action Task Force (FATF). FATF Recommendations explicitly require countries to regulate and supervise VASPs for AML/CFT purposes.
Even without a specific VASP licensing law, any entity facilitating financial transactions, including those involving virtual assets, is generally expected to adhere to Haiti's existing AML/CFT legislation. This implies implementing KYC (Know Your Customer) procedures, transaction monitoring, suspicious activity reporting (SARs), and other AML/CFT controls.
The Unité Centrale de Renseignements Financiers (UCREF) is Haiti's Financial Intelligence Unit (FIU) and is responsible for receiving and analyzing SARs and combating money laundering and terrorist financing. VASPs, like traditional financial institutions, would be expected to report to UCREF.
Exchanges, Custody Providers, Payment Processors (Cryptocurrency-Specific): No specific license required solely for crypto activities.
Hybrid Businesses: If a business combines crypto services with traditional financial services (e.g., fiat currency exchange, remittances in fiat, deposit-taking), it would likely require appropriate licenses from the BRH for those traditional services.
Neither specifically exists for VASPs. Haiti has not yet implemented the FATF recommendation for countries to license or register VASPs.
Capital Requirements: Not applicable for crypto-only services without a dedicated licensing regime. However, any entity requiring a BRH license for traditional financial services would have specific capital requirements.
AML/KYC Requirements: CRUCIAL. Even without specific crypto regulations, it is highly advisable and often implicitly required under Haiti's general AML/CFT law for any entity dealing with financial transactions to
Implement robust Know Your Customer (KYC) procedures (identity verification, customer due diligence).
Monitor transactions for suspicious activities.
Report suspicious transactions to UCREF.
Have internal AML policies, controls, and a designated compliance officer.
Local Presence: Generally, any financial services business operating in Haiti is expected to have a local legal entity and physical presence. This would likely be a requirement if a crypto business were to seek a traditional financial license or if specific crypto regulations were introduced.
Fit and proper assessment of directors and shareholders.
Detailed operational and risk management frameworks.
The primary financial regulator. While they haven't issued specific crypto regulations, any future framework would likely come from them.
Note: You'll find general banking and financial sector regulations here, but nothing specific to crypto.
Loi du 20 février 2013 portant sur la lutte contre le blanchiment d'avoirs et le financement du terrorisme (Law of February 20, 2013, on the Fight Against Money Laundering and Terrorist Financing)
This is Haiti's primary AML/CFT law. It is crucial for any entity dealing with financial transactions. While it doesn't explicitly mention "virtual assets" (being from 2013), its principles and obligations extend to activities that could facilitate money laundering or terrorist financing.
Finding a direct official government link can be challenging for Haitian laws, but the law's existence and content are well-documented by legal firms and international bodies.
Responsible for receiving and analyzing suspicious transaction reports (STRs).
Note: Any VASP operating in Haiti should understand its obligations to UCREF under the general AML/CFT framework.
Haiti is a member, and CFATF reports often include recommendations regarding VASP regulation.
Note: Searching for "Haiti" on the CFATF website might yield mutual evaluation reports that highlight the country's AML/CFT framework and recommendations, including potential future VASP regulation.
Comply fully with Haiti's existing AML/CFT laws and be prepared for potential future VASP-specific regulations.
Monitor developments from the BRH and UCREF closely.
Seek independent legal counsel in Haiti to understand the application of general financial laws to their specific business model and to ensure compliance with current and evolving legal obligations.
Be aware that international pressure (FATF/CFATF) will likely lead to the introduction of VASP-specific licensing or registration requirements in the future.
Banque de la République d'Haïti (BRH) - The Central Bank of Haiti.
Role: While not a crypto regulator, the BRH is responsible for the overall stability of the financial system, monetary policy, and oversight of traditional financial institutions. It has issued warnings about the risks associated with cryptocurrencies. It would be the primary body to initiate any future comprehensive regulation.
Role: The UCRF is responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) related to money laundering and terrorist financing. While the 2005 AML/CFT law doesn't explicitly name "virtual assets," the UCRF would interpret its mandate to cover any financial transactions suspected of illicit activity, including those involving crypto if they flow through regulated entities or trigger other reporting obligations. Haiti, as a member of the Caribbean Financial Action Task Force (CFATF), is under pressure to align with FATF Recommendations, which do cover virtual assets.
Its legal basis stems from the AML/CFT law (see below).
Loi du 11 mai 2005 relative au blanchiment d'avoirs et au financement du terrorisme (Law of May 11, 2005, on Money Laundering and Terrorist Financing)
Relevance to Crypto: This law establishes the general AML/CFT framework in Haiti. While it predates the widespread use of cryptocurrencies and does not explicitly mention them, it forms the basis for the UCRF's operations and imposes obligations on traditional financial institutions. If virtual assets are converted to fiat through a regulated financial institution (e.g., banks, money transfer operators), these entities would be subject to the law's reporting requirements.
Reference to CFATF Reports (which discuss the law): CFATF Website - Haiti Reports (You'll need to navigate to the specific reports, such as the 2018 Mutual Evaluation Report, to see detailed discussions of Haiti's AML/CFT framework).
However, it operates in a regulatory vacuum, meaning there are no specific consumer protections, licensing requirements for trading platforms, or clear legal recourse in case of fraud or loss of funds specific to virtual assets.
The BRH has issued general warnings about the risks associated with cryptocurrencies, including their volatility, lack of underlying assets, and potential for use in illicit activities.
There is no specific licensing or regulatory framework for cryptocurrency exchanges (Virtual Asset Service Providers - VASPs) operating within Haiti.
Foreign-based cryptocurrency exchanges are accessible to Haitian residents, but they operate outside Haitian jurisdiction, meaning local authorities have no oversight or control over their operations or the funds held by their users.
Any entity attempting to operate a local crypto exchange would likely fall under general business registration laws but would not be subject to financial regulations specifically tailored to virtual assets, leading to a lack of oversight regarding AML/CFT specific to crypto, capital requirements, or consumer protection.
Haiti has not established a specific legal framework for cryptocurrency or virtual asset regulation, and no dedicated licensing regime exists for crypto businesses.
Haiti is not a FATF member but is a member of the Caribbean Financial Action Task Force (CFATF), a FATF-style regional body. Caribbean Financial Action Task Force (CFATF)
The practical reality is that crypto activity operates in a regulatory vacuum, with the central bank and financial authorities having not yet issued digital asset-specific AML rules.
Haiti is a member of the Caribbean Financial Action Task Force (CFATF), which is the FATF-style regional body for the Caribbean region, including Haiti. Caribbean Financial Action Task Force (CFATF)
Haiti is not listed as a FATF member country; the FATF membership list includes countries such as Argentina, Australia, Canada, France, the United Kingdom, and the United States, but not Haiti. Haiti
The FATF has issued public statements concerning Haiti's strategic AML/CFT deficiencies, with the most recent CFATF Public Statement on Haiti issued in November 2017. CFATF Public Statement on Haiti
Haiti remains on the FATF "Jurisdictions under Increased Monitoring" list as of the June 2026 update, meaning it is actively working with the FATF to address strategic deficiencies in its AML/CFT regime. Jurisdictions under Increased Monitoring - 19 June 2026
The FATF published a progress report on Haiti on January 31, 2026, analyzing Haiti's progress in addressing technical compliance deficiencies identified in its 2019 mutual evaluation. Jurisdictions under Increased Monitoring - 19 June 2026
Haiti also remained under increased monitoring in the February 2025, June 2025, and October 2025 FATF updates. Jurisdictions under Increased Monitoring - 21 February 2025
Haiti was also listed under increased monitoring in the June 2025 and October 2025 FATF statements. Jurisdictions under Increased Monitoring - 24 October 2025
A previous CFATF Public Statement on Haiti and Suriname was issued in June 2016, indicating ongoing AML/CFT concerns prior to the 2017 statement. CFATF Public Statement on Haiti and Suriname
The FATF identifies jurisdictions under increased monitoring as those actively working with the FATF to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. Jurisdictions under Increased Monitoring - 19 June 2026
Haiti's AML/CFT framework is subject to FATF mutual evaluation processes, with the 2019 mutual evaluation identifying technical compliance deficiencies that Haiti has been working to address. Jurisdictions under Increased Monitoring - 19 June 2026
Haiti has not established any licensing or registration framework specifically for cryptocurrency exchanges, digital asset service providers, or virtual asset businesses.
No entity has been licensed as a virtual asset service provider in Haiti, as no such licensing regime exists.
The absence of a crypto licensing framework means there is no regulatory pathway for businesses seeking to legally operate cryptocurrency services in Haiti.
Zero entities have been licensed to conduct virtual asset activities in Haiti.
Haiti's AML/CFT regime has been evaluated by the FATF and found to have strategic deficiencies, which is why it remains under increased monitoring. Jurisdictions under Increased Monitoring - 19 June 2026
U.S. financial institutions are reminded that Haiti's presence on the increased monitoring list triggers enhanced due diligence obligations for correspondent accounts maintained for Haitian financial institutions under 31 CFR § 1010.610(a).
Covered U.S. financial institutions must ensure their due diligence programs for correspondent accounts include appropriate, specific, risk-based, and enhanced policies, procedures, and controls reasonably designed to detect and report known or suspected money laundering activity involving Haitian financial institutions.
Haiti's 2019 mutual evaluation identified technical compliance deficiencies in its AML/CFT framework, and a January 2026 FATF report analyzes Haiti's progress in addressing those deficiencies. Jurisdictions under Increased Monitoring - 19 June 2026
The FATF requires jurisdictions under increased monitoring to address strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing. Jurisdictions under Increased Monitoring - 19 June 2026
No specific CDD, EDD, STR reporting thresholds, record retention periods, or beneficial ownership requirements for virtual asset transactions have been identified in the available sources for Haiti. CFATF Public Statement on Haiti
The CFATF issued a Public Statement on Haiti in November 2017, highlighting AML/CFT deficiencies in the country. CFATF Public Statement on Haiti
A prior CFATF Public Statement on Haiti and Suriname was issued in June 2016, indicating ongoing concerns about Haiti's AML/CFT regime. CFATF Public Statement on Haiti and Suriname
Haiti was added to the FATF Jurisdictions under Increased Monitoring list on June 25, 2021, a form of international action reflecting deficiencies in its AML/CFT regime.
Haiti remains under FATF increased monitoring as of the February 2025, June 2025, October 2025, and June 2026 updates. Jurisdictions under Increased Monitoring - 21 February 2025
A January 31, 2026 FATF report analyzed Haiti's progress in addressing technical compliance deficiencies identified in its 2019 mutual evaluation. Jurisdictions under Increased Monitoring - 19 June 2026
No specific enforcement actions, fines, arrests, or penalties related to cryptocurrency or virtual asset activities in Haiti were identified in the provided sources.
No tax guidance has been issued for virtual assets in Haiti.
The United States Department of State's 2025 Investment Climate Statement for Haiti does not mention any tax treatment rules for cryptocurrency gains, capital gains on digital assets, or VAT treatment of virtual asset transactions.
There is no evidence in the available sources of any Haitian tax authority guidance addressing how cryptocurrency gains would be taxed. CFATF Public Statement on Haiti
Haiti has no dedicated legal framework for cryptocurrency or virtual asset regulation, creating significant legal uncertainty for businesses.
There is no licensing regime for virtual asset service providers in Haiti, meaning legitimate crypto businesses cannot obtain regulatory authorization.
Haiti's continued presence on the FATF increased monitoring list creates reputational risk and enhanced due diligence burdens for Haitian financial institutions dealing with foreign correspondent banks.
U.S. financial institutions must apply enhanced due diligence to correspondent accounts involving Haitian financial institutions, which could constrain cross-border crypto-related banking relationships.
The FATF's identification of Haiti under increased monitoring represents an implementation gap between Haiti's paper AML/CFT framework and the practical requirements of international standards. Jurisdictions under Increased Monitoring - 19 June 2026
Haiti's 2019 mutual evaluation found technical compliance deficiencies that remained significant enough to warrant continued increased monitoring through at least 2026. Jurisdictions under Increased Monitoring - 19 June 2026
Businesses operating in the crypto space in Haiti face the risk of operating without any legal protection or regulatory clarity, given the complete absence of virtual asset-specific rules.
The lack of a crypto-specific AML framework in Haiti is a significant gap, particularly given the FATF's evolving standards on virtual assets which the country would be expected to adopt. Jurisdictions under Increased Monitoring - 19 June 2026
Caribbean Financial Action Task Force (CFATF)
CFATF Public Statement on Haiti and Suriname
Jurisdictions under Increased Monitoring - 21 February 2025
No. Haiti has not yet adopted a comprehensive legal and regulatory framework specifically governing Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs), including the FATF Travel Rule. The existing Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) laws do not explicitly cover VASPs.
The CFATF 4th Round Enhanced Follow-Up Report & Technical Compliance Re-Rating of Haiti (2023) explicitly states that Haiti has not addressed Recommendation 15 (New Technologies – covering VAs and VASPs) and that there is no legal framework for the licensing, registration, or supervision of VASPs for AML/CFT purposes.
Not applicable, as the framework for VAs/VASPs, including the Travel Rule, has not been adopted.
Not defined, as the regulatory framework is not in place. The FATF Travel Rule typically applies to transactions above a de minimis threshold (e.g., USD/EUR 1,000).
Not legally defined or explicitly covered under existing Haitian law. While the FATF definition of a VASP would conceptually apply (any natural or legal person who, as a business, conducts one or more of the following activities or operations for or on behalf of another natural or legal person: exchange between VAs and fiat currencies; exchange between one or more forms of VAs; transfer of VAs; safekeeping and/or administration of VAs or instruments enabling control over VAs; and participation in and provision of financial services related to an issuer's offer and/or sale of a VA), these entities are not yet subject to specific AML/CFT obligations in Haiti.
Not specified or required, due to the absence of a legal framework.
Not specifically applicable for Travel Rule non-compliance, as the rule is not legally binding in Haiti for VASPs.
Haiti's general AML/CFT law, the Loi du 11 novembre 2016 (relative à la lutte contre le blanchiment d'argent et le financement du terrorisme), applies to traditional financial institutions and designated non-financial businesses and professions (DNFBPs). Penalties under this law would apply to those entities for non-compliance with their respective obligations, but not currently to unregulated VASPs.
Loi du 11 novembre 2016 relative à la lutte contre le blanchiment d'argent et le financement du terrorisme (AML/CFT Law of Haiti): This is Haiti's main AML/CFT legislation, but as noted, it does not explicitly cover VASPs.
Finding a direct URL for the official Haitian text of this law can be challenging, but it is referenced in all CFATF reports.
CFATF 4th Round Enhanced Follow-Up Report & Technical Compliance Re-Rating of Haiti (2023): This is the most authoritative public source on Haiti's compliance with FATF Recommendations, including its status regarding virtual assets.
A direct link to the PDF is often not static, but searching for "CFATF Haiti 2023 follow-up report" will lead you to it.
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Custody regulation data collection in progress.
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The Haitian government has not yet issued specific regulations targeting cryptocurrencies and digital assets, leaving a regulatory vacuum that could be exploited by malicious actors. Securing America's Near Abroad: Recalibrating U.S. Policy Toward Haiti
Absence of Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations for digital asset transactions in Haiti hampers efforts to prevent illicit financial flows and terrorist financing. Haiti's Instability and Its Effect on U.S. Security - Air University
No enforcement mechanisms are currently in place to address violations related to cryptocurrency and digital asset activities in Haiti, leaving the market vulnerable to abuse. Security Council Assesses Road to Elections, Stability in Haiti ...
The Haitian tax system does not explicitly address cryptocurrencies, resulting in ambiguity regarding the tax liabilities of digital asset transactions. Haiti Tax Rates & System (2026)
The lack of regulatory oversight creates significant risks, including financial instability, increased opportunities for illicit activities, and potential harm to the Haitian economy. Immediate policy development is crucial to address these gaps and safeguard national security. Beyond the Output Trap: Haiti and the Future of ...
Securing America's Near Abroad: Recalibrating U.S. Policy Toward Haiti
Haiti's Instability and Its Effect on U.S. Security - Air University
Haiti Tax Rates & System (2026)
Asset Freeze: Requires all UN member states to freeze funds, other financial assets, and economic resources owned or controlled, directly or indirectly, by designated individuals and entities.
Travel Ban: Imposes a travel ban on designated individuals.
Targeted Arms Embargo: Prohibits the direct or indirect supply, sale, or transfer of small arms, light weapons, and related ammunition to designated individuals and entities in Haiti.
VASPs must screen their customers, beneficial owners, and transaction counterparties against the UN Security Council Consolidated Sanctions List, specifically looking for individuals and entities designated under the Haiti sanctions regime.
Any detected matches (hits) trigger an obligation to freeze assets and block transactions, as well as report to relevant authorities (Financial Intelligence Units, central banks).
UNSC Resolution 2653 (2022): https://documents-dds-ny.un.org/doc/UNDOC/GEN/N22/633/32/PDF/N2263332.pdf?OpenElement
UNSC Resolution 2700 (2023): https://documents-dds-ny.un.org/doc/UNDOC/GEN/N23/305/74/PDF/N2330574.pdf?OpenElement
UN Security Council Sanctions Committees (1000 Haiti Sanctions Committee): https://www.un.org/securitycouncil/sanctions/2653 (This page lists designated individuals and entities).
Blocking (Asset Freeze): U.S. persons (including U.S. companies, their foreign branches, and persons operating within the U.S.) are prohibited from engaging in any transactions with designated individuals and entities. All property and interests in property of designated persons that are in the United States or come within the possession or control of U.S. persons are blocked.
General Prohibitions: Prohibitions extend to making or receiving any contribution or provision of funds, goods, or services to or for the benefit of any designated person, or receiving any contribution or provision of funds, goods, or services from any such person.
U.S.-based VASPs, and foreign VASPs that have a U.S. nexus (e.g., U.S. customers, servers, or transactions cleared through the U.S. financial system), must screen all customers and transactions against OFAC's Specially Designated Nationals and Blocked Persons (SDN) List and other relevant sanctions lists (e.g., Sectoral Sanctions Identifications List, Non-SDN Menu-Based Sanctions List).
Any match with a Haiti-related SDN or other designated person triggers blocking obligations and reporting to OFAC.
Beyond specific Haiti designations, VASPs must comply with all other relevant OFAC sanctions programs (e.g., if a transaction involves a sanctioned jurisdiction like Iran or North Korea, or a designated terrorist organization, it would be prohibited regardless of its Haiti connection).
OFAC Sanctions Programs and Country Information - Haiti: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/haiti-sanctions (This page provides links to relevant Executive Orders and designated individuals).
The EU implements the UN sanctions regime against Haiti.
It may also adopt additional autonomous designations mirroring or expanding upon UN or OFAC designations under its Common Foreign and Security Policy (CFSP).
Measures typically include asset freezes and prohibitions on making funds or economic resources available to designated individuals and entities.
VASPs operating in the EU must screen their customers, beneficial owners, and transaction counterparties against the EU Consolidated Sanctions List. This list includes individuals and entities designated under the EU's Haiti sanctions regime.
Any matches trigger asset freezing and reporting obligations to the relevant national competent authorities in the EU Member State.
EU Sanctions Map (Search for Haiti): https://www.sanctionsmap.eu/#/main
Council Decision (CFSP) 2022/2275 of 21 November 2022 concerning restrictive measures in view of the situation in Haiti: https://eur-lex.europa.eu/eli/dec/2022/2275/oj
Council Regulation (EU) 2022/2274 of 21 November 2022 concerning restrictive measures in view of the situation in Haiti: https://eur-lex.europa.eu/eli/reg/2022/2274/oj
Know Your Customer (KYC) / Customer Due Diligence (CDD): Implement robust KYC/CDD procedures to identify and verify the identity of customers, including beneficial owners, and assess their risk profile. This is foundational for effective sanctions screening.
Real-time and Batch Screening: Screen all new and existing customers, as well as all transaction counterparties, against the most current versions of
UN Security Council Consolidated Sanctions List (specifically the Haiti sanctions list).
OFAC Specially Designated Nationals (SDN) List: https://www.treasury.gov/ofac/downloads/sdnlist.txt
Any other relevant national sanctions lists (e.g., Canada, UK, Switzerland, if the VASP has nexus to those jurisdictions).
Enhanced Due Diligence: For high-risk customers or transactions involving Haiti, conduct enhanced due diligence to identify potential sanctions evasion or illicit finance risks.
While Haiti itself is not a comprehensively sanctioned jurisdiction, transactions directly or indirectly involving designated individuals or entities within Haiti are prohibited.
VASPs must also avoid facilitating transactions for residents or entities in comprehensively sanctioned jurisdictions (e.g., Iran, North Korea, Syria, Cuba, Crimea region, Donetsk/Luhansk/Zaporizhzhia/Kherson regions of Ukraine) regardless of any direct link to Haiti.
Transaction Monitoring: Implement automated transaction monitoring systems to detect suspicious patterns, unusually large transactions, transactions involving high-risk jurisdictions, or transactions potentially linked to sanctioned entities or individuals.
Blocked Property Reports: If a VASP blocks assets or rejects a transaction due to a sanctions match, it must typically report this to the relevant authorities (e.g., OFAC in the U.S., national competent authorities in the EU, the Financial Intelligence Unit (FIU) in Haiti if domestically relevant).
Suspicious Activity Reports (SARs) / Suspicious Transaction Reports (STRs): File SARs/STRs with the relevant FIU (e.g., UCREF in Haiti, FinCEN in the U.S.) for any activity suspected of being related to sanctions evasion, money laundering, or terrorism financing.
Travel Rule Compliance: For cross-border crypto transfers exceeding a certain threshold (e.g., $1,000 USD or equivalent, as per FATF guidance), VASPs must transmit and receive required originator and beneficiary information. This information is crucial for effective sanctions screening.
Regulatory Landscape for Crypto: Haiti's regulatory framework for cryptocurrencies is nascent. The Banque de la République d'Haïti (BRH - Central Bank of Haiti) has not yet issued comprehensive regulations specifically governing cryptocurrencies, nor has it banned them outright.
Banque de la République d'Haïti (BRH): https://www.brh.ht/
Implementation of International Sanctions: As a UN member state, Haiti is legally obliged to implement UN Security Council Resolutions, including Resolution 2653 and 2700. This typically falls under the purview of its financial intelligence unit (FIU), Unité Centrale de Renseignements Financiers (UCREF), and the BRH, which are responsible for enforcing AML/CFT laws and international sanctions domestically.
UCREF (Haiti's FIU): https://www.ucref.gouv.ht/ (UCREF would be the primary contact for SAR/STR reporting in Haiti and for providing guidance on domestic implementation of UN sanctions).
Civil Penalties: Can range from thousands to millions of dollars per violation, depending on the program, severity, and intent.
Criminal Penalties: For willful violations, individuals can face substantial fines (up to millions of dollars) and long prison sentences (up to 20 years), while corporations can face much larger fines.
Reputational Damage: Significant damage to reputation, loss of licenses, and exclusion from the financial system.
Member State Enforcement: Penalties are determined by individual EU Member States, typically involving fines (often substantial) and imprisonment for serious violations.
Reputational Damage: Similar to the U.S., non-compliance can lead to severe reputational harm.
While the UN itself does not directly enforce penalties on private entities, non-compliance with UN sanctions by member states (or entities within them) can lead to political condemnation, and potential "secondary sanctions" or enforcement actions from countries like the U.S. and EU that prioritize enforcing these regimes.
Haiti (Domestic): Haiti's domestic laws would outline penalties for failing to comply with UN Security Council resolutions, typically involving fines and imprisonment, although specific precedents for crypto-related sanctions violations would be rare given the nascent regulatory environment.
Haiti does not have a domestic, crypto-specific sanctions list.
Its primary obligation concerning "country-specific sanctions lists" related to Haiti is to implement and enforce the UN Security Council Haiti Sanctions List established under Resolution 2653 (and subsequently updated).
For VASPs globally, compliance requires screening against the UN Consolidated Sanctions List, the OFAC SDN List (which includes Haiti-specific designations), and the EU Consolidated Sanctions List (which also includes Haiti-specific designations). These international lists are the relevant "country-specific" sources for designated individuals and entities tied to Haiti.
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Likely enforcement action expected around 2026-07-06
Based on 165 historical regulatory events for Haiti, averaging every 67 days, with increasing regulatory activity.
Loi du 11 novembre 2013 relative à la Lutte Contre le Blanchiment d'Argent et le Financement du Terrorisme (Law of November 11, 2013, relating to the Fight Against Money Laundering and the Financing of Terrorism): This is the cornerstone of Haiti's AML/CFT framework. It defines money laundering and terrorist financing offenses, sets out reporting obligations for designated non-financial businesses and professions (DNFBPs) and financial institutions, and establishes the powers of the UCREF.
Banque de la République d'Haïti (BRH):
Sanctions Compliance: VASPs must screen customers and transactions against national and international sanctions lists (e.g., UN Security Council sanctions).
Limited Framework: Haiti does not have a comprehensive legal or regulatory framework specifically for cryptocurrencies.
Regulatory Landscape for Crypto: Haiti's regulatory framework for cryptocurrencies is nascent. The Banque de la République d'Haïti (BRH - Central Bank of Haiti) has not yet issued comprehensive regulations specifically governing cryptocurrencies, nor has it banned them outright.
Implementation of International Sanctions: As a UN member state, Haiti is legally obliged to implement UN Security Council Resolutions, including Resolution 2653 and 2700. This typically falls under the purview of its financial intelligence unit (FIU), Unité Centrale de Renseignements Financiers (UCREF), and the BRH, which are responsible for enforcing AML/CFT laws and international sanctions domestically.
Haiti (Domestic): Haiti's domestic laws would outline penalties for failing to comply with UN Security Council resolutions, typically involving fines and imprisonment, although specific precedents for crypto-related sanctions violations would be rare given the nascent regulatory environment.
Haiti does not have a domestic, crypto-specific sanctions list.
For VASPs globally, compliance requires screening against the UN Consolidated Sanctions List, the OFAC SDN List (which includes Haiti-specific designations), and the EU Consolidated Sanctions List (which also includes Haiti-specific designations). These international lists are the relevant "country-specific" sources for designated individuals and entities tied to Haiti.
Issuing Warnings: The BRH has issued public advisories warning the population about the risks associated with cryptocurrencies, including volatility, lack of regulation, potential for fraud, and their non-recognition as legal tender.
Anti-Money Laundering (AML) / Combating the Financing of Terrorism (CFT): Any enforcement actions related to cryptocurrency would more likely fall under broader financial crime statutes, particularly if digital assets are suspected of being used for money laundering, terrorist financing, or other illicit activities, rather than for violating securities laws.
Banque de la République d'Haïti (BRH) Official Website:
Banque de la République d'Haïti (BRH) Communications: The primary source of information on Haiti's stance comes from the BRH. While a single, easily discoverable "stablecoin regulation" document doesn't exist, the BRH has issued general warnings regarding cryptocurrencies. These warnings typically highlight the risks, the lack of legal tender status, and the absence of regulatory oversight.
Loi du 20 mars 1996 sur les institutions financières: This law governs traditional financial institutions and services in Haiti. As stablecoins are not recognized within this framework, it does not apply directly to their regulation but defines the existing, regulated financial landscape.
Approach: Partial / Largely Unregulated with Cautious Warnings. While there isn't an outright ban, there's no specific framework for licensing, operating, or supervising virtual asset service providers (VASPs) or crypto activities. The existing anti-money laundering (AML) and countering the financing of terrorism (CFT) framework is the primary, albeit indirect, mechanism that could be applied to financial institutions dealing with virtual assets. The central bank has issued warnings regarding the risks.
Banque de la République d'Haïti (BRH): The BRH has previously issued warnings regarding cryptocurrencies, emphasizing that they are not legal tender in Haiti and cautioning against their use due to risks such as volatility, lack of regulatory oversight, and potential for illicit activities. While not explicitly illegal, they are not officially recognized or regulated as financial instruments or currency.
Practicality: For infrequent, small-scale transactions by individuals, enforcement might be challenging, but legally, the potential for taxation exists.
Banque de la République d'Haïti (BRH): Haiti's central bank issues pronouncements regarding currency, financial stability, and warnings about unregulated financial instruments.
UN Security Council Resolution 2653 (2022) established the Haiti sanctions regime on 21 October 2022, including asset freezes, travel bans, and targeted arms embargoes UNSC Resolution 2653
UN Security Council Resolution 2753 (2024) extended the sanctions regime until 15 October 2025, maintaining the asset freeze, travel ban, and targeted arms embargo UNSC Resolution 2753
As of 27 April 2026, the UN sanctions regime under Resolution 2753 has expired (15 October 2025). Available public records do not show a subsequent renewal resolution passed before this date. The status post-expiry requires confirmation from official UN sources.
The UN Security Council Sanctions Committee (Haiti Committee) was established under Resolution 2653 to designate individuals and entities and oversee implementation UN Haiti Sanctions Committee
Travel Ban: Imposes a travel ban on designated individuals preventing entry into or transit through member states UNSC Resolution 2653, Para 1(b)
US sanctions are distinct from UN sanctions: OFAC can designate individuals not on the UN list, targeting broader criteria including corruption and specific human rights abuses with secondary sanctions implications Treasury Press Release on Haiti Designations
Asset Freeze: US persons (including US companies, foreign branches, and persons operating within the US) are prohibited from transactions with designated individuals; all property of designated persons in US possession/control is blocked 31 CFR Chapter V
Prohibitions extend to making/receiving any contribution of funds/goods/services to/for benefit of any designated person OFAC Haiti Sanctions FAQ
Council Decision (CFSP) 2022/2275 (21 November 2022) implements UN sanctions against Haiti with possible autonomous designations EU Council Decision
Council Regulation (EU) 2022/2274 (21 November 2022) provides legal framework for enforcement including asset freezes and fund prohibitions EU Council Regulation
EU may adopt additional autonomous designations mirroring or expanding upon UN/OFAC designations under CFSP EU Sanctions Map
VASPs operating in EU must screen against EU Consolidated Sanctions List including Haiti designations EU Consolidated Sanctions List
KYC/CDD: Implement robust KYC/CDD procedures to identify customers, beneficial owners, and assess risk profiles as foundational for sanctions screening FATF Recommendation 10
Enhanced Due Diligence: For high-risk customers/transactions involving Haiti, conduct enhanced due diligence to identify potential sanctions evasion or illicit finance risks FATF Guidance for VASPs
VASPs must also avoid facilitating transactions for comprehensively sanctioned jurisdictions (Iran, North Korea, Syria, Cuba, Crimea) regardless of Haiti link OFAC Sanctions Programs
Transaction Monitoring: Implement automated systems to detect suspicious patterns, large transactions, high-risk jurisdiction links, or potential sanctions connections FATF Recommendation 16
Travel Rule Compliance: For cross-border crypto transfers exceeding threshold (e.g., $1,000 USD), VASPs must transmit/receive originator and beneficiary information critical for sanctions screening FATF Recommendation 16
Blocked Property Reports: If VASP blocks assets or rejects transactions due to sanctions match, must report to relevant authorities (OFAC in US, national competent authorities in EU, Haiti's FIU if domestically relevant) OFAC Reporting Requirements
Suspicious Activity Reports (SARs): File SARS/STRs with relevant FIU (UCREF in Haiti, FinCEN in US) for suspected sanctions evasion, money laundering, or terrorism financing FinCEN SAR Guidance
UCREF (Unité Centrale de Renseignements Financiers): Haiti's FIU, responsible for enforcing AML/CFT laws and implementing UN sanctions domestically UCREF Official Site
Primary obligation is implementing UN Haiti Sanctions List under Resolution 2653 (and updates) - Haiti does not have a domestic crypto-specific sanctions list UN Security Council Sanctions
US Civil Penalties: Range from thousands to millions of dollars per violation depending on program, severity, and intent OFAC Enforcement Guidelines
US Criminal Penalties: Willful violations can result in fines up to millions and imprisonment up to 20 years for individuals; larger fines for corporations 31 USC § 560.701
Reputational Damage: Significant harm to reputation, loss of licenses, exclusion from financial system OFAC Enforcement Actions
EU Member State Enforcement: Penalties determined by individual EU Member States, typically involving substantial fines and imprisonment for serious violations EU Sanctions Enforcement
Haiti Domestic: Laws outline penalties for failing to comply with UN Security Council resolutions, typically fines and imprisonment; crypto-specific precedents rare due to nascent regulatory environment UCREF AML/CFT Framework
UN sanctions aim to reduce gang violence, disrupt illicit financing, and support political stability; however, implementation challenges include weak state institutions, limited enforcement capacity, and entrenched criminal networks UN Secretary-General Report on Haiti
US Treasury Haiti Sanctions Review
Penalty Amount: None - this was a public advisory/warning only Cryptopotato Report
Status as of 27 April 2026: The UN sanctions regime under Resolution 2753 has expired (15 October 2025). Available public records do not show a subsequent renewal resolution passed before this date UN Document N2263332
UN Sanctions Committee (Haiti Committee): Established under Resolution 2653 to designate individuals and entities and oversee implementation UN Haiti Sanctions Committee
Haiti Domestic Enforcement: Haiti's domestic laws outline penalties for failing to comply with UN Security Council resolutions, typically involving fines and imprisonment, although specific precedents are rare due to nascent regulatory environment UN Document N2263332
US Sanctions are Distinct: OFAC can designate individuals not on the UN list, targeting broader criteria including corruption and specific human rights abuses with secondary sanctions implications OFAC Haiti Sanctions Program
EU Autonomous Designations: EU may adopt additional autonomous designations mirroring or expanding upon UN/OFAC designations EU Sanctions Map
EU VASP Compliance: VASPs operating in EU must screen against EU Consolidated Sanctions List including Haiti designations EU Consolidated Sanctions List
Global Screening Lists: For VASPs globally, compliance requires screening against the UN Consolidated Sanctions List, the OFAC SDN List (which includes Haiti-specific designations), and the EU Consolidated Sanctions List UN Document N2263332
Haiti's Primary Obligation: Implementing the UN Haiti Sanctions List under Resolution 2653 - Haiti does not have a domestic crypto-specific sanctions list UN Security Council Sanctions
Practical Challenges: UN sanctions aim to reduce gang violence, disrupt illicit financing, and support political stability; however, implementation challenges include weak state institutions, limited enforcement capacity, and political instability UN Document S/2024/123
Focus on Broader Financial Stability: Haiti's enforcement focus appears to be on broader financial stability and anti-money laundering (AML) efforts, rather than specific crypto regulations Cryptopotato Report
Taxation Practicality: For infrequent, small-scale transactions by individuals, enforcement might be challenging, but legally the potential for taxation exists DGI Haiti
VASP Comprehensive Sanctions: VASPs must also avoid facilitating transactions for comprehensively sanctioned jurisdictions (Iran, North Korea, Syria, Cuba, Crimea) regardless of Haiti link OFAC Sanctions Programs
UN Document N2263332 - Haiti Sanctions Resolutions
31 CFR Part 501 - Blocked Property Reporting
No. Haiti has not yet adopted a comprehensive legal and regulatory framework specifically governing Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs), including the FATF Travel Rule. The existing Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) laws do not explicitly cover VASPs CFATF Haiti Mutual Evaluation
Not defined, as the regulatory framework is not in place. The FATF Travel Rule typically applies to transactions above a de minimis threshold (e.g., USD/EUR 1,000), but no such threshold has been established in Haiti FATF Recommendation 16 Standards
Not legally defined or explicitly covered under existing Haitian law. While the FATF definition of a VASP would conceptually apply (any natural or legal person who, as a business, conducts one or more of the following activities or operations for or on behalf of another natural or legal person: exchange between VAs and fiat currencies; exchange between one or more forms of VAs; transfer of VAs; safekeeping and/or administration of VAs or instruments enabling control over VAs; and participation in and provision of financial services related to an issuer's offer and/or sale of a VA), these entities are not yet subject to specific AML/CFT obligations in Haiti CFATF Technical Compliance Re-Rating
As of April 2026, there is no public evidence of significant VASP market activity or registration attempts in Haiti, consistent with the complete lack of regulatory framework Forbes SpaceX IPO
Brazil's recent requirement for banks to verify satellite deforestation data before rural credit approval (as of early 2026) exemplifies the broader Latin American trend of enhanced financial regulation, contrasting with Haiti's regulatory vacuum Brazil Banks Deforestation Verification
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