Haiti - Gangs : Increased surveillance of financial transactions in the Haitian banking system

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Haiti - Gangs : Increased surveillance of financial transactions in the Haitian banking system
31/07/2025 09:50:29

Following the designation by the Office of Foreign Assets Control (OFAC) of certain Haitian armed groups as "foreign terrorist organizations" and "global terrorists," and subsequently by the United Nations Security Council under Resolution 2653 (2022), the Bank of the Republic of Haiti (BRH) calls on financial institutions to be vigilant and requests them to strengthen their oversight mechanisms, implement additional controls, and conduct thorough due diligence to detect any attempt by designated groups or individuals, or third parties acting on their behalf, to directly or indirectly use the financial system to launder illicit funds.

More specifically, each financial institution is requested, as part of its normal operations :

1 - Strengthen its transaction monitoring mechanisms, including alerts generated by screening tools, to identify any direct or indirect links with the designated individuals or entities;

2 - Implement additional controls to detect potential intermediaries or facilitators (individuals or legal entities) who may have helped these individuals access the national or international financial system, paying particular attention to:

- Unusual or structured transfers;
- Newly opened accounts in high-risk regions;
- Changes in beneficial ownership.

3 - Conduct in-depth due diligence when entering into relationships or processing unusual transactions, particularly in high-risk areas or sectors, or involving Politically Exposed Persons, close associates, or beneficial owners of designated individuals, including :

- Targeted online searches on related individuals, companies, or entities;
- Negative media checks to identify any exposure to accusations of financial crime, terrorism, or related networks;

- Offline research to enhance its risk assessment, including :

i. Consultation of public documents (commercial register, court decisions, printed press);
ii. Contact with institutional sources (financial intelligence, regulators);
iii. Interviews or requests for information from local business partners;
iv. On-site visits.

4 - Documents expanded due diligence and retains any relevant information identified during these processes.

5 - Promptly reports to the Central Financial Intelligence Unit (UCREF) any suspicious transactions or attempted use of the financial system by third parties potentially acting on behalf of designated persons, in accordance with suspicious transaction reporting requirements.

6 - Conducts a reassessment of the integrity and good repute of the beneficial owners of all companies serving as sub-agents under Circulars 114-3 and 121.

7 - Maintains transparent and proactive communication with their foreign correspondents, providing them with relevant information on the measures taken to mitigate risks.

HL/ HaitiLibre