OFAC Sanctions Expose the Financial Networks Powering Haiti’s Gang Coalition Viv Ansanm

The latest sanctions imposed by the U.S. Office of Foreign Assets Control (OFAC) against prominent figures linked to the Haitian gang coalition Viv Ansanm have illuminated the deep financial machinery sustaining organized violence in Haiti. The designations of Dimitri Herard and Kempes Sanon represent more than a counterterrorism measure—they expose the sophisticated ways in which gang coalitions in fragile states manipulate money laundering systems to maintain dominance, expand their reach, and infiltrate legitimate markets under a cloak of disorder.

Viv Ansanm, a coalition of armed gangs that unified their operations across Port-au-Prince, was designated as a Foreign Terrorist Organization earlier this year. Beyond exerting violent territorial control, the group engages in extortion, kidnappings, illicit taxation, and smuggling—activities that generate vast illicit revenues fueling a multilayered laundering apparatus. The cases of Herard and Sanon provide a rare insight into how these financial networks operate, transforming criminal proceeds into hidden reserves of economic and political power. Their system relies on cross-border laundering, the misuse of remittance channels, and the concealment of funds through shell entities and informal value transfer systems that evade regulation.

This laundering infrastructure not only ensures the gangs’ financial endurance but also perpetuates corruption, distorts humanitarian aid, and weakens anti-money laundering (AML) frameworks already stretched thin. For regulators and financial institutions, the patterns emerging from Viv Ansanm’s operations illustrate how fragile-state dynamics can create self-sustaining criminal economies.

At the foundation of Viv Ansanm’s financial engine lies a sequence of mechanisms that turn raw street proceeds into legitimized capital. Territorial control allows gangs to extract “taxes” on everything from goods and fuel to humanitarian supplies entering their zones. Businesses pay protection fees; transporters are charged at improvised checkpoints. The resulting influx of cash often surpasses the storage capacity of any single faction, necessitating laundering. The money circulates through informal trade, is reinvested in fuel resale, or is passed to friendly merchants who fold it into legitimate transactions.

Remittance flows from the Haitian diaspora—one of the country’s largest sources of foreign income—are another critical channel. Criminal networks camouflage illicit transfers among legitimate remittances, using informal transmitters or setting up fake charities that claim to support local initiatives. Some collectors even impersonate relatives of recipients. This tactic converts crime proceeds into lawful-looking funds that reenter Haiti as family support, later redirected to sustain gang operations.

Given Haiti’s limited banking infrastructure, gangs also rely heavily on informal value transfer systems and mobile payment platforms. Through couriers, hawala-style arrangements, and micro-transactions, they break large sums into smaller units that escape detection thresholds. Structured payments create a façade of everyday personal transfers. In some cases, affiliates receive cryptocurrency payments abroad and convert them locally through intermediaries who ensure anonymity in exchange for a cut.

Illicit cash is further funneled into tangible assets—vehicles, construction materials, real estate, and fuel depots—that serve both operational and laundering purposes. Front companies, often registered as logistics or construction firms, issue fraudulent invoices to fabricate legitimate business activity. Trade-based laundering, such as over- or under-invoicing imports and exports, facilitates value transfer without moving funds, an approach frequently overlooked in jurisdictions with weak oversight.

Once the layering is complete, the funds are reintegrated into the legitimate economy through political donations, real estate projects, or local business ventures. This stage transforms dirty money into influence. When gang leaders sponsor officials or collaborate with law enforcement, laundering becomes a form of political protection, insulating their networks from scrutiny.

From an AML standpoint, the Viv Ansanm case underscores vulnerabilities extending far beyond Haiti’s borders. The country’s financial institutions, constrained by limited resources and outdated compliance systems, struggle to detect suspicious activity. Manual transaction reviews and insufficient customer verification leave significant blind spots. Meanwhile, foreign correspondent banks, wary of reputational damage, have scaled back services—forcing more financial flows into unregulated channels that gangs readily exploit.

Even as OFAC’s designations under Executive Order 13224 freeze assets and restrict dealings with U.S. persons, enforcement remains difficult. Funds continue to move through intermediaries in third countries or through informal networks beyond U.S. jurisdiction. Sanctions evasion merges with sophisticated layering to obscure origins, particularly when digital assets and trade mechanisms are involved.

The Haitian diaspora, concentrated in North America and the Caribbean, remains both a vital economic lifeline and a potential weak point. Informal remittance operators often lack compliance expertise, creating opportunities for manipulation by trusted community members posing as philanthropists or investors. Shell companies registered in nearby financial centers add another layer of opacity, as limited beneficial ownership transparency prevents investigators from tracing ultimate controllers. Through these entities, gang-linked financiers reinvest proceeds into regional real estate, maritime operations, or import-export schemes, creating portfolios that appear legitimate.

A further challenge lies in the disconnection between AML enforcement and sanctions regimes. While the designations isolate individuals, effective disruption demands synchronized data sharing, suspicious activity reporting, and intelligence exchange—functions that remain fragmented across Haiti’s fragile institutions. Financial intelligence units often lack the tools or secure systems necessary to process complex data, meaning actionable insights rarely reach enforcement agencies in time.

For global financial institutions, the Viv Ansanm sanctions serve as a stress test for compliance resilience. Institutions with exposure to Haiti or its regional trade partners must apply enhanced due diligence and expand geographic risk mapping to include diaspora corridors and secondary hubs. Transaction monitoring should move beyond threshold-based alerts, focusing on behavioral patterns, frequency, and relational networks that indicate structured activity.

Trade finance connected to Haiti requires close inspection of shipment documentation, valuation accuracy, and end beneficiaries, especially amid reports of humanitarian diversion. Banks handling aid disbursements should demand independent verification to ensure funds are not diverted under charitable cover. In the digital realm, blockchain analytics and peer-to-peer transaction monitoring are vital for tracing crypto wallets tied to designated entities.

OFAC sanctions screening must also integrate dynamically with AML monitoring to enable real-time detection of suspicious behavior linked to aliases or known gang identifiers. Governance and training are equally crucial—frontline staff in remittance and correspondent banking divisions must be aware of fragile-state laundering typologies and escalation protocols for politically sensitive accounts.

Collaboration with intelligence agencies and humanitarian organizations can enhance detection by leveraging on-the-ground insights into irregular funding flows. Regulators should formalize data-sharing arrangements that protect confidentiality while supporting enforcement. Moreover, banks must account for secondary sanctions exposure, auditing all correspondent and routing relationships to ensure compliance with OFAC’s strict liability standards.

The Viv Ansanm episode marks a pivotal moment in the understanding of financial crime within fragile states. It demonstrates how hybrid networks—part criminal, part political—use financial systems not merely to enrich themselves, but to govern. These gangs operate as parallel economies, extracting taxes, smuggling fuel, and diverting aid to fund their regimes. Money laundering, in this context, is not just a concealment strategy; it is a mechanism of power.

Confronting such networks requires a holistic approach that links financial intelligence, sanctions enforcement, and development policy. Strengthening capacity in fragile jurisdictions, enforcing transparency in regional financial centers, and tightening global correspondent oversight are essential. The lesson from Viv Ansanm is stark: as long as illicit actors can launder their money, they can rule from the shadows.

By fLEXI tEAM