The latest sanctions by the OFAC against key figures tied to the Haitian gang coalition Viv Ansanm have brought the financial underbelly of organized violence into sharp focus. The designations of Dimitri Herard and Kempes Sanon mark more than a counterterrorism step. They reveal how gang coalitions in fragile states use money laundering to sustain control, expand influence, and infiltrate legitimate markets under the cover of chaos.

Gang Coalition Money Laundering in Haiti

Viv Ansanm, a coalition of violent gangs that merged their forces in Port-au-Prince, was labeled a Foreign Terrorist Organization earlier this year. The group’s operations extend beyond violent control of neighborhoods; they involve extortion, kidnappings, illicit taxation, and smuggling, which create the raw material for extensive money laundering networks.

The case of Herard and Sanon provides a rare window into the financial mechanics of such alliances. Through illicit revenue streams and cross-border laundering, these networks create financial systems that rival state institutions. The money that funds extortion, weapons, and political influence is not left in plain sight. It is washed through complex layers of intermediaries, hidden behind diaspora remittances, shell companies, and informal value transfer systems that evade regulatory scrutiny.

This laundering ecosystem not only keeps Haiti’s gangs financially resilient but also fuels corruption, distorts aid flows, and undermines the effectiveness of anti-money laundering (AML) frameworks. Understanding these patterns is essential for financial institutions and regulators tasked with detecting and disrupting gang-linked financial flows.

How Illicit Proceeds Become Financial Power

The money laundering backbone of Viv Ansanm is built on several mechanisms that transform street-level proceeds into concealed, spendable wealth.

Extortion and Illicit Taxation
The starting point is territorial control. Gangs extract “taxes” on goods, fuel deliveries, and even humanitarian aid passing through areas they dominate. Businesses pay protection money. Trucks pay tolls at makeshift checkpoints. Cash accumulates rapidly, often exceeding the capacity of any single gang to store or manage it. This creates a natural need to launder. Funds enter informal trade circuits, are spent on fuel resales, or move through friendly merchants who blend the cash into legitimate sales.

Diaspora and Remittance Flows
Diaspora remittances are among Haiti’s largest foreign inflows. Gang networks exploit this legitimate channel by masking transfers through informal money transmitters. Some front-line collectors pose as relatives of recipients, while others operate shell “charity” groups claiming to fund local initiatives. The money enters Haiti as legitimate remittances and exits as operational funding for gang activities. It is nearly impossible for remittance providers without enhanced due diligence to distinguish family transfers from criminal ones.

Informal Value Transfer and Mobile Money
With banking services scarce and unreliable, gangs use couriers, hawala-style networks, and mobile payment apps. Small transactions under regulatory thresholds create an illusion of benign personal transfers. Dozens of micro-payments are structured to aggregate into significant sums without triggering alerts. In certain cases, gang affiliates abroad receive crypto payments which they convert locally into cash through intermediaries who provide anonymity in exchange for a commission.

Real Assets and Trade-Based Laundering
Illicit cash is also converted into tangible goods and properties. Used vehicles, spare parts, and fuel storage facilities serve dual roles: laundering instruments and operational assets. Some front businesses, such as construction or logistics companies, are used to issue false invoices, creating a paper trail that legitimizes criminal proceeds. Over-invoicing imports or under-reporting exports facilitates value transfer without moving money, a method often overlooked in weakly supervised economies.

Integration and Political Influence
Once funds are sufficiently layered, they are reintroduced into the local economy through business ventures, campaign donations, or real estate projects. This integration step turns illicit money into influence. When gangs sponsor local officials or security forces, they transform laundering into political leverage, shielding their financial operations from oversight and prosecution.

Financial System Exposure and AML Gaps

From an AML perspective, the Viv Ansanm case underscores systemic vulnerabilities that extend well beyond Haiti’s borders.

Fragile-State Blind Spots
Haiti’s financial system suffers from minimal compliance capacity and limited transaction monitoring. Banks are often forced to rely on outdated customer identification procedures and manual review processes. Correspondent banks abroad, wary of reputational risk, are increasingly reluctant to process Haitian transactions. This de-risking environment pushes more flows underground, amplifying the very informal networks gangs exploit.

Sanctions Evasion as a Laundering Strategy
OFAC’s designation of Viv Ansanm and its affiliates under Executive Order 13224 blocks property and prohibits transactions with U.S. persons. Yet the enforcement challenge lies in the indirect channels. Funds move through third-country intermediaries or non-bank remitters outside the reach of direct U.S. jurisdiction. Sanctions evasion combines with layering to blur the trace of funds, particularly when digital assets or trade transactions are involved.

Diaspora Financial Intermediaries
The Haitian diaspora, concentrated in North America and the Caribbean, provides both legitimate remittances and potential conduits for abuse. Informal transfer operators often lack compliance training or technical capacity to implement transaction monitoring. Criminal facilitators take advantage of social trust and linguistic familiarity, sending large sums disguised as community donations or business investments.

Lack of Beneficial Ownership Transparency
Shell companies registered in neighboring jurisdictions or small Caribbean financial centers provide anonymity for assets linked to gang financiers. Without effective beneficial ownership registries, tracing the ultimate controllers of these entities remains challenging. Funds laundered through such entities can later be reinvested in regional real estate or maritime operations, creating clean-looking investment portfolios that conceal illicit origins.

Weak Coordination Between AML and Sanctions Systems
While the sanctions regime isolates key individuals, effective disruption requires integration with AML frameworks. Suspicious transaction reporting, cross-border cooperation, and financial intelligence sharing remain fragmented. In fragile jurisdictions, financial intelligence units often lack secure channels or technical capacity to analyze complex data flows. As a result, actionable intelligence on gang-linked transactions rarely reaches regulators or law enforcement in time.

Lessons for Financial Institutions and Compliance Officers

The Viv Ansanm case is more than a geopolitical issue; it is a compliance stress test. Financial institutions must recognize that criminal-terrorist coalitions can evolve faster than traditional AML systems can adapt. Several lessons emerge from this episode.

Enhanced Due Diligence on High-Risk Jurisdictions
Institutions dealing with clients or counterparties connected to Haiti should treat all transactions as high-risk and apply enhanced due diligence. Geographic risk mapping must extend beyond national borders to include remittance corridors, diaspora communities, and regional hubs where Haitian-linked businesses operate.

Transaction Pattern Analysis Beyond Thresholds
Relying solely on large transaction alerts misses structured activity. Sophisticated laundering often relies on micro-transfers. Machine learning and behavioral analytics can identify irregular frequency, velocity, and network relationships that signal hidden layering.

Trade Finance and Humanitarian Aid Oversight
Banks facilitating trade to or from Haiti must apply rigorous scrutiny to documentation, shipment values, and ultimate beneficiaries. Given reports of diverted humanitarian containers, financial institutions involved in NGO funding should require independent verification of project partners and end-use tracking to prevent laundering under humanitarian cover.

Crypto and Alternative Payment Monitoring
Digital assets are increasingly used to bypass geographic constraints. Compliance teams should deploy blockchain analytics to trace wallet clusters linked to sanctioned individuals. Even where crypto use is minimal, monitoring cross-border peer-to-peer transactions can reveal early indicators of sanctions evasion.

Integrating Sanctions Screening and AML Monitoring
OFAC designations should not remain siloed in sanctions databases. Screening tools must be dynamically connected to transaction monitoring systems, enabling real-time interdiction when a transfer matches known aliases, locations, or behavioral signatures of designated entities.

Staff Awareness and Governance
Frontline staff, particularly in remittance and correspondent banking divisions, must understand the typologies specific to fragile-state laundering. Regular training on emerging risks and typology red flags is essential. Governance frameworks must ensure that AML escalation procedures function even in cases involving politically sensitive clients or humanitarian intermediaries.

Collaboration with Intelligence Agencies and NGOs
Cross-sector collaboration is key. Humanitarian organizations often observe financial irregularities in the field that can inform AML investigations. Regulators and FIUs should formalize mechanisms for safe intelligence exchange, balancing confidentiality with operational necessity.

Secondary Sanctions Risk Management
Foreign financial institutions facilitating transactions for sanctioned persons may face secondary sanctions. Risk assessments should include exposure analysis for all correspondent relationships and payment routing chains. Internal audits should verify compliance with OFAC’s strict liability standards.

A Broader Reflection on Financial Crime in Fragile States

The Viv Ansanm network exposes a critical evolution in global money laundering. Traditional typologies based on organized crime or terrorism alone no longer suffice. Gangs that merge territorial control with political influence now operate hybrid models of financial crime.

Their operations resemble insurgent economies—self-funding through extortion, protection, and smuggling, but sophisticated in laundering their proceeds. They exploit regulatory vacuums, leverage technology, and mimic legitimate business behavior. For AML systems, this hybridization poses unique detection challenges.

The overlap between organized crime, terrorism financing, and corruption in fragile states suggests a need for systemic recalibration. AML frameworks must evolve from transaction-based compliance toward intelligence-driven disruption. Risk-based approaches should incorporate socio-political dynamics, including the degree of non-state control over territory and infrastructure.

In Haiti, this means recognizing that gangs do not merely commit predicate offenses; they function as shadow financial systems. Every illicit tax, every smuggled fuel container, and every diverted aid shipment feeds an economy that operates parallel to the state. Money laundering here is not an end—it is governance by another name.

To counter it, global cooperation must bridge the divide between development policy, sanctions enforcement, and financial intelligence. Building capacity in fragile jurisdictions, enforcing transparency in regional financial centers, and tightening correspondent oversight form the backbone of sustainable disruption. The lesson of Viv Ansanm is clear: as long as illicit networks can launder, they can rule.

---

Related Links

• U.S. Department of State – Designation of Viv Ansanm as a Foreign Terrorist Organization
• United Nations Security Council – Sanctions Information on Haiti
• Financial Crimes Enforcement Network – Sanctions Compliance Guidance
• Global Initiative – Analysis of Criminal and Terrorist Finance in Haiti

Other FinCrime Central Articles About Terrorism Financing

• BNP Paribas Faces Renewed AML Scrutiny Over Terrorism Financing Case
• Global Charity Laundering Exposed Khalistani and Islamist Networks Funding Terror
• Hezbollah’s Secret Car Trade Networks in Canada Fuel Billions in Dirty Money

Source: US Treasury

Some of FinCrime Central’s articles may have been enriched or edited with the help of AI tools. It may contain unintentional errors.

Want to promote your brand, or need some help selecting the right solution or the right advisory firm? Email us at info@fincrimecentral.com; we probably have the right contact for you.