In the first quarter of 2025, at least 1 617 people were killed in Haiti. As the gangs have tightened their grip over the country, the need for aid is intensifying – more than a million people have been displaced and more than half of the population needs humanitarian assistance, a 9 per cent increase against 2024. Criminal groups have recently launched new offensives, particularly in the Central Plateau and Artibonite regions. The population of these areas risk joining the millions in the capital, Port-au-Prince, who already live under the de facto authority of gangs. 

In this constantly deteriorating situation, on 2 May 2025 the United States designated the Viv Ansanm gang coalition and the Gran Grif gang as foreign terrorist organizations and specially designated global terrorists. The measures bar members of the designated gangs from accessing financial institutions with a US link, and from being issued visas. They also provide for potential legal action and secondary sanctions against individuals or organizations providing various forms of support to the gangs.  

The action is the latest use of counterterrorism measures as a tool to combat organized crime, building on a previous tranche of US designations targeting Latin American gangs and cartels. However, the US designations may inadvertently worsen the situation on the ground by impeding humanitarian assistance, strengthening gang governance and empowering broader criminal networks. This may drive further entrenchment of designees in the illicit political economy. But in the short term, the most pressing concern is whether the US designations will prevent Haitian and international NGOs from continuing to deliver aid to communities in gang-controlled areas that lack public services.  

For NGOs working in areas under gang control in Haiti, as in other locations, negotiating access with criminal leaders is often a necessary condition for reaching affected populations. In such contexts, it is these non-state actors (and not official authorities) who dictate the terms of engagement, effectively exercising control over communities and restricting humanitarian access. Under prevailing sanctions regimes, these dynamics expose humanitarian organizations to legal and reputational risks, including potential liability for engaging – even indirectly – with sanctioned or criminal entities.  There is therefore growing concern within the aid community that organizations could lose funding or face legal risks – including prosecution. Under the terrorist designation, the assistance they provide could now be classified as ‘material support’ to terrorist groups. 

The inability to provide assistance could also indirectly deepen gang governance. If people find themselves even more isolated than they are today, living under the thumb of criminal leaders, the bargaining power of those bosses will be strengthened. Gangs are also likely to increase the pressure they exert through widespread extortion and territorial expansion to secure their sources of income. Finally, a halt to humanitarian support could be used by criminal leaders as another element of propaganda against international action in Haiti, which Viv Ansanm regularly condemns as foreign interference. 

‘Invisible’ exemptions  

US policy provides mechanisms to mitigate these risks, to the extent that exemptions exist to allow humanitarian activities to continue in such contexts. In December 2022, the US Department of the Treasury’s  Office of Foreign Asset Control (OFAC) issued a series of general licences that authorize certain humanitarian activities that might otherwise be prohibited under US sanctions programmes, including those targeted at terrorist actors. These were introduced as part of the implementation of the UN’s Security Council resolution 2664, which authorized a humanitarian exemption to asset freezes in various UN sanctions regimes.  

The issuing of these licences underscores the US government’s recognition of the complexities involved in conducting humanitarian operations in sanctioned jurisdictions. In the past, such measures have been taken to ensure that the provision of humanitarian aid is not impeded by overly stringent sanctions enforcement. Notably, the licences are self-executing, meaning that entities or individuals who reasonably determine that their activities fall within the scope of the authorization may proceed without needing to obtain pre-approval or additional guidance from the OFAC. 

Alarmingly, however, and reflecting the wider lack of strategic coherence currently blighting Haiti, whether these exemptions continue to apply in the face of the new designations does not appear to have been communicated to the humanitarian sector – either by the US authorities, the Haitian government or international partners.  

Therefore, despite this legal framework, there are concerns about its implementation on the ground, particularly in Haiti. The Trump administration’s commitment to the general licences issued under the Biden administration is uncertain. There is also lack of clarity in terms of how and to what extent NGOs working in Haiti are familiar with or can rely on the general licences. And questions remain about the coordination of these efforts with the Haitian authorities. The lack of a clearly articulated and coordinated strategy casts doubt on the effectiveness of these measures in practice. 

Fuelling the underworld?  

From a more structural perspective, the ability of humanitarian actors to carry out their operations is directly linked to their ability to access international financial services, which could be cut off or hampered in the context of sanctions. The perceived legal and operational risks associated with sanctions compliance may lead financial institutions and money transfer companies to scale back or even withdraw from Haiti. For example, companies such as Western Union may reduce or cease operations in the country due to potential exposure under US law, even if their activities are technically authorized.  

The broader concern is that a strict or inconsistent interpretation of sanctions might lead to widespread de-risking, whereby financial institutions disengage entirely from high-risk regions. Unable to use formal banking channels, NGOs are often forced to rely on informal systems, increasing operational risks and reducing oversight.  

This constrained operating environment also creates space for criminal networks and illicit actors to exploit the aid vacuum, which in the medium and long term could expand rather than constrain the power and scope of the gangs and associated illicit economies in Haiti. 

Regulated financial channels are heavily used by the diaspora to send remittances and by Haitian businesses to move funds. With those potentially blocked, unregulated intermediaries – including some fintech companies and money services businesses – could step in to facilitate transactions, potentially without adequate scrutiny. This not only hampers humanitarian access, but also risks increasing informality, further weakening local institutions and strengthening criminal financing structures. 

Previous research by the Global Initiative Against Transnational Organized Crime (GI-TOC) has underscored how far-reaching sanctions have a shaping impact on criminal economies – such as in Guinea-Bissau and the Central African Republic – with criminal actors exploiting new opportunities for profit. Moreover, the experience of Somalia provides a relevant comparative example. In response to the terrorist designation of al-Shabaab by the US, the UN and others in the international community, major banks cut ties with Somali money services businesses and clients, leading to a significant reduction in formal financial access. This, in turn, affected remittances from the diaspora and increased reliance on informal financial networks, which are more vulnerable to exploitation by criminal actors and can facilitate money laundering and other illicit activities.  

In the case of Somalia, de-risking in response to the terrorist designation arguably exacerbated rather than mitigated the risks posed by terrorism and criminality, such as by expanding financial channels used for arms trafficking. In the Haitian context, it is critical that US authorities engage with banks and money services businesses to prevent such de-risking. At the same time, however, humanitarian actors should prepare for the possibility of disruptions to remittances and financial access, and consider how this might affect humanitarian needs and their own operations. 

A 180-degree turn is urgently needed 

Without appropriate safeguards, the terrorist designations risk further destabilizing Haiti and inadvertently empowering gang structures, which previous GI-TOC research suggests are likely to remain largely unaffected by sanctions alone. And, without coordination with a clear security and judicial strategy, particularly to dismantle political-criminal networks, the designations risk becoming yet another policy tool that is poorly used or not used at all.  

It is troubling that these designations have not been accompanied by robust engagement, strategic coordination or technical support from the United States, the Haitian authorities and the international community. Immediate action is needed to provide clarity, facilitate the work of NGOs and ensure the continued delivery of life-saving assistance to a population whose latest misfortune is to have been left vulnerable to the rule of armed criminal groups.