Overview:
As part of the 2026 National Defense Authorization Act, Congress passed a landmark provision requiring the U.S. government to investigate and sanction Haitian elites who collaborate with criminal gangs. The move comes amid a widening U.S.-led crackdown on corruption and gang financing, which has already resulted in arrests and sanctions against prominent figures such as Dimitri Vorbe and Pierre Réginald Boulos.
Congress passed Wednesday, Dec. 17the Haiti Criminal Collusion Transparency Act of 2025, a new provision embedded in the 2026 National Defense Authorization Act (NDAA), marking a significant shift in United States foreign policy toward Haiti.
The law mandates the U.S. government to investigate, report on and impose sanctions against political and economic elites in Haiti who have colluded with violent gangs. Within 180 days of the law’s enactment, the Secretary of State must submit a report to Congress identifying prominent gangs, their leaders and their ties to elite actors. Sanctions, including asset freezes and visa revocations, are to be imposed within 90 days of the report’s release.
Faith in Action International, an advocacy group, praised the legislation as a “potential turning point for Haiti” and urged U.S. officials to fully implement the law, including sanctions on influential individuals accused of financing gangs.
The act also calls for a detailed annual report to expose the relationships between criminal gangs and the political and economic elites in Haiti.
The report is designed to be a “shining light” on corruption and must contain several specific components:
- Gang Identification: A list of prominent criminal gangs, their leaders, their specific criminal activities (including coercive recruitment), and their primary areas of operation.
- Linkage List: A list of political and economic elites in Haiti who have “direct and significant links” to these criminal gangs. Any organizations or entities controlled by these elites.
- Detailed Descriptions: A comprehensive explanation of the relationships between elites and gangs. Analysis of how elites use gang affiliations to advance political and economic interests and agendas.
- Border Security Assessment: Identification of criminal organizations involved in trafficking Haitian and other individuals to the U.S. border.
- Transnational Connections: An assessment of connections among Haitian elites, domestic gangs, and transnational criminal organizations
- Impact Analysis: An assessment of how this collusion threatens the Haitian people and U.S. national security interests.
- Proposed Actions: Recommendations for actions that both the U.S. and Haitian governments could take to address the findings.
The Haiti Criminal Collusion Transparency Act authorizes two primary categories of sanctions against foreign individuals identified as having significant links to criminal gangs in Haiti: financial sanctions and travel restrictions.
Under the property blocking provision, the president is empowered to freeze all property and interests in property belonging to sanctioned individuals if those assets are located in the United States, enter the U.S., or are held or controlled by a U.S. person, including foreign branches of U.S.-based entities. This measure effectively prohibits the sanctioned individuals from conducting any financial transactions involving U.S. institutions or assets. The authority is grounded in the International Emergency Economic Powers Act and is designed to cut off access to global financial systems for those fueling instability in Haiti.
The law also imposes strict visa restrictions. Sanctioned individuals are deemed inadmissible to the U.S. and are barred from receiving any visa or entry documentation. For those who already possess such documents, immediate revocation is mandated. This revocation also automatically nullifies any other valid visas or travel authorizations they may hold. These measures aim to isolate individuals who, despite facing serious allegations, have often continued to travel freely or maintain residences abroad—including in the U.S.
The bill’s passage coincides with a wave of U.S. enforcement actions targeting members of Haiti’s political and business elite. In September, federal immigration agents arrested Dimitri Vorbe, a powerful businessman whose family controls SOGENER, one of Haiti’s largest private power companies. Authorities suspect Vorbe of gang financing and noted his family’s deep ties to both political and business networks in Haiti.
Key Timeline:
- August 1, 2025: Senator Jeanne Shaheen submitted this amendment (the “Haiti Criminal Collusion Transparency Act of 2025”) to be included in the NDAA.
- October 9, 2025: The Senate initially passed an amended version of the bill.
- December 17, 2025: Following negotiations between the House and Senate, the final compromise version of the NDAA passed the Senate.
- Current Status: The bill has been sent to the President’s desk for his signature to become law.
Vorbe’s arrest followed the detention of another elite figure, Pierre Réginald Boulos, in July. Boulos, a businessman and former presidential hopeful, was taken into custody on allegations including gang support, immigration fraud and corruption. According to ICE, Boulos failed to disclose ties to political organizations and gang-related violence during his U.S. residency application.
“There is not much love lost in Haiti either for Dimitri Vorbe or Réginald Boulos, or many of the elite families,” said Jake Johnston, international research director at the Washington-based Center for Economic and Policy Research, in a September 2025 interview with the Associated Press. “Many people will cheer it in a country with a broken judicial system as it’s some sliver of accountability, (but) we don’t know what any of this is for. … How does this all fit together into a strategy that actually benefits Haiti?”
The U.S. has also imposed sanctions on several former Haitian officials, including ex-parliamentarians Arnel Bélizaire and Antonio “Don Kato” Chéramy, citing corruption and interference in democratic institutions. Both men were political allies of elite business families and allegedly used their positions to support destabilizing activities.
In a September statement, Deputy Secretary of State Christopher Landau said the U.S. would remain “relentless in pursuing those supporting terrorist gangs through indictments, arrests, sanctions, arms seizures and other immigration restrictions.”
While the U.S. crackdown is seen by many as long overdue, Haitian observers warn that sanctions and arrests abroad must be accompanied by local enforcement to achieve lasting impact.
“This pattern of impunity sends a dangerous signal,” said Wilner Exantus, a Port-au-Prince resident, in a September interview with The Haitian Times. “If foreign governments sanction our leaders but Haiti’s own justice system does nothing, the corruption and violence will never end.”
The Haiti Criminal Collusion Transparency Act gives the U.S. executive branch broad authority to investigate and sanction elites, but also includes safeguards for humanitarian aid to continue flowing into Haiti. The law is set to sunset in five years.
Faith in Action and other advocacy groups say the legislation also strengthens the case for extending Temporary Protected Status for Haitians in the U.S., citing worsening violence, airport closures and unsafe conditions for deportees.
“This law acknowledges the real sources of Haiti’s instability,” the organization said. “It should be a starting point for rethinking U.S. policy in the region to support civil society and real democratic governance in Haiti.”
The bill has been sent to President Donald Trump’s desk for signature today.
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