New Bill Targets Haitian Elites with Mandatory Sanctions, Requires Annual Reports for Five Years

The Haiti Criminal Collusion Transparency Act of 2025 is designed to pull back the curtain on the connection between criminal gangs and powerful figures in Haiti. This bill mandates that the Secretary of State produce a detailed annual report for five years, starting 180 days after enactment, specifically identifying prominent gangs, their leaders, and, crucially, the political and economic elites who have "direct and significant links" to them.

The Mandatory Name-and-Shame List

This isn't just a research project; it’s a direct action plan. The annual report must detail how these elites use their gang connections to advance their political and economic interests, essentially laying out the blueprint for corruption. Think of it as creating a mandatory "Who's Who" of destabilizing forces in Haiti, complete with an assessment of how this collusion threatens both the Haitian people and U.S. interests, as well as listing criminal organizations involved in human trafficking to the U.S. border.

Sanctions: The Automatic Hammer

The real teeth of this bill come in Section 3, which makes sanctions mandatory. Not later than 90 days after the report hits Congress, the President must impose sanctions on every foreign person identified in that report. There’s no wiggle room here—if you are named, you are sanctioned. These sanctions are severe: they include Property Blocking, which means freezing any assets the identified foreign person has under U.S. jurisdiction, and Visa and Entry Restrictions, making them inadmissible to the U.S. and automatically revoking any existing visas. For U.S. citizens or businesses, this means you need to be extremely careful: transacting with a sanctioned individual could land you in hot water, facing penalties described under the International Emergency Economic Powers Act (IEEPA).

Where the President Gets Broad Authority

While the sanctions are mandatory, the bill grants the President considerable power in two areas. First, the property blocking authority is granted via IEEPA, but it bypasses some standard requirements, giving the Executive Branch a quicker path to freezing assets. Second, the President has a Waiver Authority: sanctions can be waived if the President certifies to Congress—just 15 days before the waiver takes effect—that it is "vital to the national security interests of the United States." This means that while the bill forces action, the President retains the ultimate ability to pull the punch if geopolitics require it, a significant power that bypasses typical checks and balances.

Humanitarian Exceptions and the Clock

To avoid punishing the people who are already suffering, the bill explicitly carves out exceptions for humanitarian aid. Sanctions cannot be applied to transactions related to the sale of food, medicine, or medical devices to Haiti, or to providing humanitarian assistance. This is a crucial practical measure designed to keep aid flowing even while the U.S. targets corrupt actors. Finally, this entire Act has a five-year sunset clause, meaning the mandatory reporting and sanctioning authority will expire five years after the bill is signed into law, unless Congress renews it.