Haiti
Retail_Trading_Status
- Analysis ID
- #680
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- Latest
- Created
- 2025-12-12 04:22
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- a05f4526...
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Executive Summary
Retail cryptocurrency trading is legally permitted in Haiti due to the absence of specific prohibitory legislation, placing it in an unregulated status. The Banque de la République d'Haïti (BRH) has not issued a licensing regime for Virtual Asset Service Providers (VASPs) nor has it explicitly banned banks from processing crypto-related transactions, though strict foreign exchange controls complicate fiat on-ramps. The country is currently under increased monitoring by the FATF (Gray List), which pressures the government to eventually enact VASP regulations to address anti-money laundering (AML) deficiencies. Currently, citizens can buy, sell, and hold digital assets, but they do so without consumer protections or local recourse.
Key Pillars
Banque de la République d'Haïti (BRH) - Primary financial regulator, currently focused on FX stability and traditional AML.
Unité Centrale de Renseignements Financiers (UCREF) - Financial intelligence unit responsible for AML/CFT enforcement, likely to cover crypto under broad asset definitions.
No Specific VASP License - There is currently no registration or licensing framework for crypto exchanges.
General AML/CFT Laws - The Decree of April 30, 2023, strengthens the AML framework but lacks specific implementation details for virtual assets.
Landmark Laws
Decree Sanctioning Money Laundering and Terrorist Financing (Decree of 30 April 2023) - Enacted: 2023-04-30
- A broad AML/CFT law intended to align Haiti with FATF standards. While it covers 'assets' generally, it does not yet have specific by-laws or circulars operationalizing the regulation of Virtual Asset Service Providers (VASPs).
- Source
Law on Money Laundering and Terrorist Financing (Law of 11 November 2013) - Enacted: 2013-11-11
- The foundational AML law. Circular 100-3 (2022) updates compliance measures for banks under this law but does not explicitly mention cryptocurrency prohibitions.
- Source
Regulation on Money Exchange Agents (Law 114-2 / Circular 114-3) - Enacted: 2020-09-18
- Mandates that money transfer agents pay out remittances in Haitian Gourdes (HTG) rather than USD. This creates a significant operational barrier for crypto exchanges relying on USD liquidity or remittances.
Considerations
FATF Gray List Status: Haiti is under 'increased monitoring' by the FATF, creating high pressure to regulate VASPs soon.
Foreign Exchange Controls: Strict rules forcing conversion of remittances to Gourdes (HTG) make operating a local USD-denominated crypto exchange difficult.
Infrastructure Barriers: High electricity costs ($0.33/kWh) and unstable internet make mining and reliable trading operations challenging.
Lack of Banking Support: While not legally banned, local banks are extremely risk-averse due to de-risking by correspondent banks, making crypto-related wire transfers difficult.
Consumer Protection: No safety nets exist; users have no recourse against fraud or exchange insolvency.
Notes
The 'Allowed-UnRegulated' status is precarious. Given Haiti's position on the FATF Gray List, the government is obligated to implement VASP regulations. This often results in a sudden shift to 'Allowed-Regulated' or 'Gray-Zone' (if they impose a bank ban as a stopgap). Analysts should monitor CFATF plenary outcomes for Haiti closely.
Remaining Uncertainties
- Timeline for the introduction of a specific VASP law to satisfy FATF Recommendation 15.
- Whether the 'Digital Gourde' CBDC project will be accompanied by a ban on private cryptocurrencies when/if it launches.
- The extent to which local banks are informally blocking crypto transactions despite the lack of a formal circular.
Detailed Explanation
Detailed Explanation
Retail cryptocurrency trading is legally permitted but unregulated in Haiti, a status defined by the absence of specific prohibitory legislation. The Banque de la République d'Haïti (BRH), the primary financial regulator, has not established a licensing or registration framework for Virtual Asset Service Providers (VASPs), nor has it explicitly forbidden banks from engaging with crypto-related transactions. Consequently, citizens can buy, sell, and hold digital assets, but they operate without formal consumer protections or local recourse in cases of fraud or exchange insolvency. The regulatory landscape is primarily shaped by existing anti-money laundering (AML) and counter-terrorist financing (CFT) laws, which apply broadly to financial activities. The foundational Law on Money Laundering and Terrorist Financing of 11 November 2013 provides the initial framework, while the more recent Decree Sanctioning Money Laundering and Terrorist Financing of 30 April 2023 aims to strengthen Haiti's alignment with international standards, though it lacks specific implementing rules for virtual assets. The Unité Centrale de Renseignements Financiers (UCREF) serves as the financial intelligence unit responsible for AML/CFT enforcement and is likely to interpret its mandate to cover crypto assets under these broad legal definitions. However, significant practical barriers exist. Strict foreign exchange controls, notably enforced by the Regulation on Money Exchange Agents (Law 114-2 / Circular 114-3) enacted on 18 September 2020, mandate that remittances be paid out in Haitian Gourdes (HTG) rather than US dollars. This creates a major operational hurdle for establishing local USD-denominated crypto exchanges and complicates fiat on-ramps. Furthermore, local banks, while not legally prohibited from processing crypto transactions, are extremely risk-averse due to de-risking pressures from international correspondent banks, making wire transfers for crypto activities difficult. The country's precarious 'Allowed-Unregulated' status is under significant international pressure, as Haiti is currently on the Financial Action Task Force's (FATF) 'Gray List' for increased monitoring. This status obligates the government to address AML deficiencies, which will likely lead to the eventual enactment of specific VASP regulations, potentially causing a sudden shift in the regulatory landscape. Analysts are advised to monitor developments closely, particularly outcomes from Caribbean Financial Action Task Force (CFATF) plenaries.
Summary Points
I. Regulatory Status
* Retail cryptocurrency trading is legally permitted but unregulated.
* There is no specific licensing or registration framework for Virtual Asset Service Providers (VASPs).
* The status is considered precarious due to Haiti's placement on the FATF Gray List (increased monitoring), which pressures the government to enact regulations.
II. Key Regulatory Bodies
* Banque de la République d'Haïti (BRH): The primary financial regulator, focused on foreign exchange stability and traditional AML. It has not issued a VASP licensing regime.
* Unité Centrale de Renseignements Financiers (UCREF): The financial intelligence unit responsible for AML/CFT enforcement; its broad mandate is likely to cover virtual assets.
III. Important Legislation
* Decree Sanctioning Money Laundering and Terrorist Financing (Decree of 30 April 2023): A broad AML/CFT law intended to align with FATF standards. It covers 'assets' generally but lacks specific by-laws for operationalizing VASP regulation.
* Law on Money Laundering and Terrorist Financing (Law of 11 November 2013): The foundational AML law. Associated Circular 100-3 (2022) updates bank compliance but does not explicitly prohibit cryptocurrency.
* Regulation on Money Exchange Agents (Law 114-2 / Circular 114-3, enacted 18 September 2020): Mandates that money transfer agents pay out remittances in Haitian Gourdes (HTG) rather than USD.
IV. Compliance Requirements
* No specific VASP compliance requirements exist due to the lack of a licensing framework.
* General AML/CFT obligations under the laws of 2013 and 2023 may apply broadly to financial activities involving virtual assets.
V. Notable Restrictions or Limitations
* Foreign Exchange Controls: The requirement to convert remittances to HTG creates a significant barrier for establishing local USD-denominated crypto exchanges and fiat on-ramps.
* Lack of Banking Support: Banks are highly risk-averse due to de-risking by correspondent banks, making crypto-related wire transfers practically difficult, despite no explicit legal ban.
* Infrastructure Barriers: High electricity costs and unstable internet connectivity pose challenges for mining and reliable trading operations.
* Consumer Protection: No formal safety nets exist; users have no recourse against fraud or exchange insolvency.
VI. Recent Developments or Notes
* Haiti's FATF Gray List status is the primary driver for potential future regulatory change, likely leading to VASP-specific rules.
* Analysts should monitor CFATF plenary outcomes for Haiti closely, as the status could shift rapidly to 'Allowed-Regulated' or a 'Gray-Zone' if interim measures like a bank ban are imposed.
Full Analysis Report
Full Analysis Report
Haiti's regulatory environment for cryptocurrency is characterized by a lack of specific legislation, resulting in an 'Allowed-UnRegulated' status. Unlike some Caribbean neighbors that have moved to either license (e.g., Bahamas) or ban (e.g., Bolivia historically) digital assets, Haiti has remained largely neutral in its official statutes. The Banque de la République d'Haïti (BRH) has issued educational materials on blockchain and Bitcoin but has not promulgated a circular explicitly prohibiting financial institutions from dealing with crypto assets. Consequently, retail trading is legal by default, as no law criminalizes the possession or transfer of digital currencies.
However, the absence of a ban does not imply a friendly environment. The primary regulatory friction comes from Haiti's strict foreign exchange controls. In 2020, the BRH and Ministry of Commerce enforced regulations (Law 114-2) requiring money transfer agencies to pay out remittances in the local currency, the Gourde, rather than US dollars. This policy severely impacts the liquidity of potential local crypto exchanges, which often rely on USD rails. Furthermore, the country's inclusion on the FATF 'Gray List' (Jurisdictions under Increased Monitoring) means that local banks are under intense pressure to de-risk. While there is no explicit 'bank ban' circular for crypto, most Haitian banks are likely to block crypto-related transactions to preserve their fragile correspondent banking relationships.
From a legislative perspective, Haiti updated its AML/CFT framework with the Decree of April 30, 2023, to better align with international standards. While this decree broadens the definition of illicit finance, it has not yet been followed by specific regulations for Virtual Asset Service Providers (VASPs). The Caribbean Financial Action Task Force (CFATF) has noted Haiti's strategic deficiencies in this area (Recommendation 15), and the government has made high-level political commitments to address them. This suggests that a VASP regulatory framework is likely in the pipeline, which would eventually move the status from 'UnRegulated' to 'Regulated' (or 'Banned' if they choose a restrictive path).
Practically, Haitian residents access cryptocurrency primarily through peer-to-peer (P2P) markets or offshore exchanges that do not require strict local banking integration. The BRH has previously announced plans for a Central Bank Digital Currency (CBDC), the 'Digital Gourde,' but this project has seen little public progress compared to the private crypto market's organic growth. For now, retail investors operate in a 'buyer beware' environment with no consumer protection, high operational friction due to FX controls, and the looming prospect of sudden regulatory changes driven by FATF compliance requirements.
Haiti's regulatory environment for cryptocurrency is characterized by a lack of specific legislation, resulting in an 'Allowed-UnRegulated' status. Unlike some Caribbean neighbors that have moved to either license (e.g., Bahamas) or ban (e.g., Bolivia historically) digital assets, Haiti has remained largely neutral in its official statutes. The Banque de la République d'Haïti (BRH) has issued educational materials on blockchain and Bitcoin but has not promulgated a circular explicitly prohibiting financial institutions from dealing with crypto assets. Consequently, retail trading is legal by default, as no law criminalizes the possession or transfer of digital currencies. However, the absence of a ban does not imply a friendly environment. The primary regulatory friction comes from Haiti's strict foreign exchange controls. In 2020, the BRH and Ministry of Commerce enforced regulations (Law 114-2) requiring money transfer agencies to pay out remittances in the local currency, the Gourde, rather than US dollars. This policy severely impacts the liquidity of potential local crypto exchanges, which often rely on USD rails. Furthermore, the country's inclusion on the FATF 'Gray List' (Jurisdictions under Increased Monitoring) means that local banks are under intense pressure to de-risk. While there is no explicit 'bank ban' circular for crypto, most Haitian banks are likely to block crypto-related transactions to preserve their fragile correspondent banking relationships. From a legislative perspective, Haiti updated its AML/CFT framework with the Decree of April 30, 2023, to better align with international standards. While this decree broadens the definition of illicit finance, it has not yet been followed by specific regulations for Virtual Asset Service Providers (VASPs). The Caribbean Financial Action Task Force (CFATF) has noted Haiti's strategic deficiencies in this area (Recommendation 15), and the government has made high-level political commitments to address them. This suggests that a VASP regulatory framework is likely in the pipeline, which would eventually move the status from 'UnRegulated' to 'Regulated' (or 'Banned' if they choose a restrictive path). Practically, Haitian residents access cryptocurrency primarily through peer-to-peer (P2P) markets or offshore exchanges that do not require strict local banking integration. The BRH has previously announced plans for a Central Bank Digital Currency (CBDC), the 'Digital Gourde,' but this project has seen little public progress compared to the private crypto market's organic growth. For now, retail investors operate in a 'buyer beware' environment with no consumer protection, high operational friction due to FX controls, and the looming prospect of sudden regulatory changes driven by FATF compliance requirements.
Source Evidence
Primary and secondary sources cited in this analysis
"La présente circulaire définit les conditions et modalités de transmission des déclarations de transactions... pour toute transaction en espèces."
"La présente circulaire détermine les mesures que les banques doivent prendre dans le cadre de la mise en œuvre de leur programme de prévention..."
"Haiti made a high-level political commitment to work with the FATF and CFATF to strengthen the effectiveness of its AML/CFT regime."
"BITCOIN, les crypto-monnaies et la technologie du blockchain"
"Haiti has not currently enacted regulations or legislation specifically regulating cryptocurrency yet."
"Cryptocurrency is neither banned nor legal in Haiti. There is no specific cryptocurrency regulation in place too."
Web Sources (4)
Sources discovered via web search grounding
Search queries used (9)
- legal status of bitcoin in Haiti
- Haiti CFATF Mutual Evaluation Report virtual assets
- Banque de la République d'Haïti cryptocurrency regulation
- Haiti central bank crypto warning
- BRH Digital Gourde project cryptocurrency stance
- Banque de la République d'Haïti circular bitcoin ban banks
- Haiti crypto bill 2024 2025
- Haiti VASP regulation FATF action plan
- BRH Digital Gourde private crypto ban
https://www.youtube.com/watch?v=5D3d4IAtKeQ
https://www.fatf-gafi.org/en/countries/detail/Haiti.html
https://newsday.co.tt/2025/09/25/digital-currency-players-crypto-ban-a-backward-step/
https://www.gibsondunn.com/digital-assets-recent-updates-september-october-2025/