Haiti KYC, KYB & AML compliance checklist
A practical, source-linked checklist for implementing KYC, KYB and AML requirements in Haiti.
- Last reviewed
- Last reviewed:
- Version
- Version 1.0
Direct answer
What does the Haiti compliance checklist cover?
The Haiti checklist translates primary KYC, KYB and AML rules into 11 control areas and 35 implementation checks. It identifies the relevant authorities, customer and beneficial-owner controls, reporting duties, recordkeeping expectations and evidence teams should retain.
Key regulatory facts
- FIU
- Unité Centrale de Renseignements Financiers (UCREF)
- Primary current framework
- Decree of 30 April 2023; BRH Circular 129-1 effective 2 March 2026
- Suspicion reporting
- Promptly to UCREF; do not wait for a threshold
- Transaction reports
- Sector-specific thresholds and deadlines under BRH Circular 95-5
- Retention
- At least 5 years for BRH-regulated financial institutions
- FATF status
- Increased monitoring as at 13 February 2026; recheck live lists
Implementation detail
Haiti compliance requirements and actions
Open each control area to review the requirement, recommended implementation action, evidence to retain and the primary-source citation used by the research team.
01Scope, authorities, and licensingMap the legal entity, activity and delivery model before applying sector rules.3 items+
Determine whether the business is a reporting entity under the 2023 decree.
- Implementation action
- Map each service and entity to the financial or designated non-financial categories; document any excluded or uncertain activity and obtain local advice.
- Evidence to retain
- Applicability memo, service map and counsel or authority confirmation.
- Primary citation
- Decree of 30 April 2023; UCREF legal framework
Treat UCREF as Haiti's financial intelligence unit.
- Implementation action
- Register for the applicable UCREF reporting channel, nominate authorised reporters and test access before onboarding customers.
- Evidence to retain
- UCREF registration, access test and reporter appointment.
- Primary citation
- UCREF Organic Law of 4 May 2017; UCREF reporting guidance
Obtain BRH authorisation before providing a regulated financial or payment service.
- Implementation action
- Classify banking, transfer, exchange, microfinance and electronic-payment functions and secure the relevant BRH approval before launch.
- Evidence to retain
- Licence analysis, BRH approval and permitted-activity register.
- Primary citation
- Banking Law of 14 May 2012; BRH Circular 121; Circular 129-1 scope
02Governance and risk assessmentBRH-regulated financial institutions require a documented, proportionate prevention programme.3 items+
Maintain an AML/CFT/CPF prevention programme proportionate to the institution.
- Implementation action
- Approve policies, internal controls, employee screening, training, independent testing and branch-level compliance responsibilities.
- Evidence to retain
- Board approval, programme, training records and audit reports.
- Primary citation
- BRH Circular 129-1, section 1
Appoint a compliance officer and operational compliance contacts.
- Implementation action
- Document authority, independence, direct escalation, resources and substitution arrangements.
- Evidence to retain
- Appointment, job description, reporting line and committee minutes.
- Primary citation
- BRH Circular 129-1, sections 1.1-1.3
Apply a documented risk-based approach.
- Implementation action
- Assess customer, product, channel, geography and transaction risks; assign a client risk level and tune controls to it.
- Evidence to retain
- Enterprise risk assessment, client scoring and control mapping.
- Primary citation
- BRH Circular 129-1, sections 1.7, 2 and 7
03Natural-person identificationIdentify and verify customers, representatives and persons behind transactions using reliable evidence.4 items+
Identify and verify the customer before establishing a relationship.
- Implementation action
- Collect identity, address, occupation and expected activity; verify with current reliable documents and record exceptions.
- Evidence to retain
- Identity file, verification result, address proof and onboarding approval.
- Primary citation
- Decree of 30 April 2023 arts. 37-39; BRH Circular 129-1, sections 3-4
Apply CDD to relationships, covered occasional transactions, transfers, suspicion and unreliable prior data.
- Implementation action
- Trigger CDD for every relationship; for financial institutions also apply Circular 129-1's HTG 1,320,000 occasional/linked-cash trigger and all national or international transfers, without treating the threshold as a safe harbour.
- Evidence to retain
- CDD trigger log, linked-transaction logic and completed case files.
- Primary citation
- BRH Circular 129-1, section 2
Collect specified identity evidence for remittances and transmissions at HTG 132,000 or equivalent.
- Implementation action
- For covered financial institutions, verify the parties and retain required transfer information at or above the threshold and whenever risk or complexity warrants it.
- Evidence to retain
- Transfer record, identity documents and threshold alert.
- Primary citation
- BRH Circular 129-1, section 3
Do not proceed when required identity or authority cannot be established.
- Implementation action
- Refuse or end the relationship or transaction and assess whether to report suspicion to UCREF.
- Evidence to retain
- Decline record, escalation and STR decision.
- Primary citation
- Decree of 30 April 2023 art. 46; BRH Circular 129-1, sections 3 and 5
04KYB, registries, and beneficial ownershipRegistry evidence is a starting point; it does not replace ownership and control verification.4 items+
Verify legal existence, purpose, registered office and authority to act.
- Implementation action
- Obtain constitutive documents, MCI commercial-registration evidence, tax identifiers, directors and representative powers; independently confirm current status.
- Evidence to retain
- Registry extract, statutes, tax evidence and authority documents.
- Primary citation
- Decree of 30 April 2023 art. 38; MCI company-registration procedures
Understand ownership and control and identify beneficial owners.
- Implementation action
- Trace natural persons who ultimately own or control the customer and apply the decree's control and fallback sequence without inventing a percentage threshold.
- Evidence to retain
- Ownership chart, source documents, control analysis and verified natural-person files.
- Primary citation
- Decree of 30 April 2023 arts. 40-42; BRH Circular 129-1, section 5
Keep beneficial-owner information current and plausible.
- Implementation action
- Refresh on ownership, management or risk changes; stop service and consider UCREF reporting when information is missing, implausible or cannot be verified.
- Evidence to retain
- Change monitoring, refresh log and escalation record.
- Primary citation
- BRH Circular 129-1, sections 5, 8 and 9
Do not assume a comprehensive public beneficial-ownership register.
- Implementation action
- Use MCI records and published formation documents where accessible, then obtain independent ownership/control evidence from the customer and reliable third parties.
- Evidence to retain
- Registry search, access log, ownership documents and discrepancy memo.
- Primary citation
- MCI commercial-register procedures; FATF Haiti action plan
05PEPs, EDD, and remote onboardingHigh-risk relationships require approval, provenance evidence and enhanced monitoring.3 items+
Detect domestic, foreign and international-organisation PEPs and connected persons.
- Implementation action
- Screen customers and beneficial owners at onboarding and periodically, including family members and close associates.
- Evidence to retain
- Screening output, match disposition and refresh schedule.
- Primary citation
- Decree of 30 April 2023 art. 6; BRH Circular 129-1, section 6
Apply PEP controls when a match is confirmed.
- Implementation action
- Obtain senior-management approval, establish source of wealth and source of funds and conduct enhanced ongoing monitoring.
- Evidence to retain
- Approval, provenance file and monitoring plan.
- Primary citation
- BRH Circular 129-1, section 6
Control non-face-to-face and other high-risk relationships.
- Implementation action
- Use stronger identity, liveness, device, document and first-payment controls proportionate to risk and record why residual risk is acceptable.
- Evidence to retain
- Remote-onboarding test results, fraud checks and approval.
- Primary citation
- Decree of 30 April 2023 art. 36; BRH Circular 129-1, section 2.3
06Monitoring and suspicious reportingSuspicion is independent of amount and reporting must remain confidential.4 items+
Monitor consistently with the customer's expected activity and risk.
- Implementation action
- Detect unusual, complex, unjustified and linked activity; investigate origin, purpose and parties and preserve a confidential written analysis.
- Evidence to retain
- Alerts, investigation notes, disposition and rule governance.
- Primary citation
- BRH Circular 129-1, sections 1.8 and 2.1
Report suspicion promptly to UCREF.
- Implementation action
- File when funds or property are suspected or reasonably suspected to be criminal proceeds or connected to ML/TF; do not wait to prove the predicate offence.
- Evidence to retain
- STR decision, transmission receipt and supporting analysis.
- Primary citation
- 2013 Law art. 31; Decree of 30 April 2023; UCREF reporting guidance
Escalate before, during or after a transaction as facts require.
- Implementation action
- Use the authorised electronic channel or another written method if unavailable; follow UCREF instructions for a pending transaction and promptly supplement post-transaction suspicion.
- Evidence to retain
- Timestamped escalation, UCREF communication and supplements.
- Primary citation
- UCREF reporting guidance, 2013 Law arts. 19 and 33-34
Prevent tipping off and protect reporter confidentiality.
- Implementation action
- Restrict STR knowledge, exclude it from customer disclosures and train staff on prohibited communications.
- Evidence to retain
- Access logs, confidentiality procedure and training attestations.
- Primary citation
- 2013 Law arts. 35 and 37; BRH Circular 129-1, section 16
07Payments, wires, thresholds, and agentsTransaction reports and transfer information use sector-specific rules.4 items+
Apply Circular 95-5 reporting thresholds only to the named sector.
- Implementation action
- Report: banks at HTG 1,320,000 for cash/transfers/wires; transfer houses at HTG 132,000 for transfers; exchange bureaux at HTG 1,132,000 cash or HTG 350,000 bank transfer; credit cooperatives and microfinance companies at HTG 1,132,000 cash, including linked transactions.
- Evidence to retain
- Threshold configuration, aggregation tests and filed reports.
- Primary citation
- BRH Circular 95-5, section 2
Transmit threshold reports within the prescribed channel and time.
- Implementation action
- Send electronically each day; where paper is used, send within three business days in the metropolitan area or five business days in provincial cities.
- Evidence to retain
- Submission log, UCREF receipt and exception record.
- Primary citation
- BRH Circular 95-5, section 1
Carry complete originator and beneficiary information through wire transfers.
- Implementation action
- Validate names, addresses, account identifiers and accompanying information; use risk-based rules to execute, reject or suspend incomplete transfers.
- Evidence to retain
- Payment message, validation result and exception decision.
- Primary citation
- Decree of 30 April 2023 arts. 47-53; BRH Circular 129-1, section 11
Control agents, sub-agents and outsourced providers.
- Implementation action
- Perform due diligence, contract for compliance and data access, monitor performance and retain final accountability.
- Evidence to retain
- Due-diligence file, contract, monitoring and remediation.
- Primary citation
- BRH Circular 129-1, sections 12 and 15; Circular 121
08Targeted financial sanctionsFinancial institutions must screen and act on applicable UN designations under Haiti's 2023 framework.3 items+
Screen customers, beneficial owners, counterparties and transactions against applicable designation lists.
- Implementation action
- Screen at onboarding, before execution and on list updates; cover aliases, ownership/control and indirect availability of assets.
- Evidence to retain
- List source, screening logs, match logic and dispositions.
- Primary citation
- Decree of 30 April 2023; BRH targeted-financial-sanctions guidelines (16 February 2026)
Freeze matched funds and other assets without delay and without prior notice.
- Implementation action
- Block dealing or making assets available, preserve the asset trail and notify the competent authorities through the prescribed channel.
- Evidence to retain
- Freeze timestamp, asset inventory, authority report and access restriction.
- Primary citation
- BRH targeted-financial-sanctions guidelines, sections 3-7
Manage false positives and release only under competent authority.
- Implementation action
- Document match analysis; do not release frozen property until the legally competent authority confirms delisting, exemption or authorisation.
- Evidence to retain
- Match file, authority instruction and controlled release approval.
- Primary citation
- BRH targeted-financial-sanctions guidelines
09Records and regulator accessRecords must reconstruct decisions and transactions and be promptly retrievable.3 items+
Retain CDD records for at least five years after closure or the end of the relationship.
- Implementation action
- Preserve identity, beneficial-owner, authority and risk records with immutable dates and retrieval controls.
- Evidence to retain
- Retention schedule, archive sample and deletion controls.
- Primary citation
- BRH Circular 129-1, section 14
Retain transaction, analysis, correspondence and transfer records for at least five years.
- Implementation action
- Calculate from transaction execution or relationship end as applicable and preserve copies of UCREF reports.
- Evidence to retain
- Transaction archive, analysis file and filing copy.
- Primary citation
- BRH Circular 129-1, section 14
Respond promptly to lawful information requests.
- Implementation action
- Authenticate the requester, preserve confidentiality, produce complete records and log every disclosure.
- Evidence to retain
- Request, legal review, production log and receipt.
- Primary citation
- 2013 Law art. 36; BRH Circular 129-1, section 14
10Privacy, biometrics, and transfersA comprehensive general private-sector data-protection statute and authority were not confirmed in the reviewed primary materials; confidentiality and sector rules still apply.2 items+
Use KYC data for defined lawful purposes and restrict access.
- Implementation action
- Document purpose, necessity, access roles, security and retention; obtain Haitian advice for biometrics, monitoring and cross-border hosting.
- Evidence to retain
- Data inventory, access matrix, security review and legal assessment.
- Primary citation
- Constitution of Haiti art. 28-1; Banking Law confidentiality provisions; BRH Circular 126
Do not claim a general privacy-law transfer mechanism that has not been verified.
- Implementation action
- Contract for security, confidentiality, incident response, return/deletion and regulator access; record the legal basis and uncertainty for each cross-border flow.
- Evidence to retain
- Transfer assessment, vendor contract and data-flow map.
- Primary citation
- BRH Circular 126; sector confidentiality duties
11Practical evidence packsKeep concise packs that allow an auditor to reproduce each decision.2 items+
Maintain one reconstructable onboarding pack per customer.
- Implementation action
- Bundle identity, KYB, beneficial ownership, screening, risk, approvals and exceptions under stable identifiers.
- Evidence to retain
- Complete sampled onboarding pack.
- Primary citation
- Operational control supporting BRH Circular 129-1
Maintain one reconstructable monitoring and reporting pack per case.
- Implementation action
- Link source transactions, alerts, analysis, approvals, UCREF submissions and post-filing controls without exposing the filing to unauthorised staff.
- Evidence to retain
- Complete sampled case pack and access log.
- Primary citation
- Operational control supporting Decree of 30 April 2023 and BRH Circulars 95-5 and 129-1
Primary-source register
11 sources used for this checklist
Use these links to verify the underlying legislation, regulator guidance, reporting procedures and international status statements.
- Decree of 30 April 2023 sanctioning ML, TF and proliferation financingUCREF / Le Moniteur · Primary legislation
- BRH Circular 129-1 - preventive AML/CFT/CPF measuresBanque de la République d'Haïti · Binding financial-sector regulation
- BRH Circular 95-5 - transaction reports and thresholdsBanque de la République d'Haïti · Binding financial-sector regulation
- Targeted financial sanctions guidelinesBanque de la République d'Haïti · Authoritative supervisory guidance
- UCREF AML/CFT reporting guidanceUCREF · Official FIU guidance
- UCREF legal and regulatory frameworkUCREF · Official legal inventory
- BRH prudential standards and current circularsBanque de la République d'Haïti · Official supervisory inventory
- BRH Circular 121 - electronic payment service providersBanque de la République d'Haïti · Binding payment regulation
- MCI professional identity and commercial-register procedureMinistry of Commerce and Industry · Official registry guidance
- Haiti 4th enhanced follow-up report (2024)CFATF · Authoritative regional assessment
- FATF black and grey lists - 13 February 2026FATF · Authoritative current status
Direct answers
Haiti KYC, KYB and AML questions
Who receives suspicious transaction reports in Haiti?+
UCREF. Report promptly through the authorised channel and keep the report confidential.
Is there one universal transaction-reporting threshold?+
No. BRH Circular 95-5 sets different thresholds by financial-sector category and transaction type; suspicion is reportable regardless of amount.
How long should financial institutions retain AML records?+
At least five years under BRH Circular 129-1, calculated from account closure, relationship end or transaction execution as applicable.
Is beneficial ownership a registry-only check?+
No. Financial institutions must understand ownership/control, identify and verify beneficial owners and resolve missing or implausible information independently.
Are electronic payment services regulated?+
Yes. BRH Circular 121 regulates electronic payment service providers, and Circular 129-1 includes them within its financial-institution scope.
Does Haiti have a confirmed comprehensive public beneficial-ownership register?+
The reviewed official materials did not establish one. Use MCI registration evidence but independently verify natural-person ownership and control.
Does Haiti have a confirmed comprehensive private-sector data-protection statute?+
No such comprehensive statute or dedicated general authority was confirmed in the reviewed primary materials. Constitutional confidentiality, sector rules, cybersecurity duties and contractual controls still require careful handling.
Is Haiti on a FATF public list?+
Yes. Haiti remained under increased monitoring in FATF's 13 February 2026 statement reviewed on 8 August 2026. Recheck the live list before reliance.
Research and review method
VOVE ID Compliance Research maps the regulatory perimeter, translates obligations into operational controls, links each material claim to a source and records the date and version of every review.
General regulatory information, not legal advice or a licence determination. Reviewed 8 August 2026 and legally scoped as applicable on that date. Confirm UCREF forms and access, BRH interpretations, non-financial-sector supervision, registry access, sanctions release procedures, privacy rules and product-specific licensing with the competent authority and qualified Haitian counsel before launch.