The UK has introduced a sanctions regime designed to target criminal actors, gangs and their financiers whose actions are causing instability in Haiti, pursuant to The Haiti (Sanctions) Regulations 2022, which enter into force on 28 December 2022.

The restrictive measures consist of: financial sanctions measures through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available; trade sanctions, including restrictions on the trade in military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008); and travel restrictions in respect of designated persons, implemented through section 8B of the Immigration Act 1971. The UK has published an explanatory memorandum and guidance accompanying the Regulations.

These measures follow the EU’s introduction of restrictions against gang leaders in Haiti and their financiers on 28 November and UN Resolution 2653 (2022) imposing UN sanctions on Haiti. See our previous blog post on the EU measures here.

The Regulations provide that each person for the time being named on the Resolution 2653 Sanctions List is a designated person for the purposes of the financial and trade sanctions. So far only one person (gang leader Jimmy Cherizier) has been designated.


Ben Smith is a Partner in Baker McKenzie’s London office and a member of the firm’s Compliance & Investigations and International Trade practice groups. Both these practices are ranked Tier 1 by Legal 500 UK. Ben joined the London office of Baker & McKenzie in September 2007. He has also worked in Baker McKenzie's San Francisco and Brussels offices, as well as on secondment to the legal and compliance teams at three FTSE 100 UK plcs. The Legal 500 UK ranked Ben as a “Rising Star”, noting “Ben Smith is a pleasure to work with. Professional, knowledgeable and always ready to assist with practical solutions.”


Adeel Haque is an Associate in Baker McKenzie's London office. He is a member of the International Commercial & Trade and Antitrust & Competition practice groups. Adeel qualified in September 2019 and has spent time working in the Firm's Hong Kong office.