Third Generation Gangs Strategic Note No. 57: Designation of Haitian Viv Ansanm and Gran Grif as Foreign Terrorist Organizations (FTOs)

The US Government has announced the designation of Viv Ansanm and Gran Grif as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs).[1] The designation for both organizations was officially approved 5 May 2025.[2] This action by the State Department is representative of the shift in focus by the second Trump administration towards Latin American organized crime groups. Of the 63 FTO designations since 9/11, only fourteen of these have been directed towards non-Islamist organizations. Ten of those designations have taken place since February 2025 with the advent of the new presidency.[3] All of the recent FTO designations, except for the one reinstating the Houthis (Ansar Allah), are Mexican cartel and Latin American gang focused. This will have increasing significance for our understanding of organized crime (cartel and gang) activities vis-à-vis terrorism in the future.

Key Information: “Designation of Viv Ansanm and Gran Grif. Fact Sheet. United States Department of State, Office of the Spokesperson. 2 May 2025, https://www.state.gov/designation-of-viv-ansanm-and-gran-grif/:

Today, the Department of State announces the designation of Viv Ansanm and Gran Grif as Foreign Terrorist Organizations (FTOs) and Specially Designated Global Terrorists (SDGTs).

• Viv Ansanm is a group formed in September 2023 as a coalition of gangs through an alliance between the two main gang factions operating in Port-au-Prince, G-9 and G-Pép.

• The groups provide a unified platform for criminal groups to use violence to destabilize Haiti and quash actions aimed at restoring state control. Viv Ansanm has launched coordinated attacks on critical infrastructure in Haiti, including prisons, government buildings, and Haiti’s main airport in Port-au-Prince as part of a campaign that, among other things, forced the resignation of former Haitian Prime Minister Ariel Henry.

• Gran Grif is the largest gang in Haiti’s Artibonite department, a region that is home to much of the country’s rice fields. Since 2022, Gran Grif has been responsible for 80 percent of civilian death reports in Artibonite. Gran Grif has attacked Haitian National Police and the UN-authorized Multinational Security Support (MSS) mission, including in the February 2025 attack that killed a Kenyan MSS mission officer.

Terrorist designations expose and isolate entities and individuals, denying them access to the U.S. financial system and the resources they need to carry out attacks.

All property and interests in property of those designated today that are in the United States or that are in possession or control of a U.S. person are blocked. U.S. persons are generally prohibited from conducting business with sanctioned persons.

Persons, including American citizens, that engage in certain transactions or activities with these entities, or these individuals may expose themselves to sanctions risk. Notably, engaging in certain transactions with the organizations designated today entails risk of secondary sanctions pursuant to counterterrorism authorities. It is a crime to knowingly provide material support or resources to these organizations, or to attempt or conspire to do so. Moreover, terrorist designations can assist law enforcement actions of other U.S. agencies and governments.

Today’s actions are taken pursuant to section 219 of the Immigration and Nationality Act, as amended, and Executive Order 13224, as amended. FTO designations go into effect upon publication in the Federal Register.

Key Information: Marco Rubio, “Terrorist Designations of Viv Ansanm and Gran Grif.” Press Statement. United States Department of State. 2 May 2025, https://www.state.gov/releases/office-of-the-spokesperson/2025/05/terrorist-designations-of-viv-ansanm-and-gran-grif/:

Today, I am announcing the State Department’s designation of Viv Ansanm and Gran Grif as Foreign Terrorist Organizations and Specially Designated Global Terrorists. The age of impunity for those supporting violence in Haiti is over.

Haitian gangs, including the Viv Ansanm coalition and Gran Grif, are the primary source of instability and violence in Haiti. They are a direct threat to U.S. national security interests in our region. These gangs have killed and continue attacking the people of Haiti, Haitian security forces, and Multinational Security Support (MSS) mission personnel, and are committed to overthrowing the government of Haiti. Their ultimate goal is creating a gang-controlled state where illicit trafficking and other criminal activities operate freely and terrorize Haitian citizens. Terrorist designations play a critical role in our fight against these vicious groups and are an effective way to curtail support for their terrorist activities. Engaging in transactions with members of these groups entails risk in relation to counterterrorism sanctions authorities, not only for Haitians but also for U.S. lawful permanent residents and U.S. citizens. Individuals and entities providing material support or resources to Viv Ansanm or Gran Grif could face criminal charges and inadmissibility or removal from the United States.

Key Information: “Foreign Terrorist Organizations.” United States Department of State. Accessed 7 May 2025, https://www.state.gov/foreign-terrorist-organizations/:

Legal Criteria for Designation under Section 219 of the INA as amended

1. It must be a foreign organization.
2. The organization must engage in terrorist activity, as defined in section 212 (a)(3)(B) of the INA (8 U.S.C. § 1182(a)(3)(B)),or terrorism, as defined in section 140(d)(2) of the Foreign Relations Authorization Act, Fiscal Years 1988 and 1989 (22 U.S.C. § 2656f(d)(2)), or retain the capability and intent to engage in terrorist activity or terrorism.
3. The organization’s terrorist activity or terrorism must threaten the security of U.S. nationals or the national security (national defense, foreign relations, or the economic interests) of the United States.

Legal Ramifications of Designation

1. It is unlawful for a person in the United States or subject to the jurisdiction of the United States to knowingly provide “material support or resources” to a designated FTO. (The term “material support or resources” is defined in 18 U.S.C. § 2339A(b)(1) as “any property, tangible or intangible, or service, including currency or monetary instruments or financial securities, financial services, lodging, training, expert advice or assistance, safehouses, false documentation or identification, communications equipment, facilities, weapons, lethal substances, explosives, personnel (1 or more individuals who maybe or include oneself), and transportation, except medicine or religious materials.” 18 U.S.C. § 2339A(b)(2) provides that for these purposes “the term ‘training’ means instruction or teaching designed to impart a specific skill, as opposed to general knowledge.” 18 U.S.C. § 2339A(b)(3) further provides that for these purposes the term ‘expert advice or assistance’ means advice or assistance derived from scientific, technical or other specialized knowledge.’’
2. Representatives and members of a designated FTO, if they are aliens, are inadmissible to and, in certain circumstances, removable from the United States (see 8 U.S.C. §§ 1182 (a)(3)(B)(i)(IV)-(V), 1227 (a)(1)(A)).
3. Any U.S. financial institution that becomes aware that it has possession of or control over funds in which a designated FTO or its agent has an interest must retain possession of or control over the funds and report the funds to the Office of Foreign Assets Control of the U.S. Department of the Treasury.

Other Effects of Designation

1. Supports our efforts to curb terrorism financing and to encourage other nations to do the same.
2. Stigmatizes and isolates designated terrorist organizations internationally.
3. Deters donations or contributions to and economic transactions with named organizations.
4. Heightens public awareness and knowledge of terrorist organizations.
5. Signals to other governments our concern about named organizations.

Key Information: “Executive Order 13224.” United States Department of State, Office of the Coordinator for Counterterrorism. 23 September 2001, https://2009-2017.state.gov/j/ct/rls/other/des/122570.htm:

Designation Criteria In addition to the 29 individuals and entities designated by the President and listed in the Annex to the Executive Order, as amended by Executive Order 13268 of July 2, 2002, the Order provides authority for the designation (and blocking of assets) of additional individuals or entities (defined to mean partnerships, associations, corporations, or other organizations, groups, or subgroups):

• The Secretary of State, in consultation with the Secretary of the Treasury and the Attorney General, may designate foreign individuals or entities that he determines have committed, or pose a significant risk of committing, acts of terrorism that threaten the security of U.S. nationals or the national security, foreign policy, or economy of the U.S.;
• The Secretary of the Treasury, in consultation with the Secretary of State and the Attorney General, may designate individuals or entities that are determined:
• To be owned or controlled by, or act for or on behalf of an individual or entity listed in the Annex to the Order or by or for persons determined to be subject to subsection 1(b), 1(c), or 1(d)(i) of this Order;
• To assist in, sponsor, or provide financial, material, or technological support for, or financial or other services to or in support of, acts of terrorism or individuals or entities designated in or under the Order; or
• To be otherwise associated with certain individuals or entities designated in or under the Order.

For the purpose of the Order, “terrorism” is defined to be an activity that (1) involves a violent act or an act dangerous to human life, property, or infrastructure; and (2) appears to be intended to intimidate or coerce a civilian population; to influence the policy of a government by intimidation or coercion; or to affect the conduct of a government by mass destruction, assassination, kidnapping, or hostage-taking.

Legal Consequences

1. With limited exceptions set forth in the Order, or as authorized by OFAC, all property and interests in property of designated individuals or entities that are in the United States or that come within the United States, or that come within the possession or control of U.S. persons are blocked.
2. With limited exceptions set forth in the Order, or as authorized by OFAC, any transaction or dealing by U.S. persons or within the United States in property or interests in property blocked pursuant to the Order is prohibited, including but not limited to the making or receiving of any contribution of funds, goods, or services to or for the benefit of individuals or entities designated under the Order.
3. Any transaction by any U.S. person or within the United States that evades or avoids, or has the purpose of evading or avoiding, or attempts to violate, any of the prohibitions in the Order is prohibited. Any conspiracy formed to violate any of the prohibitions is also prohibited.
4. Civil and criminal penalties may be assessed for violations.

Other Effects

1. Deters donations or contributions to designated individuals or entities.
2. Heightens public awareness and knowledge of individuals or entities linked to terrorism.
3. Alerts other governments to U.S. concerns about individuals or entities aiding terrorism, and promotes due diligence by such governments and private sector entities operating within their territories to avoid associations with terrorists.
4. Disrupts terrorist networks, thereby cutting off access to financial and other resources from sympathizers.
5. Encourages designated entities to get out of the terrorism business.

Third Generation Gang Analysis

The United States under the second Trump administration is rapidly expanding the scope of Foreign Terrorist Organizations (FTOs) designations to include criminal based Third Generation Gangs (3GEN Gangs). This change in scope of FTOs comes directly from Executive Order 14157 under President Trump where “…certain international cartels (the Cartels) and other organizations will be designated as Foreign Terrorist Organizations.”[4] Since February 2025, eleven new FTOs have been designated. Six of these designations apply to Mexican cartel organizations, some of which have been active for decades. Four such designations apply to street (and prison) gangs. Most notably, the most recent FTOs apply to Viv Ansamn and Gran Grif, which are exclusively based in the Caribbean country of Haiti. This places them on par with the major league international gangs—Tren de Aragua (TdA), which initially emerged in Venezuela and Mara Salvatrucha (MS-13), which originated on the Streets of Los Angeles—as national security threat groups identified by the United States.

Viv Ansamn is a newer 3GEN organization operating in Haiti which formed by means of a merger between former rivals G9 and G-Pep in September 2023.[5] Gran Grif, on the other hand, has existed since the 2010s.[6] These gangs (as well as others) are directly challenging a failing Haitian state for direct control of Port-au-Prince and other urban regions of the country. One estimate places gang control of Haiti’s capital at 85% of its territory.[7] The situation has become so dire that a multinational security support mission (MSS) has now been deployed against the armed gangs.

Although these gangs are relatively new organizations (more so Viv Ansamn), their recent activities have resulted in extremely high levels of conflict now enveloping the Haitian people. For example, the homicide rate per 100,000 for Haiti rose from 18.9 percent in 2022 to 62.0 percent in 2024, for a total change of +51.6 percent increase in just two years. This is more than double the same homicide rate of Mexico where Mexican cartels have been operating for decades, in any year since 2022.[8]

As has been identified, Haiti imports most of its firearms and ammunition from the United States, much of which ends up in the hands of the Haitian gangs. These weapons flows originating from the US begin as ‘strawman’ purchases within the country and are then trafficked into Florida before crossing international waters into Haiti.[9] The FTO designation directed against Viv Ansanm and Gran Grif provides additional domestic US avenues to weaken the groups’ ability to fund and arm themselves. The FTO designation also makes it illegal to provide many forms of resources to Viv Ansanm and Gran Grif. Specifically:

“the term ‘material support or resources’ means any property, tangible or intangible, or service, including currency or monetary instruments or financial securities, financial services, lodging, training, expert advice or assistance, safehouses, false documentation or identification, communications equipment, facilities, weapons, lethal substances, explosives, personnel (1 or more individuals who may be or include oneself), and transportation, except medicine or religious materials;…”[10]

Adding Haiti’s Viv Ansanm and Gran Grif organizations to the US FTOs list—along with Tren de Aragua (TdA) and Mara Salvatrucha (MS-13)—marks a significant change in US foreign policy in relationship to how terrorist organizations are envisioned. Prior to Trump’s second administration, only five non-radical Islamist based organizations designated post 9/11 were on the FTOs listing:

• Communist Party of the Philippines/New People’s Army (CPP/NPA); 9 August 2002
• Continuity Irish Republican Army (CIRA); 13 July 2004
• Revolutionary Struggle (RS); 18 May 2009
• Revolutionary Armed Forces of Colombia–People’s Army (FARC-EP); 1 December 2021
• Segunda Marquetalia; 1 December 2021.[11]

FARC-EP and Segunda Marquetalia (a FARC faction) represent hybrid organizations—formerly ideologically driven guerillas which have since backslid into organized criminality—which have actively engaged in narco-terrorism. In some ways adding the Mexican cartels to the FTOs designation is less of a stretch than imagined given this precedence. However, TdA and MS-13, as transnational gangs, are outliers. They are not ideologically driven like Salafist-Jihadi groups such as al Qaeda, the Islamic State, and their franchise and affinity-linked organizations. Now with Viv Ansanm and Gran Grif—extremely violent and increasingly politicized gangs only found in Haiti—being designated as FTOs, we are quickly moving into another era (or possibly paradigm) of determining what a terrorist group is from a US governmental federal perspective. At this time, these two Haitian groups do not have a transnational footprint or the capability (or intent) to engage in direct ‘terrorist acts’ against our homeland. The defining lines between gang members, criminal insurgents, and ideological terrorists are quickly fading away. The unintended second order effects of these new designations are still developing. Many see the potentials of them backfiring and actually furthering criminal control in Haiti and/or resulting in humanitarian tragedy.[12]

The designation of transnational criminal organizations. (TCOs), including criminal cartels and transnational gangs as FTOs and specially designated global terrorists (SDGTs) is controversial and raises significant operational and legal challenges. These include conflating terrorism and criminality which can inhibit effective policy development, enhanced militarization of civil policing, and potential political backlash due to an erosion on human rights and due process. Of course, there is overlap and both crime and terrorism converge within the spectrum of hybrid threats. Additional research, policy development, and an evolution of legal frameworks is essential to counter the threats to state sovereignty, effective governance, and both national and global security.[13][14]

The Trump administration has fully exited the old post-9/11 Global War on Terrorism (GWOT) perceptual lens that had defined US terrorism perceptions for over a generation.[15] In doing so, it is now blurring terrorism with the organized crime (specifically cartel and gang) activities increasingly challenging many regions of Latin America. Much of this has been articulated for well over a decade at El Centro by means of the Third Generation Gangs and Criminal Insurgency constructs.[16] What this signifies for the future is unknown, however, what is known is that discussion and debate about what this may mean for our future US national security is only now beginning.

Sources

“Designation of Viv Ansanm and Gran Grif. Fact Sheet. United States Department of State, Office of the Spokesperson. 2 May 2025, https://www.state.gov/designation-of-viv-ansanm-and-gran-grif/.

“Terrorist Designations of Viv Ansanm and Gran Grif.” Press Statement. United States Department of State. 2 May 2025, https://www.state.gov/releases/office-of-the-spokesperson/2025/05/terrorist-designations-of-viv-ansanm-and-gran-grif/.

“Foreign Terrorist Organizations.” United States Department of State, Bureau of Counterterrorism. Accessed 7 May 2025, https://www.state.gov/foreign-terrorist-organizations/.

“Executive Order 13224.” United States Department of State, Office of the Coordinator for Counterterrorism. 23 September 2001, https://2009-2017.state.gov/j/ct/rls/other/des/122570.htm.

Endnotes

[1] “Designation of Viv Ansanm and Gran Grif. Fact Sheet. United States Department of State, Office of the Spokesperson. 2 May 2025, https://www.state.gov/designation-of-viv-ansanm-and-gran-grif/.

[2] “Foreign Terrorist Organizations.” United States Department of State, Bureau of Counterterrorism. Accessed 7 May 2025, https://www.state.gov/foreign-terrorist-organizations/.

[3] Ibid.

[4] Donald Trump, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” Executive Order 14157. 20 January 2025, https://public-inspection.federalregister.gov/2025-02004.pdf.

[5] Dánica Coto, “Who’s behind Haiti’s Powerful Gang Alliance?” PBS News. 21 October 2022, https://www.pbs.org/newshour/world/whos-behind-haitis-powerful-gang-alliance and Sandra Pellegrini, “Viv Ansanm: Living together, fighting united – the alliance reshaping Haiti’s gangland.” Armed Conflict Location & Event Data (ACLED). 16 October 2024, https://acleddata.com/2024/10/16/viv-ansanm-living-together-fighting-united-the-alliance-reshaping-haitis-gangland/.

[6] “Insécurité: Trois présumés bandits arrêtés et un véhicule saisi aux Gonaïves par la Police nationae d’Haïti.” Alter Presse. 24 December 2019, https://www.alterpresse.org/spip.php?article25097. In addition, see, John P. Sullivan and Robert J. Bunker, “Third Generation Gangs Strategic Note No. 41: Criminal Insurgency and ‘Revolution’ in Haiti?” Small Wars Journal. 2 July 2021, https://smallwarsjournal.com/2021/07/02/third-generation-gangs-strategic-note-no-41-criminal-insurgency-and-revolution-haiti/.

[7] “Haiti Struggles with Criminal Insurgency as U.S. Designates Gangs as Terror Groups.” INTELBRIEF. The Soufan Center. 22 May 2025, https://thesoufancenter.org/intelbrief-2025-may-22/.  

[8] Marina Cavalari, Juliana Manjarrés, and Christopher Newton. “InSight Crime’s 2024 Homicide Round-Up.” InSight Crime. 26 February 2025, http://insightcrime.org/news/insight-crime-2024-homicide-round-up/.

[9] Haiti’s Criminal Markets: Mapping Trends in Drugs and Firearms Trafficking. New York: United Nations Office on Drugs and Crime (UNODC), Research and Trend Analysis Branch, 2023, p. 18, https://www.unodc.org/documents/data-and-analysis/toc/Haiti_assessment_UNODC.pdf.

[10] Op. cit., United States Department of State, Bureau of Counterterrorism at Note 2.

[11] Ibid.

[12] Romain Le-Cour-Grandmaison and Matt Herbert, “Haiti: How US terrorist designations could deepen criminal rule and humanitarian tragedy.” Global Initiative Against Transnational Organized Crime (GI-TOC). 8 May 2025, https://globalinitiative.net/analysis/haiti-how-us-terrorist-designations-could-deepen-criminal-rule-and-humanitarian-tragedy/ and Sarah Morland and Harold Isaac, “Haiti gangs’ US terrorism designation risks harming most vulnerable, NGOs warn.” Reuters. 8 May 2025, https://www.reuters.com/world/americas/haiti-gangs-us-terrorism-designation-risks-harming-most-vulnerable-ngos-warn-2025-05-08/.

[13] These challenges are pressing legal and policy concerns, for recent works at Small Wars Journal on “narcoterrorism” and related issues, see Michael Harper, Mallory Cooney, and Paul Andersen, “From Corruption to Cartels: A Shifting Focus of DOJ Enforcement for Companies Operating in Latin America.” Small Wars Journal. 30 May 2025, https://smallwarsjournal.com/2025/05/30/from-corruption-to-cartels-a-shifting-focus-of-doj-enforcement-for-companies-operating-in-latin-america/; Ron MacCammon, “Venezuela’s Gray War: A Criminal Army, a Migrant Wave, and the US ‘Invasion’?” Small Wars Journal. 28 May 2025, https://smallwarsjournal.com/2025/05/28/venezuelas-gray-war-a-criminal-army-a-migrant-wave-and-the-us-invasion/; and Mahmut Chengiz, “The Impact of Terrorist Designation on Mexican Cartels: Implications for Security and Policy.” Small Wars Journal. 27 January 2025, https://smallwarsjournal.com/2025/01/27/the-impact-of-terrorist-designation-on-mexican-cartels-implications-for-security-and-policy/.

[14] For a discussion of the legal dimensions, see Kenneth Watkin, Fighting at the Legal Boundaries: Controlling the Use of Force in Contemporary Conflict. Oxford: Oxford University Press, 2016; Robert Muggah and John P. Sullivan, “The Coming Crime wars.” Foreign Policy. 21 September 2018, https://foreignpolicy.com/2018/09/21/the-coming-crime-wars/; Tess Bridgeman, Rebecca Ingber and Scott Roehm, “What are “Wartime Authorities” and When Can the President Use Them? An Expert Q&A.” Just Security, 2 June 2025, https://www.justsecurity.org/113973/wartime-authorities-when-can-president-use/; Brian Finucane, “U.S. Military Action in Mexico: Almost Certainly Illegal, Definitely Counterproductive.” Just Security. 20 February 2025, https://www.justsecurity.org/107850/us-military-mexico-illegal/; and Rachel Levinson-Waldman, “The Dangerous Sweep of Trump’s Plan to Designate Cartels as Terrorist Organizations.” Just Security. 5 February 2025, https://www.justsecurity.org/107400/trump-plan-cartels-terrorist-organizations/.

[15] These perceptions have already been shifting for some time in Central America where powerful gangs—such as MS-13 and Barrio 18—can represent existential threats to low-capacity states. This perceptual shift is also possibly taking place in the Caribbean. The Dominican Republic is backing the US designation of Haitian gangs as terrorist organizations though given that it shares the island of Hispaniola with Haiti this should not come as a surprise. See Jim Wyss, “Haitian Gangs Declared Terrorist Groups by Dominican Republic.” Bloomberg. 27 February 2025, https://www.bloomberg.com/news/articles/2025-02-27/haitian-gangs-declared-terrorist-groups-by-dominican-republic?embedded-checkout=true.

[16] See, for example, John P. Sullivan, “Criminal Insurgency in the Americas.” Small Wars Journal. 13 February 2010, https://smallwarsjournal.com/2010/02/13/criminal-insurgency-in-the-americas/; John P. Sullivan, “From Drug Wars to Criminal Insurgency: Mexican Cartels, Criminal Enclaves and Criminal Insurgency in Mexico and Central America. Implications for Global Security.” Working Paper N^o9. Paris:Fondation Maison des sciences de l’homme. June 2011, https://shs.hal.science/FMSH-WP/halshs-00694083; Alexander Elfes, “Militarised Criminal Networks in Mexico and the Challenges They Present to the Military and Police.” Small Wars Journal. 10 July 2020, https://smallwarsjournal.com/2020/07/10/militarised-criminal-networks-mexico-and-challenges-they-present-military-and-police/; and John P. Sullivan, “Crime wars: Operational perspectives on criminal armed groups in Mexico and Brazil.” International Review of the Red Cross. IRRC No. 923. June 2023, https://international-review.icrc.org/articles/crime-wars-operational-perspectives-923.

For Additional Reading

Jean-michel Newberg and Robert J. Bunker, “Third Generation Gangs Subject Bibliography No. 2: Haitian Gangs.” Small Wars Journal. 11 March 2025.

John P. Sullivan and Robert J. Bunker, Eds., Strategic Notes on Third Generation Gangs. Bloomington: Xlibris, 2020.

John P. Sullivan and Robert J. Bunker, Eds., Third Generation Gangs and Transnational Cartels. Bloomington: Xlibris, 2025.

Haiti’s Criminal Markets: Mapping Trends in Drugs and Firearms Trafficking. New York: United Nations Office on Drugs and Crime (UNODC), Research and Trend Analysis Branch, 2023.

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