Regulatory AlertsCircular 124 on Modifications of Certain Post-Approval Situations
The Bank of the Republic of Haiti issued Circular 124 to mandate that financial institutions notify the central bank of post-approval changes to their operational, ownership, or governance structures. The circular categorizes these changes into three notification tiers: prior authorization for significant alterations like mergers or capital shifts exceeding 20%, 33%, or 50%; prior declaration for changes such as reaching the 10% qualified shareholder threshold or appointing new executives; and ex post declaration for amendments to shareholder agreements or changes in risk and compliance officers within 30 days. Non-compliance triggers daily penalties of HTG 50,000, potential administrative sanctions under the 2012 Banking Law, and the nullification of unauthorized share acquisitions.