A firm reported a $75,000 deposit to lobby on OFAC policy for Haiti's sanctioned ex-president

A Washington lobbying firm has registered under the Foreign Agents Registration Act to represent former Haitian President Michel Joseph Martelly, who has been under U.S. Treasury sanctions since 2024, through a Miami company. The Justice Department filing reports a $75,000 contract deposit. The attached engagement letter sets a larger fee schedule. It describes the work as advocacy aimed at U.S. sanctions policy.

Liberty Government Affairs, LLC's registration statement was received by the FARA Unit on Nov. 5, 2026. The department assigned registration number 7793. The records were retrieved from the Justice Department's public eFile system on Nov. 10, 2026. The foreign principal is listed as "Michel Joseph Martelly (through Invisible Investigations LLC)," a Haitian national, with an address in Peguyville, Haiti.

Brian Darling, the firm's president and founder, is the only officer listed and the only short-form registrant. The company is a single-owner LLC organized in the District of Columbia on May 22, 2017. It gives a business address at 1015 15th Street NW, Suite 600, in Washington, and describes itself as a public affairs firm. Darling's short form, also received on Nov. 5, lists his occupation as "Lobbying, Attorney, PR." It says he will work on a part-time basis. It describes the services as "strategic advice, monitoring, and direct advocacy services." Asked whether that work includes political activity under the Act, the short form says yes: "The scope of work includes lobbying services by communicating and meeting with the relevant officials."

Registering under FARA is a legal disclosure. It is not a finding that Darling, the firm, Invisible Investigations or Martelly has violated sanctions law or the Act. The packet does not report a Justice Department or Treasury enforcement action tied to this contract. It also does not show that any meeting with Treasury or State Department officials has already occurred. It does not show that any sanctions designation has been changed.

The contract's stated target is OFAC policy#

Exhibit B says the agreement is a formal written contract. Item 7 of the exhibit lists the agreement date as Oct. 26, 2026. The attached letter is dated Oct. 22, 2026, on Liberty Government Affairs letterhead. It is signed on Oct. 26 by Darling for the firm and by Edward Haynes for Invisible Investigations, LLC, of 7900 NW 27th Avenue, Suite 241, Miami, Florida. The letter says it "supersedes any prior agreement."

The scope section is specific. Liberty, called "Lobbyist" in the letter, "is to be retained by Invisible Investigations, LLC ('Client') to provide professional government relations and lobbying services." The firm "agrees to provide strategic advice, monitoring, and direct advocacy services focused on the U.S Department of Treasury and State Department to change a policy that uses the U.S. Department of Treasury's Office of Assets Control (OFAC) to sanction foreign individuals for reasons not supported by sufficient factual or legal grounds or otherwise warrant review."

The letter then names the intended beneficiary. "Client has disclosed that the intended beneficiary of the representation is Michel Joseph Martelly ('Sanctioned Person'), who Client understands to be a person subject to U.S. sanctions restrictions administered by OFAC." The parties "acknowledge that, although Invisible Investigations, LLC is the contracting Client under this agreement, the services contemplated by this agreement may be deemed to be provided to or on behalf of the Sanctioned Person."

The letter recites the existing designation in the same terms the firm later used in its FARA paperwork. "Michel Joseph Martelly was sanctioned by OFAC on August 20, 2024, and was added to OFAC's Non-SDN Menu-Based Sanctions List (NS-MBS List). Michel Joseph Martelly is not a Specially Designated National or otherwise subject to blocking sanctions."

That last sentence matters for what the designation does and does not do. On Aug. 20, 2024, the Treasury Department announced that OFAC had sanctioned Martelly under Executive Order 14059, "Imposing Sanctions on Foreign Persons Involved in the Global Illicit Drug Trade." Treasury said Martelly "abused his influence to facilitate the trafficking of dangerous drugs, including cocaine, destined for the United States." It said he engaged in laundering of illicit drug proceeds, worked with Haitian drug traffickers and "sponsored multiple Haiti-based gangs." Acting Under Secretary Bradley T. Smith said the action emphasized "the significant and destabilizing role he and other corrupt political elites have played in perpetuating the ongoing crisis in Haiti." Treasury also said Canada had sanctioned Martelly on Nov. 17, 2022. Those are Treasury's allegations and administrative findings. They are not a criminal conviction recited in the 2024 announcement.$

OFAC's same-day update added Martelly to the Non-SDN Menu-Based Sanctions List. The prohibitions listed there, and in Treasury's press release, are narrower than a full asset freeze. U.S. financial institutions may not make loans or extend credit to him. Transactions in foreign exchange that are subject to U.S. jurisdiction and in which he has any interest are prohibited. U.S. persons may not invest in or purchase significant amounts of his equity or debt instruments. He was not added to the Specially Designated Nationals and Blocked Persons List. Treasury's announcement also said the goal of sanctions "is not to punish, but to bring about a positive change in behavior." It pointed to OFAC's process for seeking removal from a sanctions list.

The engagement letter says Liberty will undertake only services it "reasonably determines are authorized by applicable U.S. sanctions laws and regulations." It says the firm may suspend or end the representation if a service, payment, communication or transaction "may be prohibited or requires further OFAC authorization." Listed services include developing advocacy strategies concerning specified sanctions policy, executive orders or OFAC designations, "including the Sanctioned Person." They also include communicating and meeting with "key administration officials and staff," and providing progress reports to the client. The firm does not, the letter says, guarantee any particular outcome, including a meeting, a policy change or the removal of a designation. The initial term runs from Oct. 22, 2026, to Dec. 31, 2026, then month to month, with 30 days' written notice to terminate.

A separate clause, titled "Relationship Between Martelly and Client," is written to keep Martelly off the payment trail. Invisible Investigations "confirms and acknowledges that the Sanctioned Person will not directly or indirectly reimburse or otherwise compensate Client in any manner for its payments of fees and expenses to Lobbyist." The client also warrants that it "will not engage in any foreign exchange transactions in connection, directly or indirectly, with the services and payments described herein." It warrants that "all funds used to pay Lobbyist for the services and expenses described herein will originate exclusively from U.S. dollars presently held at financial institutions within the United States." Those are contractual representations. The FARA forms do not include bank records that would allow a reader to test them.

The fees in the letter and the $75,000 already reported#

The compensation section of the Oct. 22 letter is larger than the amount reported as already received.

Invisible Investigations, the letter says, agrees to pay an initial contract deposit of $125,000 within 10 days of acceptance, to be credited toward a final payment. It also agrees to a monthly retainer of $50,000, payable on the first business day of each month, and reimbursement of pre-approved out-of-pocket expenses, capped at $5,000 a month unless the client approves a higher amount in writing. Unearned portions of the deposit or retainer are to be returned at the end of the representation, subject to professional-conduct rules.

The registration statement and Exhibit B, however, report a single receipt in the 60 days before registration: a $75,000 "Contract Deposit" received on Sept. 10, 2026, from Invisible Investigations LLC, for the foreign principal "Michel Joseph Martelly (through Invisible Investigations LLC)." No other receipt is listed. The firm reported no disbursements on the principal's behalf in that period.

The dates do not line up neatly. The $75,000 is recorded about six weeks before the Oct. 22 letter and the Oct. 26 signatures. The letter says it supersedes any prior agreement. It specifies a $125,000 deposit, not $75,000. The FARA forms do not explain the difference. They do not attach an earlier contract. They do not say whether the $75,000 is a first installment toward the $125,000, a separate prior fee, or something else. The only amount the Justice Department filing reports as actually received, as of the Nov. 5 stamp, is $75,000.

Darling's short form, asked about compensation, checks "Salary: Not based solely on services rendered to the foreign principal(s)." It does not list a dollar figure on that line. The firm's registration is the document that reports the $75,000.

The same short form, and the registration, disclose two of Darling's own campaign contributions in the look-back window, both dated Sept. 28, 2026, and made in cash: $500 to Davidson for Congress and $2,500 to Reinventing a New Direction PAC. Those gifts are required disclosures on a FARA short form. They are not, without more, evidence that the recipients have any role in the Martelly work. The forms list no contacts with those committees about Haiti or OFAC.

Haiti policy is the backdrop#

Martelly, a former musician known as Sweet Micky, was president of Haiti from 2011 to 2016. The 2024 Treasury action, and the 2026 contract that seeks a change in sanctions policy, sit against a country still facing armed groups, disputed politics and a heavy foreign security presence. 567 Politics has recently reported on Haitian gang leader Wilson Joseph's letter seeking United Nations talks and on Salvadoran President Nayib Bukele's unverified claim that his forces destroyed a gang leader's house. Those stories are about security operations in Haiti, not about Martelly's designation. They are the current setting in which a former president's U.S. sanctions status remains a live political fact.

Exhibit A describes the foreign principal's activity as "Politician." It answers "no" to every question about whether he is supervised, owned, directed, controlled, financed or subsidized by a foreign government or political party. The firm is therefore registering for an individual, not for the Haitian state. That distinction matters. A former official can hire a lobbyist without making the current government the client. It also means the filing does not show any authorization from today's Haitian authorities.

Invisible Investigations LLC is the contracting client and the source of the reported $75,000. Haynes signed for that company. The FARA forms do not describe Haynes's relationship to Martelly. They do not attach Invisible Investigations' ownership records. They do not say how the Miami firm came to hold the U.S. dollars the letter says will be used for payment. Those are open questions, not conclusions.

What the people involved have said, and what they have not#

Treasury's 2024 announcement is the U.S. government's public case for the designation. The engagement letter is the most detailed public statement, in this record, of what Darling's firm has agreed to try to change and how it intends to go about it. Liberty's website, reviewed on Nov. 10, 2026, describes Darling as a lobbyist and former communications director and counsel to Sen. Rand Paul$ who earlier spent seven years at the Heritage Foundation. It lists the same 15th Street address that appears on the FARA forms. The site does not mention Martelly or the November registration.

567 Politics did not obtain a comment from Darling, Liberty Government Affairs, Haynes, Invisible Investigations, Martelly or the Treasury Department about the new filing. In 2024, news organizations reporting the original designation said they could not reach Martelly for comment. This story does not treat that earlier silence as a current response. If Martelly, the firm or Treasury later issues a statement, it should be added.

A 567 Politics review of FARA records on Jason Miller's work for India showed how official contact logs and fee figures can be disclosed without proving what was said or whether any rule was broken. The same caution applies here, in the other direction. A detailed contract and a reported deposit do not prove that OFAC will change course, that a meeting has been granted, or that any sanctions law has been breached. A story on Katie Wiles's firm's disclosed lobbying fees is a reminder that public filings can document money and still leave influence claims unsettled.

What the Nov. 5 packet shows is narrower and still significant. A former Haitian president who is on the Treasury Department's Non-SDN Menu-Based Sanctions List, and who is not on the SDN list, is the named beneficiary of a U.S. lobbying contract. A Miami company signed that contract. It represented that it would pay from U.S. bank funds and that Martelly would not reimburse it. According to the registration, it had already sent $75,000 in September. The lobbyist's written assignment is to try to change a sanctions policy at Treasury and the State Department. Whether that assignment produces a meeting, a petition for delisting, a rejection, or nothing will have to be read from later FARA supplements and from OFAC's own records. Those later records are not in this filing.