The Tollbooth State: How Nicaragua Turned Sovereignty Into a Revenue Line

This month, at the 47th anniversary of the Sandinista revolution, Daniel Ortega declared that Nicaragua was finished with elections. “Never, never, never,” in his words. Whatever democratic pretense remained was gone. But a government that has dispensed with voters still needs revenue, and the Murillo-Ortega dictatorship has spent the past five years assembling a portfolio built around a single asset: sovereignty itself. Visa policy, mining concessions, border territory, and even security cooperation are all for rent.

Migration was the proof of concept. Beginning in late 2021, Managua dropped visa requirements for Cubans and then Haitians, and charter flights carrying more than 190,000 passengers in a single year turned the airport into a tollbooth. Haitian passengers paid $3,000 to $5,000 for one-way seats on routes that normally cost a fraction of that, while the state collected fees from every arrival. US visa restrictions and a joint State, DHS, and Treasury aviation advisory eventually squeezed the pipeline.  The corridor has since cooled, but that is the point. The regime did not abandon the model when one product line got squeezed.  It simply found another.

Gold is now the flagship product. Since 2020, the regime has restructured the mining sector into a network of front companies and regime-linked intermediaries to generate foreign currency, launder sanctioned assets, and reinforce political control, with the state miner ENIMINAS deciding who digs and who profits. Treasury’s Office of Foreign Assets Control laid out the machinery in unusual detail this April, sanctioning seven gold companies in a single day alongside two of Ortega and Murillo’s sons and the vice minister of energy and mines. One firm, EMSA, collected unrefined gold from six sites, smelted it in Managua, and sold it in bulk in the United States; Treasury assesses that the proceeds may have been used to equip and pay regime paramilitaries. Another, Xinxin, shipped over $25 million in gold to the US in 2025 alone.

The designations also documented the evasion playbook. When OFAC sanctioned the mining firm COMINTSA in May 2024, the company’s legal representative transferred its concessions to another gold company, Zhong Fu Development, before the action, then to a third, Thomas Metal, after it, with a notary expediting the paperwork. Firms with little or no mining history received tens of thousands of acres in concessions. Grupo Minero Xiloa, itself designated in April, rose to prominence precisely because its predecessors were sanctioned, buying artisanal gold in cash and exporting it through allied companies to place illicit funds in the US financial system. Sanctioning a Nicaraguan gold company is sanctioning a costume, and the regime keeps a full wardrobe. The gold, the concessions, the managers, and the buyers all stay the same.   Only the nameplate on the exporter changes.

The Chinese connection adds another layer to the tollbooth model. The regime is not simply monetizing Nicaragua’s resources. It is granting foreign actors access to the concessions and territory that make those resources valuable. Costa Rican officials accuse Chinese companies operating on the Nicaraguan bank of the San Juan River of buying gold-bearing sediment illegally extracted from Costa Rica’s Crucitas reserve, where illegal mining has expanded from roughly 900 to more than 3,000 hectares. Researchers at Fundación del Río have identified 15 Chinese companies holding mining concessions covering roughly 8.5 percent of Nicaraguan territory, much of it granted after the regime amended five laws to facilitate the expansion. 

The financial flows deserve scrutiny as well. Trade data point to roughly $32 million in apparent under-invoicing on exports to China, a discrepancy consistent with techniques used in trade-based value transfer. Two companies designated by OFAC in April have direct Chinese ties, including one whose president was previously identified in the seizure of a gold plant backed by US investment.  The commodity is gold, but the more valuable underlying asset being sold is access.  

A state that rents out its sovereignty attracts tenants, and Moscow signed its lease years ago. OFAC’s May 2024 gold action arrived alongside its designation of the Russian Interior Ministry’s training center in Managua, which schools the regime’s security forces in the Russian playbook of repression. Gold companies and a Russian police academy in the same press release is the Nicaraguan business model in miniature.

There are three practical implications for financial institutions and investigators.  First, static list screening is not enough when the underlying network is playing concession musical chairs. The relevant unit of analysis is not simply the sanctioned company, but the network around it: legal representatives, notaries, concession transfers, managers, buyers, and successor entities. OFAC’s April action effectively published part of that map. Second, this is not exotic offshore risk. Nicaraguan gold entered the US financial system through bulk sales and eight-figure shipments, creating exposure for refiners, bullion dealers, traders, and the financial institutions behind them. Third, Treasury appears to be asking the private sector to help identify what comes next. The April action paired a warning about secondary sanctions exposure for foreign financial institutions with a direct reference to FinCEN’s whistleblower program. The message is difficult to miss: some of the next useful leads may already sit inside the industry. 

A regime that has just declared elections finished is telling the world its revenue model is permanent. Migration tolls, gold concessions, foreign access, and sanctions evasion are not separate stories. They are different revenue lines built around the same asset: the state itself.  Nicaragua is not hiding the tollbooth. It is expanding it.

Meridian3 is an investigations and intelligence firm working at the intersection of open-source intelligence, financial intelligence, sanctions, and digital assets. We focus on the networks that move money, influence, and power across borders, and the financial and commercial infrastructure that makes those networks possible.