The Ninth Circuit has determined that extortion, when accompanied by threats of violence, qualifies as persecution. If a protected ground (i.e., family ties) is at least a reason for this persecution, an applicant qualifies for withholding of removal.
The full text of Ayala v. Sessions can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2017/05/01/13-72250.pdf