{"id":"BIH-020","notes":"AML-by-practice: the foreign agent registry that failed legislatively (BIH-015) is implemented through administrative inspection. Demanding 5-year donor lists during tax audits achieves the same data collection a foreign agent registry would have. Selective enforcement (CSOs fined, football clubs exempt) proves political motivation. Detection signal: when tax inspections specifically ask about foreign donors, treat as foreign agent narrative operationalized. | DATE UPDATE: Date refined: wave of unannounced inspections peaked March-June 2023. Strategically timed alongside public/parliamentary debates on Draft Law on Special Registry (foreign agent law). Key tactic: \"5-year donor list\" demand — inspectors shifted from standard audits to demanding exhaustive international donor lists dating back 2018-2019. Sources: BCSDN Monitoring Matrix BiH 2023; CPCD/TI BiH joint statement mid-2023.","country":"Bosnia and Herzegovina (Republika Srpska)","sources":[{"url":null,"citation":"BCSDN Monitoring Matrix BiH 2023"}],"summary":"RS tax inspectors conduct unannounced inspections of multiple CSOs, specifically demanding lists of all international donors over the past 5 years — framing foreign funding as inherently suspicious. Inspections target larger, more vocal organizations. Fines are 'unreasonably high' and inspectorates 'never issue advisory measures, only sanctions.' Youth organization fined for last 5 years while football clubs owe millions with no consequences.","tactics":[{"code":"TC-19","role":"primary","label":"AML/CFT Framework Weaponization","needs_review":false}],"version":1,"channels":["Official/Regulatory"],"entities":[{"id":723,"name":"RS Tax Inspectorate","role":"actor","entity_type":"Prosecutor/Judicial"},{"id":726,"name":"Multiple CSOs in RS (larger and more vocal organizations targeted)","role":"target","entity_type":"Sector"}],"date_text":"Mar 2023","created_at":"2026-09-24T17:50:55.358311+00:00","escalation":3,"harm_track":"Both","narratives":[{"code":"NF-03","role":"primary","label":"Financial Corruption / AML Framing","needs_review":false},{"code":"NF-01","role":"secondary","label":"Foreign Agent / Foreign Influence","needs_review":false}],"report_ids":[],"signal_ids":["SIG-BIH-020"],"updated_at":"2026-09-24T17:50:55.358311+00:00","occurred_on":"2023-03-01","campaign_ids":["BIH-CAMP-003"],"enabler_type":"Financial Surveillance Capacity","response_ids":[],"trigger_type":"TR-08: Proactive / Ambient","campaign_phase":"Phase 4: Institutional Operationalization","civic_response":"","date_precision":"month","enabler_status":"Active","campaigns_served":["BIH-CAMP-003","BIH-CAMP-004"],"consequence_category":"Legal/Administrative + Social Trust Erosion","institutional_consequence":"Financial surveillance; Chilling effect"}