{"id":"BIH-041","notes":"STAGE 6 STRUCTURAL ENABLER — Financial Surveillance Capacity. CAMPAIGN ASSIGNMENT: BIH-CAMP-005 (state-level AML/FATF NPO surveillance). This is the first state-level BiH case in the database — all prior BiH cases are RS-entity level. CROSS-COUNTRY AML PATTERN — now documented at state level in BiH: Serbia (SRB-015 AMLU 2020); Georgia (GEO-011 Moneyval Dec 2020 → GEO-016 ACB Jun 2025); BiH state level (BIH-041 Apr 2026). The \"continuous identification with no pre-defined list\" mechanism is the administrative uncertainty tactic in its purest documented form. The Permanent Coordinating Body (established July 2025) operationalizes what the RS has done through tax inspection — but at state level and under explicit FATF legitimacy cover. FATF grey list threat (decision possible mid-2026) creates urgency frame that accelerates adoption without CSO consultation. Source: RSE April 17 2026 — Milorad Milojević reporting.","country":"Bosnia and Herzegovina","sources":[{"url":null,"citation":"Radio Slobodna Evropa (RSE) April 17 2026 — primary (https://www.slobodnaevropa.org/a/bosna-hercegovina-nvo-pranje-novca-terorizam/33396155.html); BiH Council of Ministers Instructions on Control of Risk Organizations (primary regulatory document — full text not yet obtained)"}],"summary":"BiH Council of Ministers adopts Instructions on Control of Risk Organizations (April 17, 2026), establishing a sector-wide AML/financial surveillance framework targeting non-profit organizations. KEY PROVISIONS: (1) Donations above €15,000 automatically subject to enhanced investigation — above this threshold, funds are treated as subject of investigation, not standard donation; (2) Organizations receiving funds from FATF \"black list\" countries (Iran, North Korea, Myanmar) or \"grey list\" countries (Algeria, Angola, Lebanon, Syria, Yemen, DRC, Haiti, Kenya, Monaco, Venezuela) subject to automatic enhanced scrutiny; (3) No pre-defined list of \"risk organizations\" — \"continuous identification\" based on risk indicators, operational intelligence, and financial flow analysis; (4) Risk assessment outputs distributed to: Financial Intelligence Department (FOO) at SIPA (State Investigation and Protection Agency), police and security agencies, supervisory and inspection bodies; (5) Banks explicitly included as mandatory monitoring actors — obliged to monitor and report unusual transactions; (6) Organizations flagged as \"risk\" face enhanced targeted surveillance, not formal prohibition — but all transactions above €15,000 monitored. JUSTIFICATION FRAME: FATF/Moneyval compliance presented as primary rationale — BiH previously on FATF grey list 2015-2018; risk of return to grey list cited as justification for measures. Economic expert Željko Rička cited in RSE: \"Given that NGOs worldwide are often used for money abuse, the legislator has made additional strengthening precisely in the part relating to terrorism financing. We currently have about 27,000 registered NGOs and the probability that someone is abusing the system for money transfer is quite large.\" COORDINATION MECHANISM: Permanent Coordinating Body for Prevention of Money Laundering and Terrorist Financing (40+ experts from state and entity institutions) established July 2025 — now operational. Sub-group for NPO Terrorist Financing Risk Assessment will continuously identify risk organizations and compile lists. ANALYTICAL SIGNIFICANCE — CROSS-COUNTRY PATTERN: This is the BiH state-level operationalization of the same AML/FATF architecture documented in: Serbia (AMLU/SRB-015 — bank letters requesting CSO transaction monitoring); Georgia (Moneyval Rec 8 non-compliance → foreign agent legislation — GEO-011). The \"continuous identification\" mechanism with no pre-defined list is analytically equivalent to Georgia's ACB inspection waves — administrative uncertainty as restriction mechanism. The inclusion of SIPA (security agency) in the information chain formally links financial surveillance to the security apparatus.","tactics":[{"code":"TC-19","role":"primary","label":"AML/CFT Framework Weaponization","needs_review":false},{"code":"TC-24","role":"secondary","label":"Administrative CSO Burdening","needs_review":false}],"version":1,"channels":["Official/Regulatory"],"entities":[{"id":759,"name":"BiH Council of Ministers (originating actor — adopts instructions); Permanent Coordinating Body / Sub-group for NPO TF Risk Assessment (operational implementation); SIPA / FOO (security apparatus — receives risk assessment outputs); Banks (mandatory monitoring actors); Radio Slobodna Evropa (RSE) — source/dissemination","role":"actor","entity_type":"Government Official"},{"id":760,"name":"All registered NPOs in BiH (approx. 27,000 organizations); organizations receiving donations above €15,000; organizations receiving funds from FATF-listed countries; organizations with activities deemed disproportionate to funding","role":"target","entity_type":"Sector"}],"date_text":"17/04/2026","created_at":"2026-09-24T17:50:55.358311+00:00","escalation":4,"harm_track":"Track 1 — Legal/Administrative","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-041"],"updated_at":"2026-09-24T17:50:55.358311+00:00","occurred_on":"2026-04-17","campaign_ids":["BIH-CAMP-005"],"enabler_type":"Financial Surveillance Capacity","response_ids":[],"trigger_type":"TR-06: Legislative Milestone","campaign_phase":"Phase 4: Institutional Operationalization","civic_response":"Not documented in source at time of coding. Civil society response to be monitored.","date_precision":"day","enabler_status":"Active — operational from April 2026","campaigns_served":["BIH-CAMP-005"],"consequence_category":"Legal/Administrative","institutional_consequence":"Sector-wide financial surveillance of ~27,000 NPOs; €15,000 threshold converts standard donations into investigation triggers; continuous risk identification with no pre-defined criteria — administrative uncertainty as restriction; SIPA security apparatus formally integrated into NPO financial monitoring; banks obligated as surveillance infrastructure; organizations from FATF-listed countries automatically flagged"}