{"id":"GEO-013","notes":"THIRD ROUND OF ACB INSPECTIONS — escalation documented: Round 1: June 2025 (8 organizations, court orders for documents); Round 2: August 2025 (6 organizations, FARA inspection letters); Round 3: September 22 2025 (20+ organizations, Grants Law inspections). The destruction of sensitive beneficiary data is analytically significant: organizations are forced to destroy their own records to protect beneficiaries from state surveillance — this is the most direct documented case of state surveillance forcing self-destruction of civil society institutional memory. Targeted sectors include torture victim support and LGBTQIA+ rights — the most vulnerable beneficiary populations. CIVICUS downgrade to \"Repressed\" (first two-consecutive-year downgrade) frames the cumulative effect. Cross-ref GEO-005 (August 27 account freezes), GEO-010 (ACB abolished November 2025 after serving repression function).","country":"Georgia","sources":[{"url":null,"citation":"FIDH September 25 2025 (https://www.fidh.org/en/issues/human-rights-defenders/georgia-escalating-repression-over-20-georgian-csos-targeted-by-the-anti-corruption-bureau); GNDEM July 2 2025 statement; HRW UPR submission July 23 2025; IBAHRI October 1 2025"}],"summary":"Third round of Anti-Corruption Bureau inspections against Georgian CSOs (September 22, 2025). At least 20 civil society organizations receive ACB letters demanding extensive documentation under the Amended Law on Grants: grant agreements; donor information; activity reports; work contracts; sensitive and confidential personal data of beneficiaries. Letters do not detail legal basis or factual circumstances warranting inspection. ACB submits motions to Tbilisi City Court — court issues orders against nine organizations obliging them to provide requested information. TARGETED SECTORS: organizations providing legal and psychosocial support to torture victims; gender equality organizations; LGBTQIA+ rights organizations. All targeted organizations publicly refuse to provide information citing confidentiality obligations to beneficiaries — declare they have partially destroyed sensitive information. ESCALATION SEQUENCE: June 2025: 8 organizations receive court orders for documents; August 2025: 6 organizations receive FARA inspection letters; August 27 2025: 7 organizations bank accounts frozen (GEO-005); September 22 2025: 20+ organizations receive ACB inspection letters. GYLA documents GEL 2 million in fines on protesters November 28 2024 — March 18 2025. HRW UPR submission July 2025: \"Smear campaigns of posters in cities featured images of NGO leaders and critical journalists, calling them traitors and enemies.\" CIVICUS March 2026: Georgia rated \"Repressed\" — first country downgraded in two consecutive years.","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":791,"name":"Anti-Corruption Bureau (ACB); Tbilisi City Court (court orders); Prosecutor's Office of Georgia","role":"actor","entity_type":"Government Official"},{"id":792,"name":"At least 20 civil society organizations including: Human Rights Center Georgia; organizations providing legal aid to protest victims; gender equality CSOs; LGBTQIA+ rights organizations; ISFED; Social Justice Center; Sapari; Civil Society Foundation","role":"target","entity_type":"Sector"}],"date_text":"22/09/2025","created_at":"2026-09-24T17:50:55.358311+00:00","escalation":5,"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-GEO-013"],"updated_at":"2026-09-24T17:50:55.358311+00:00","occurred_on":"2025-09-22","campaign_ids":["GEO-CAMP-001"],"enabler_type":"","response_ids":[],"trigger_type":"TR-06: Legislative Milestone","campaign_phase":"Phase 5: Systemic Assault","civic_response":"All targeted organizations publicly refuse to provide information; cite confidentiality obligations; declare partial destruction of sensitive data; joint statement September 22 2025; GNDEM solidarity statement July 2025; FIDH/OMCT urgent intervention September 25 2025","date_precision":"day","enabler_status":"","campaigns_served":[],"consequence_category":"Legal/Administrative","institutional_consequence":"20+ organizations under ACB inspection; nine organizations subject to court orders; confidential beneficiary data at risk of state seizure; organizations providing legal aid to protest victims paralyzed; sector-wide chilling effect — organizations destroying sensitive data"}