{"id":"SRB-071","notes":"ANALYTICALLY IMPORTANT: personal bank account surveillance of individual leaders, not organizational accounts. Targets individuals to circumvent organizational legal protections. Timing: February 2025 — between USAID suspension (Feb 3) and raids (Feb 25). Three-event sequence: USAID suspension (Feb 3) → AMLU bank letters (Feb 2025) → raids (Feb 25). CINGO formal letter = international documentation at CoE level. Cross-ref SRB-015 (APML 2020 financial monitoring — same tactic, earlier activation establishing the infrastructure). Exact date within February 2025 TBC — primary source confirms February but not specific day.","country":"Serbia","sources":[{"url":null,"citation":"CINGO Second Report on Serbia (September 2025 visit, first draft) — primary source documenting CINGO letter to CoE Permanent Representative; CINGO letter to CoE (February 2025)"}],"summary":"Administration for the Prevention of Money Laundering and Financing of Terrorism (AMLU) sends letters to all banks in Serbia requesting data, information, and documentation regarding personal bank accounts of leaders of five NGOs. Request targets individual leaders' personal accounts — not organizational accounts — indicating financial surveillance of individuals, not just organizations. CINGO sends formal letter to the CoE Permanent Representative of Serbia in response, sharing concerns about incompatibility of such requests with Council of Europe standards on non-governmental organisations and the right to freedom of association. CINGO letter constitutes formal international documentation of this Track 1 financial surveillance activation. Timing: February 2025 — same month as USAID suspension (Feb 3) and three weeks before CSO raids (Feb 25). Establishes financial profile of individual CSO leaders immediately before coordinated raids. Pattern: AMLU financial surveillance precedes physical raids — same sequence as SRB-015 (APML 2020) preceding the 2020-2022 AML weaponization arc.","tactics":[{"code":"TC-19","role":"primary","label":"AML/CFT Framework Weaponization","needs_review":false}],"version":1,"channels":["Official/Regulatory"],"entities":[{"id":971,"name":"Administration for Prevention of Money Laundering (AMLU); coordinated with MUP/BIA (inferred from timing)","role":"actor","entity_type":"Government Official"},{"id":972,"name":"Leaders of five named NGOs — personal bank accounts; CRTA, Građanske inicijative, CPP, Trag Foundation, KOMS (inferred from pattern matching Feb 25 raids)","role":"target","entity_type":"Individual Organization"}],"date_text":"Feb 2025","created_at":"2026-09-24T17:50:55.358311+00:00","escalation":5,"harm_track":"Track 1 — Legal/Administrative","narratives":[{"code":"NF-02","role":"primary","label":"Financial Corruption / Grant Abuse","needs_review":false},{"code":"NF-01","role":"secondary","label":"Foreign Agent / Foreign Influence","needs_review":false}],"report_ids":[],"signal_ids":["SIG-SRB-071"],"updated_at":"2026-09-24T17:50:55.358311+00:00","occurred_on":"2025-02-01","campaign_ids":["SRB-CAMP-006"],"enabler_type":"","response_ids":[],"trigger_type":"TR-03: Foreign Policy Event","campaign_phase":"Phase 4: Institutional Operationalization","civic_response":"CINGO sends formal letter to CoE Permanent Representative February 2025; concerns documented as incompatible with CoE standards on NGOs and freedom of association","date_precision":"month","enabler_status":"","campaigns_served":[],"consequence_category":"Legal/Administrative","institutional_consequence":"Personal financial data of five NGO leaders requested from all Serbian banks; CINGO formal letter to CoE Permanent Representative; financial profile established immediately before Feb 25 raids"}