{"code":"TC-19","label":"AML/CFT Framework Weaponization","category":"Regulatory","definition":"Anti-money laundering and counter-terrorist financing frameworks are weaponized to restrict civil society financing and operation. Operates at three levels: (1) state FIU/APML — financial intelligence unit directly deploys against CSOs under FATF compliance framing, requesting transaction data or placing organizations on monitoring lists; (2) banking sector — financial institutions misclassify the CSO sector as structurally high-risk under AML/CFT rules, producing account closures and transaction refusals without legislation; (3) international standards — FATF/Moneyval non-compliance findings or Recommendation 8 obligations are exploited as legitimacy cover for domestic CSO surveillance embedded in foreign agent or transparency legislation. In all cases the AML/CFT architecture provides deniable, internationally legitimate justification for politically directed restriction.","needs_review":false,"instrument_type":"Regulatory","detection_signal":"APML request for CSO financial data; CSO names on financial monitoring lists; banks closing CSO accounts citing AML risk without specific legal trigger; CSO sector designated high-risk in banking compliance frameworks; FATF/Moneyval non-compliance cited in foreign agent bill preambles; Recommendation 8 language in government consultation documents."}
