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SIG-BIH-020

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country
BiH (RS)
date text
Mar 2023
actor text
RS Tax Inspectorate
campaign id
BIH-CAMP-003
confidence 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 ex | 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.
date confidence
month_year
excerpt
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.
id
SIG-BIH-020
incident id
BIH-020
normalized date
2023-03-01
observation
country
BiH (RS)
actor primary
RS Tax Inspectorate
actor type primary
Prosecutor/Judicial
campaign id
BIH-CAMP-003
campaign phase
Phase 4: Institutional Operationalization
campaigns served
BIH-CAMP-003; BIH-CAMP-004
case id
BIH-020
channel primary
Official/Regulatory
confidence 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 ex | 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.
consequence category
Legal/Administrative + Social Trust Erosion
date confidence
month_year
enabler status
Active
enabler type
Financial Surveillance Capacity
escalation stage
4
event date normalized
2023-03-01
event date raw
Mar 2023
harm track
Both
institutional consequence
Financial surveillance; Chilling effect
primary narrative code
NF-03
primary narrative label
Financial Corruption / AML
secondary narrative code
NF-01
secondary narrative label
Foreign Agent / Foreign Influence
secondary source url
https://www.ohchr.org/en/press-releases/2025/02/bosnia-and-herzegovina-bill-registering-ngos-will-increase-government
signal id
SIG-BIH-020
source text excerpt
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.
source type
Official/Regulatory
source url
https://balkancsd.net/cpcd-publishes-2023-report-on-the-civil-society-environment-in-bosnia-and-herzegovina/
tactic code
Regulatory / Financial Inspection (foreign donor list demands)
target
Multiple CSOs in RS (larger and more vocal organizations targeted)
target type
Sector
trigger type
TR-08: Proactive / Ambient
secondary source url
https://www.ohchr.org/en/press-releases/2025/02/bosnia-and-herzegovina-bill-registering-ngos-will-increase-government
source type
Official/Regulatory
source url
https://balkancsd.net/cpcd-publishes-2023-report-on-the-civil-society-environment-in-bosnia-and-herzegovina/
target text
Multiple CSOs in RS (larger and more vocal organizations targeted)

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