APG Mutual Evaluation — Civic Submission Template
A citation-only civic submission template framed for the FATF / Asia-Pacific Group on Money Laundering Mutual Evaluation of Sri Lanka. Structural observations only — no named entities, no accusations of individuals, no substitute for law enforcement.
Hard rules — non-removable
- ·No named individuals, no named businesses, no named diaspora entities.
- ·No accusations — structural observations only, anchored to published Tier-A sources.
- ·Never frames TLTE as a law-enforcement body. APG civic submissions are an input to assessors, not a complaint.
- ·Never presents aggregate ‘Tamil money’ or ‘diaspora wealth’ figures.
- ·Always pairs an NE Tamil source with a Sri Lankan / international institutional source.
Template structure
1. Identity of the submitter
TLTE submits as a civic-research framework registered in the United Kingdom. No client, no funder, no individual signatory. The submission is published openly on this surface in the same form sent to APG.
2. Scope
Limited to the structural intersection of post-2009 militarisation, the documented shadow economy in the Northern and Eastern provinces, and AML/CFT effectiveness — not to any specific predicate offence, person, or transaction.
3. Citation-only evidence base
Anchored exclusively to: APG Mutual Evaluation framework; FATF Recommendations 2012 (as amended); NDDCB published drug-incidence figures; HRCSL annual reports; CPA and Verité Research publications; Adayaalam NE monitoring; ICG and OHCHR reports. No primary intake, no field interviews, no leaked material.
4. Structural observations (no entities named)
Three structural observations follow Staniland 2014 and Schultze-Kraft 2017: (a) post-2009 ‘armed orders’ in the NE coincide with a documented heroin and methamphetamine economy (NDDCB); (b) successive HRCSL annual reports flag custodial and accountability gaps without naming perpetrators; (c) the gap between Sri Lanka's ICCPR / ICERD treaty ratification and enforcement creates an environment in which AML/CFT effectiveness is structurally degraded for minority-region civic actors.
5. Specific question to the assessment team
Whether the APG assessment methodology gives sufficient weight to the structural interaction between minority-region militarisation and AML/CFT effectiveness in a single political settlement — as distinct from treating them as separate domains.
6. What this submission is NOT
Not a complaint against any person. Not a request to designate any entity. Not a request to freeze any account. Not a substitute for law enforcement or for the Sri Lankan Financial Intelligence Unit. Not an aggregate diaspora-finance claim.
7. Publication
Mirror-published on this surface under the Recorded Legal Memory protocol. Any APG response received is published in full alongside the submission.
Two-layer disclosure
Now (Aarambam)
TLTE is a UK-registered civic-research framework. It cannot designate any entity, freeze any account, or compel any disclosure. This template exists so that diaspora researchers can engage international AML/CFT processes through the front door rather than through unsourced campaign material.
Becoming (Nilaiththanmai)
A standing civic-submissions desk that mirror-publishes every APG, UPR, Treaty-Body and EU GSP+ submission alongside the response received — so the record of what was said, by whom, and what came back, is permanent and public.
Anchor sources
Stable citation IDs in the tlte-cite: namespace. Each link resolves to a permanent record at docs.tlte.cloud/cite/<slug> with title, publisher, archive URL, and reuse guidance.
- KNOMAD Migration and Remittances Data — South Asia
tlte-cite:wb-knomad-remittancesWorld Bank, Global Knowledge Partnership on Migration and Development (KNOMAD) · World Bank GroupPrimary remittance-corridor dataset. Used to size diaspora economic flows without speculative 'Tamil GDP' aggregation.
- Annual Report — External Sector chapter (Remittances)
tlte-cite:cbsl-annual-reportCentral Bank of Sri Lanka · CBSL, ColomboSri Lankan state's own reporting on monthly worker remittances by source country. Pair with KNOMAD for the honesty-index pattern.
- IMF Country Report — Sri Lanka (Article IV Consultation series)
tlte-cite:imf-article-iv-lkaInternational Monetary Fund · IMF, Washington DCMacroeconomic baseline for evaluating the state's dependence on diaspora-driven remittance inflows.
- The Sri Lankan Tamil Diaspora after the LTTE (Asia Report 186)
tlte-cite:icg-diasporaInternational Crisis Group · ICG, 23 February 2010Structural map of post-2009 diaspora political and economic networks across UK, Canada, Europe, and Australia.
- UK Sanctions List — Consolidated List of Financial Sanctions Targets
tlte-cite:uk-ofsi-consolidatedHM Treasury — Office of Financial Sanctions Implementation (OFSI) · UK GovernmentPrimary UK sanctions instrument. Used to surface the existence of designations relevant to Sri Lanka; TLTE never adds names of its own.
- Specially Designated Nationals And Blocked Persons List (SDN)
tlte-cite:us-ofac-sdnUS Treasury — Office of Foreign Assets Control (OFAC) · US Department of the TreasuryAuthoritative US sanctions list. Mirror of OFSI for the diaspora-economy honesty-index pattern.
- The Global Human Rights Sanctions Regulations 2020 (UK Magnitsky)
tlte-cite:uk-magnitsky-2020UK Government · legislation.gov.uk, S.I. 2020/680Statutory instrument enabling UK targeted human-rights sanctions. Cited as the *legal mechanism*, not as a list of names.
- FATF / Asia/Pacific Group on Money Laundering — Mutual Evaluation framework and Sri Lanka schedule
tlte-cite:apg-merAsia/Pacific Group on Money Laundering (APG) · APG / FATFAPG conducts FATF-style Mutual Evaluations of AML/CFT effectiveness for Asia-Pacific jurisdictions including Sri Lanka. Civic submissions are received into the assessment process. The Civilian Safety sub-page references the APG schedule as the highest-leverage international forum into which civic-grade structural concerns about the NE shadow economy can be submitted — without naming entities, accusing individuals, or substituting for law enforcement.
- FATF Methodology for Assessing AML/CFT Compliance and Effectiveness
tlte-cite:fatf-apg-methodFinancial Action Task Force · FATFProcedural ground for what civic submissions to an APG Mutual Evaluation may contain. The Observatory uses this to scope what structural risk indicators may be submitted — and what may not (named allegations against individuals/entities).
- Central Bank of Sri Lanka — Worker Remittances data
tlte-cite:ecumene-cbsl-remittanceCentral Bank of Sri Lanka · CBSLCountry-pair remittance flows. Cited as the available proxy for diaspora financial flows into the Eelam region — explicitly never disaggregated by ethnicity, because the data are not ethnic.
- World Bank KNOMAD Bilateral Remittance Matrix
tlte-cite:ecumene-knomadWorld Bank KNOMAD · World BankBilateral remittance dataset. Cited as the multilateral source for country-pair corridors referenced from Ecumene node pages. No 'Tamil corridor' exists in any public dataset; KNOMAD country pairs are the honest available proxy.
- FATF — Mutual Evaluation methodology and Recommendation 8 (Non-Profit Organisations) guidance
tlte-cite:fatf-methodFinancial Action Task Force · FATF — fatf-gafi.orgFATF methodology governs Asia/Pacific Group (APG) Mutual Evaluation Reviews of Sri Lanka and recipient/transit jurisdictions of diaspora flows. Recommendation 8 governs NPO sector risk-based supervision — the framework under which lawful Tamil diaspora welfare work now operates after the TRO designation history and broader post-9/11 CTF environment. The TLTE APG civic submission template is structured to the FATF Immediate Outcomes IO.1/3/6/7/11.
- Funding the 'Final War'
tlte-cite:hrw-funding-the-final-warHuman Rights Watch · HRW (March 2006)Documents coerced contributions from diaspora communities to LTTE structures. Establishes — in HRW's framing — that coerced donors are extortion victims, with implications for civil-tort and asset-recovery work.