Geopolitical Risk and Regulatory Compliance: A Strategic Analysis of Gazette Extraordinary No. 2470/19 and Sri Lanka’s Counter-Terrorism Designations

Disclaimer

This report is for informational purposes only and does not constitute legal, financial, or security advice. The analysis is based on publicly available data, government notifications, and international monitor reports accessible as of January 2026. While every effort has been made to ensure accuracy, readers should consult official government channels or qualified legal counsel for specific compliance requirements.

Editor's Note

The publication of Gazette Extraordinary No. 2470/19 on January 6, 2026, marks the most significant update to Sri Lanka’s counter-terrorism designation list since May 2025. This document serves as the primary legal trigger for domestic asset freezes and international law enforcement coordination. This analysis integrates the technical details of the Gazette with broader geopolitical trends and human rights considerations to provide a holistic view of Sri Lanka's current security environment.

Abstract: Human Rights and Impacts on Tamil Issues

The 2026 counter-terrorism designations continue to exert a profound impact on the Tamil community, both within Sri Lanka and in the global diaspora. While the state justifies these measures as necessary to prevent the resurgence of separatist militancy, international monitors and civil society groups highlight significant human rights concerns. Tamils in the Northern and Eastern provinces remain subject to high levels of surveillance and monitoring, particularly those involved in political activism or victim commemoration. The designation list is often cited as a tool that contributes to a climate of distrust and self-censorship, as peaceful advocacy for self-determination is frequently conflated with terrorism by state authorities. Furthermore, systemic discrimination in employment, education, and access to justice persists, with the Prevention of Terrorism Act (PTA) continuing to facilitate arbitrary detentions and the intimidation of community members. For the diaspora, the proscription of groups like the Transnational Government of Tamil Eelam (TGTE) and the  National Council of Canadian Tamils (NCCT) acts as a deterrent to public debate and humanitarian engagement, often stigmatizing those seeking accountability for conflict-era abuses.

Methodology

This research report was developed through a multi-layered investigative approach:

1.     Primary Legal Analysis: Detailed examination of the Gazette of the Democratic Socialist Republic of Sri Lanka, Extraordinary No. 2470/19, and its statutory foundations under the United Nations Act, No. 45 of 1968.⁹

2.     Data Categorization: Extraction and classification of entities and individuals listed in the First and Second Schedules, including the cross-referencing of identification data with international law enforcement notices.¹

3.     Conflict Cross-Referencing: Comparing the 2026 list with previous iterations (e.g., May 2025 and August 2022) to identify emerging threats and delisted parties.²

4.     Socio-Political Impact Assessment: Synthesizing reports from international bodies (UNHRC, ICJ) and human rights organizations (Amnesty International, Human Rights Watch) to evaluate the domestic consequences of these regulations.

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The publication of the Gazette of the Democratic Socialist Republic of Sri Lanka, Extraordinary No. 2470/19, on January 6, 2026, represents a critical juncture in the nation’s ongoing efforts to refine its domestic security apparatus and align its regulatory framework with international counter-terrorism standards.¹ Issued under the authority of the United Nations Act, No. 45 of 1968, and specifically through the implementation of Regulation 4(7) of the United Nations Regulations No. 1 of 2012, this legislative instrument provides an exhaustive update to the list of designated persons, groups, and entities associated with terrorism and terrorist financing.¹ The January 2026 amendment serves as a successor to the previous consolidated list from May 30, 2025, reflecting the dynamic nature of Sri Lanka’s threat environment and its commitment to the mandates of United Nations Security Council Resolution (UNSCR) 1373.³ This analysis delves into the statutory foundations, the specific entities and individuals identified, the transnational implications of the designations, and the broader geopolitical context that informs Sri Lanka's current security posture.

Statutory Foundations and the Role of the Competent Authority

The mechanism of Targeted Financial Sanctions (TFS) in Sri Lanka is governed by a robust legal architecture designed to identify and neutralize the financial lifelines of extremist organizations.⁵ The primary enabling statute, the United Nations Act, No. 45 of 1968, empowers the Minister of Foreign Affairs to issue regulations that give effect to the decisions of the UN Security Council.⁶ Under these regulations, the Secretary to the Ministry of Defence is appointed as the Competent Authority.¹ In the current context, Air Vice Marshal Sampath Thuyacontha (Retd) serves as the signatory for Gazette No. 2470/19, wielding the authority to mandate the immediate freezing of all funds, financial assets, and economic resources belonging to designated parties.¹

The 2012 Regulations established a process for national-level designations that bypasses the need for immediate judicial intervention, prioritizing the swiftness required to prevent the flight of capital.³ Upon the publication of the Gazette, a legally binding Freezing Order is automatically triggered, placing the onus on financial institutions, including licensed banks and finance companies, as well as Designated Non-Financial Businesses and Professions (DNFBPs) like real estate agents and jewelry dealers, to identify and secure assets.³ The scope of these freezes is comprehensive, extending beyond bank accounts to include immovable property, vehicles, and even intangible economic resources that could be used to facilitate terrorist acts.⁵

Regulatory Instrument	Date of Origin	Focus Area	Statutory Link
UN Regulations No. 1 of 2012	May 15, 2012	Implementation of UNSCR 1373 (Terrorism/Terrorist Financing)	UN Act No. 45 of 1968
UN Regulations No. 2 of 2012	May 31, 2012	Implementation of UNSCR 1267 (Al-Qaeda, ISIL, Taliban)	UN Act No. 45 of 1968
UN (DPRK) Regulations of 2017	Oct 06, 2017	Sanctions related to North Korea	UN Act No. 45 of 1968
Gazette 2470/19	Jan 06, 2026	Comprehensive update to designated schedules	Regulation 4(7) of 2012 Regs

The enforcement of these sanctions is not merely a domestic endeavor but is closely monitored by the Financial Action Task Force (FATF), which assesses nations based on their ability to disrupt the financing of terrorism (CFT).⁵ For Sri Lanka, the 2026 update signals to the international community that its intelligence-sharing and financial surveillance capabilities have recovered from the disruptions of previous years and are now operating with increased granularity.⁷

Analysis of the First Schedule: Designated Entities and Front Organizations

The First Schedule of the January 2026 Gazette identifies sixteen distinct entities, categorized by their ideological roots and operational mechanisms.¹ This list reflects the dual-track security challenge facing Sri Lanka: the residual threat of ethno-nationalist separatism following the 2009 end of the civil war, and the emerging threat of decentralized Islamist militancy.¹

Separatist Legacies and the Diaspora Network

The Liberation Tigers of Tamil Eelam (L.T.T.E.) remain the primary entry in the First Schedule (EN/CA/2026/01).¹ Despite their military defeat over fifteen years ago, the Gazette explicitly states that their "front organizations and structures" continue to remain active overseas, promoting the ideology of a "mono ethnic separate state of Tamil Eelam".¹ The state's assessment highlights that between 2012 and 2020, there were several observed resurgence attempts within the country facilitated by these overseas pro-L.T.T.E. groups.¹ This suggests that the current security doctrine views the diaspora's institutional capacity as the most significant long-term risk to domestic stability.

The entities listed to counter this risk include:

●       Tamil Rehabilitation Organization (T.R.O.) (EN/CA/2026/02): Designated for its role in funding terrorism, the Gazette provides specific bank accounts at Seylan Bank (072001498811003, 0720001498343001, and 072000149866101) for immediate seizure.¹ The inclusion of specific account numbers indicates a highly targeted approach to financial interdiction.

●       Tamil Coordinating Committee (T.C.C.) (EN/CA/2026/03): This group represents a sophisticated transnational logistical network, with listed addresses in France, the UK, Belgium, Switzerland, Germany, the Netherlands, Norway, Canada, Australia, and Italy.¹ The geographical breadth of the T.C.C. highlights the difficulty of a single-state response and underscores the necessity of international cooperation in freezing assets.¹

●       World Tamil Movement (W.T.M.) (EN/CA/2026/04) and National Council of Canadian Tamils (N.C.C.T.) (EN/CA/2026/11): Both entities are heavily concentrated in Canada, particularly in the Toronto and Scarborough regions.¹ The W.T.M. is associated with eight distinct Canadian addresses, signifying its role as a major financial and political hub for separatist advocacy.¹

●       Transnational Government of Tamil Eelam (T.G.T.E.) (EN/CA/2026/05): Headquartered in New York, the T.G.T.E. operates a public platform (www.tgte.org) and is designated for terrorism-related activities and funding.¹ Its status as a legally operating entity in the United States while being designated in Sri Lanka creates a persistent point of diplomatic and legal friction.¹²

 

Entity ID	Name	Primary Location	Strategic Role
EN/CA/2026/01	L.T.T.E.	Global	Ideological core; separatist advocacy.
EN/CA/2026/03	T.C.C.	Europe/Oceania	Cross-border logistics and coordination.
EN/CA/2026/04	W.T.M.	Canada	Diaspora mobilization and funding.
EN/CA/2026/05	T.G.T.E.	USA	Political representation of separatism.
EN/CA/2026/12	T.Y.O.	Global	Youth radicalization and recruitment.

The Islamist Threat Matrix and the Post-2019 Evolution

The Second category of entities in the First Schedule pertains to Islamist extremist groups, most of which gained prominence or entered the state’s focus following the 2019 Easter Sunday bombings.¹¹ The National Thowheed Jama'ath (N.T.J.) (EN/CA/2026/08) continues to be designated as the foundational extremist group in this milieu, with its registered headquarters in Batticaloa.¹ The Gazette also lists Jama'athe Milla'athe Ibrahim (J.M.I.) (EN/CA/2026/09) and Willayath As Seylani (W.A.S.) (EN/CA/2026/10), which are viewed as the local iterations of the Islamic State’s (IS) global network.¹⁴ Willayath As Seylani is particularly significant, as its start date of 2016 aligns with the period when IS was aggressively expanding its "provinces" beyond the Middle East.¹

A more recent addition to the schedule is "Super Muslim," also known as Sahabi Tharika (EN/CA/2026/16).¹ This group, which emerged in India in 2018 and established a Sri Lankan presence in 2019, represents a new wave of radicalization that utilizes encrypted communication channels.¹ The Gazette identifies a Telegram URL (https://t.me/supermuslimtamil/2482) as a primary source of radical content and funding coordination, reflecting the state’s adaptation to digital-first extremist movements.¹

The designation of "Save the Pearls" (EN/CA/2026/15) is another high-profile case.¹ This organization, ostensibly a charitable entity, has been accused by investigators of receiving significant funding—notably Rs. 13 million from a Qatari institution—to promote extremist ideologies.¹⁹ The freezing of its accounts at Amana Bank and Commercial Bank is a clear example of the state using the Gazette to sever the link between international charity and domestic radicalization.¹

Entity ID	Name	Origins/Start	Notable Context
EN/CA/2026/08	N.T.J.	2012 (Batticaloa)	Mastermind group of Easter 2019 attacks.
EN/CA/2026/09	J.M.I.	2014	Self-radicalized Salafi-jihadist network.
EN/CA/2026/10	W.A.S.	2016	Islamic State (IS) affiliate in Sri Lanka.
EN/CA/2026/15	Save the Pearls	2015	Charitable front with alleged Qatari funding.
EN/CA/2026/16	Super Muslim	2018 (India)	Encrypted social media-based movement.

The Second Schedule: Individual Profiles and the Reach of Global Terrorism

The Second Schedule of Gazette No. 2470/19 lists over 200 individuals, providing granular identity details that include full names, National Identity Card (NIC) numbers, passport details, and known domestic and foreign addresses.¹ Analysis of this data reveals several critical trends in the profile of modern terrorism in Sri Lanka.

Interpol Integration and International Law Enforcement

A defining feature of the 2026 list is the heavy reliance on international law enforcement notices.¹ Of the first several dozen individuals detailed in the Second Schedule, approximately 86% are linked to an active Interpol Red or Blue Notice.¹ This high prevalence indicates that the Sri Lankan Ministry of Defence is effectively leveraging the global police network to track high-value targets who have fled the country.

Notable examples include:

●       Velupillai Revathan (IN/CA/2026/01): An L.T.T.E. member with an Interpol Red Notice issued on September 6, 2010 (Control No: A-5656/9-2010).¹ Revathan’s long-standing presence on the list, coupled with his multiple addresses in Colombo and Vavuniya, suggests he remains a priority for the state’s counter-intelligence wing.¹

●       Kanigayalam Siri Sankar (IN/CA/2026/13): Identified as a Senior Intelligence Wing Leader for the L.T.T.E., his designation highlights the government's focus on individuals with command-and-control experience who might facilitate a resurgence.¹

●       Sanmuga Sundaram Kanthaskaran (IN/CA/2026/06): A key figure in "funding for terrorism," Kanthaskaran maintains an address in Mitcham, Surrey, UK.¹ His designation reinforces the first-order insight that the primary role of the L.T.T.E. network in 2026 is financial rather than kinetic.¹

The Geopolitical Dimension: Farhad Shakeri and the IRGC

One of the most significant individual entries in the January 2026 update is Farhad Shakeri (IN/CA/2026/193).¹ Shakeri, an Afghan national believed to be residing in Tehran, is an asset of Iran’s Islamic Revolutionary Guard Corps (IRGC).²⁰ His inclusion on Sri Lanka’s terrorism list is directly linked to an unsealed U.S. Justice Department indictment detailing a plot to assassinate Israeli tourists in Arugam Bay, Sri Lanka, in October 2024.²²

The Shakeri case represents a complex convergence of transnational crime and state-sponsored terrorism.²⁰ Shakeri reportedly utilized a network of criminal associates he met while serving time in a U.S. prison for a 14-year robbery conviction to recruit operatives for the IRGC.²⁰ In Sri Lanka, Shakeri’s accomplice—unnamed in some reports but identified as "CC-2"—was arrested by local authorities after a high-level security warning from the United States and Israel.²² The Arugam Bay plot involved a planned mass shooting using AK-47 rifles, aimed at Israeli travelers during a period of heightened tension in the Middle East.²²

The designation of Shakeri highlights the way Sri Lanka’s counter-terrorism framework is being utilized to combat "gray zone" activities where foreign state actors use criminal proxies to conduct operations on third-country soil.²² It also illustrates the critical importance of intelligence sharing between Colombo and Washington, particularly as Sri Lanka seeks to prevent its tourism hubs from becoming battlegrounds for external conflicts.²³

Individual ID	Name	Primary Association	Interpol Status
IN/CA/2026/01	Velupillai Revathan	L.T.T.E. Member	Red Notice (2010)
IN/CA/2026/06	S. S. Kanthaskaran	L.T.T.E. (Financial)	Red Notice (2010)
IN/CA/2026/13	K. Siri Sankar	L.T.T.E. (Intelligence)	Red Notice (2011)
IN/CA/2026/193	Farhad Shakeri	IRGC Asset	U.S. DOJ Indictment
IN/CA/2026/202	Dr. Rise	Super Muslim Leader	Domestic Designation

Diplomatic Reciprocity and the FETO Designations

The 2026 Gazette also includes individuals associated with the Fethullahist Terrorist Organization (FETO), which the Turkish government blames for the 2016 failed coup attempt.¹ The inclusion of Kenan Avsar (IN/CA/2026/198) and Saim Turetken (IN/CA/2026/199) on the Sri Lankan list is a notable example of diplomatic reciprocity.¹ Turkey has aggressively lobbied its allies and members of the Asian Parliamentary Assembly (APA) to designate FETO as a terrorist group, arguing that its global network of schools and financial institutions poses a threat to national stability.²⁶

Saim Turetken is listed with a domestic address in Colombo 06, suggesting that FETO-linked individuals have maintained a physical presence in Sri Lanka under the guise of commercial or educational activities.¹ For Sri Lanka, designating these individuals serves as a strategic alignment with Turkey, a key regional partner, even as Western nations like the United States have resisted such a designation.²⁷ This highlights the fragmented nature of international terrorism designations, where a group’s status often depends on the bilateral security priorities of the host nation.

Regional Security and the Maldivian Australian Nexus

Another striking feature of the Second Schedule is the presence of several foreign nationals who are not traditional actors in Sri Lankan internal politics. This includes a cluster of Maldivian nationals:

●       Ahamed Hisham (IN/CA/2026/171): A Maldivian national listed with addresses in Male and S. Hulhudhu, associated with terrorism related activities and funding.¹

●       Mohamed Ismail (IN/CA/2026/172): Noted for connections to regional extremist networks, with addresses in Male and Hulhumale.¹

●       Mohomed Nishan (IN/CA/2026/173): Listed with addresses in Himandhu, Male.¹

The inclusion of Maldivian citizens reflects the growing integration of the "Jihadist archipelago" in the Indian Ocean.³⁰ Extremist cells in the Maldives and Sri Lanka have historically shared financial and ideological links, and the 2026 Gazette demonstrates that the Sri Lankan Ministry of Defence is tracking these cross-border threats with increasing scrutiny.

Furthermore, the Gazette lists Australian citizens such as Ahamed Thalib Luqman Thalib (IN/CA/2026/160) and Ahamed Luqman (IN/CA/2026/161).¹ Thalib Luqman Thalib is linked to an address in Doncaster East, Victoria, and is designated for "terrorism related activities and funding for terrorism".¹ The inclusion of Australian nationals underscores the global nature of the "foreign fighter" and "terrorist financier" problem, where individuals in stable Western democracies can play a pivotal role in funding operations in South Asia.¹

The Banking Sector: Compliance, Risks, and Obligations

For the Sri Lankan financial sector, the January 2026 Gazette is a mandatory compliance directive with significant legal and reputational consequences.³ The Financial Intelligence Unit (FIU) of Sri Lanka has issued clear guidelines for Licensed Banks, Finance Companies, and Stock Brokering Companies regarding their obligations under UN Regulations No. 1 and No. 2.³

Reporting institutions are required to:

1.     Immediate Screening: All customer databases must be screened against the updated First and Second Schedules of Gazette 2470/19.³

2.     Asset Freezing: If a match is found, the institution must immediately freeze the funds or assets without prior notice to the designated person.⁵ This "no-notice" requirement is essential to prevent the preemptive withdrawal or transfer of funds.⁵

3.     Mandatory Reporting: Any frozen assets or "hits" against the list must be reported to the Competent Authority and the FIU within 24 hours.³

4.     Prohibition of Services: It is a criminal offense to provide any financial services or economic resources to a designated person or entity.⁵

The inclusion of specific bank accounts for entities like the Tamil Rehabilitation Organization and Save the Pearls demonstrates that the state is monitoring the flow of funds through the formal banking system.¹ Banks like Seylan Bank, Amana Bank, and Commercial Bank are named as holders of these accounts, placing them at the center of the enforcement action.¹ Failure to comply with these freezing orders can result in severe penalties, including the revocation of banking licenses and criminal prosecution for the officers involved.³

Human Rights, Constitutional Challenges, and the PTA Debate

The use of administrative designations and asset freezes is not without controversy.¹⁰ The January 2026 Gazette is issued alongside a broader debate about the reform or repeal of the Prevention of Terrorism Act (PTA).¹⁰ Human rights organizations, including the International Commission of Jurists (ICJ), have argued that the current counter-terrorism framework enables prolonged arbitrary detention and the extraction of confessions through torture.¹⁰

The ICJ has specifically criticized the "overbroad" definition of terrorism in Sri Lankan law, which can lead to the targeting of minority communities and civil society groups.³¹ For instance, the designation of organizations like the Tamil Youth Organization (T.Y.O.) or the National Council of Canadian Tamils (N.C.C.T.) is viewed by some as an attempt to stifle diaspora advocacy rather than a legitimate counter-terrorism measure.¹ Furthermore, the fact that a person can be placed on a terrorism list and have their assets frozen solely on the order of the Secretary to the Ministry of Defence—without a prior court conviction—is a major point of constitutional concern.¹⁰

Between 1983 and 2009, the PTA was primarily used against ethnic Tamils; however, since 2019, it has been increasingly used against the Muslim community.¹⁰ Cases like that of Barmasiri Chandraiyer Ragupathi Sharma, who spent 15 years on remand before being convicted on a potentially coerced confession, serve as warnings about the risks of a counter-terrorism system that lacks sufficient judicial oversight.¹⁰ While the January 2026 update is focused on financial sanctions, it operates within the same legal ecosystem that the UN and human rights bodies have urged Sri Lanka to reform.¹⁰

Geopolitical Synthesis and Strategic Implications

The 2026 Gazette is more than a list of names; it is a strategic document that maps Sri Lanka's current place in the global security order. Several key insights emerge from a comprehensive review of the document and its surrounding context.

First, the transition from kinetic to financial warfare is complete. The state's primary concern regarding the L.T.T.E. is no longer a jungle insurgency but the "mono ethnic separate state" ideology funded by sophisticated diaspora networks in Europe and Canada.¹ By designating entities like the T.G.T.E. and T.C.C., Sri Lanka is attempting to isolate the separatist movement from its international financial bases.¹

Second, the "Super Muslim" and N.T.J. designations show that the threat of Islamist radicalization remains a persistent and evolving challenge.¹ The state's focus on digital platforms like Telegram indicates a move toward more proactive monitoring of online radicalization, which is often decentralized and difficult to track via traditional intelligence methods.¹

Third, the Farhad Shakeri case demonstrates that Sri Lanka has become a theater for global proxy conflicts.²⁰ The Arugam Bay plot was not born of domestic grievances but was an Iranian operation targeting Israeli interests.²² This forces the Sri Lankan security forces to maintain high levels of readiness and cooperate with international intelligence agencies to protect their vital tourism industry.²³

Finally, the inclusion of Australian, Maldivian, and Turkish nationals on the list reflects the globalization of the threat.¹ Sri Lanka’s security is now inextricably linked to the stability of the Indian Ocean region and the political shifts in the Middle East and the West.

Strategic Outlook and Conclusion

The publication of Gazette Extraordinary No. 2470/19 on January 6, 2026, provides a comprehensive blueprint of Sri Lanka’s contemporary threat landscape.¹ By updating the First and Second Schedules, the Competent Authority has neutralized some of the legal ambiguity that plagued previous iterations of the list, providing banks and law enforcement with the specific identifiers needed to enforce Targeted Financial Sanctions effectively.¹

However, the efficacy of this system will ultimately depend on three factors:

1.     International Cooperation: Since the majority of the high-value targets and front organizations are based overseas, the Sri Lankan government must secure the cooperation of foreign governments in Canada, the UK, and the EU to enforce these asset freezes.¹

2.     Regulatory Rigor: The financial sector must maintain high standards of compliance to prevent the "nesting" of terrorist funds within legitimate commercial accounts, particularly for entities operating under charitable or humanitarian guises.³

3.     Judicial and Human Rights Balance: To maintain international legitimacy and comply with UN standards, Sri Lanka must ensure that its counter-terrorism measures do not become tools for political repression or the marginalization of minority groups.¹⁰

As Sri Lanka navigates the challenges of 2026 and beyond, the January Gazette remains the primary legal instrument for disrupting the financial underpinnings of extremism. Whether it is the legacy of the L.T.T.E., the threat of the Islamic State, or the shadow of the IRGC, the nation’s security will increasingly be defined by its ability to control the flow of capital and the dissemination of radical ideology across its borders. The exhaustive detail of Gazette No. 2470/19 serves as both a shield for the nation’s financial integrity and a sword for its counter-terrorism strategy.

     In solidarity,

     Wimal Navaratnam

     Human Rights Advocate | ABC Tamil Oli (ECOSOC)

      Email: tamilolicanada@gmail.com

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