Genocide by Attrition 47 on childbirth (two per family), to restrictions on marriage and private relationships, all of which are tracked and enforced using bureaucratic forms of documentation.146 Formal and informal restrictions on the right to freedom of movement for Rohingya have exacerbated these restrictions. Restrictions on movement include requirements for formal permissions to travel, curfews, checkpoints, restricted zones, and requirements for “security” escorts to travel to other townships.147 These restrictions pose time-consuming and expensive obstacles for Rohingya to access schools, mosques, medical facilities, markets, and livelihood activities.148 As part of a citizenship verification process initiated under Myanmar President Thein Sein’s administration Myanmar government began to issue Identity Cards of National Verification (ICNV).149 The application process to obtain an ICNV required Rohingya to identify as “Bengali” or other foreign identity.150 Following a landslide victory by Aung San Suu Kyi’s National League for Democracy (NLD) party during the 2015 elections, from which Rohingya ICNV-card holders were excluded from participating or voting in, the new democratically elected Government of Myanmar reinforced the previous administration’s discriminatory identification documentation policies, rebranding the ICNVs as NVCs.151 While the government asserted that the NVC was “the first step before the scrutinisation of citizenship, in accordance with the 1982 Citizenship Law,” in reality, the NVC fails to guarantee citizenship in Myanmar, and holders are still required to apply for citizenship under the 1982 Citizenship Law.152 On the back of the card, the NVC states in the English and Burmese languages “[h]olding this identity card does not testify that the card holder is [sic] Myanmar citizen,” as well as “[t]his identity card holder is a person who need [sic] to apply for citizenship in accordance with the Myanmar Citizenship Law.”153 The NVC process is an integral part of protracted attempts to deny Rohingya their identity and citizenship.154 For example, Yanghee Lee, the former U.N. Special Rapporteur on situation of human rights in Myanmar, said the NVC was being used as “a way of exterminating their [Rohingya] basic identity.”155 Before the International Court of Justice (ICJ) at The Hague, during hearings on whether Myanmar violated the U.N. Genocide Convention on December 2019, attorney Tafadzwa Pasipanodya 146 Id. at pp. 22-43. Not only did Myanmar implemented orders on controlling births but in April 2022 Bangladesh Home Minister Asaduzzaman Khan Kamal told national media that the government would introduce birth control measures in the refugee camps to stop population growth among the refugees. See, “Birth Control Measures to be Introduced in Rohingya Camps: Home Minister,” Prothomalo English, April 11, 2022, https://en.prothomalo.com/ bangladesh/government/birth-control-measures-to-be-introduced-in-rohingya-camps-home-minister. 147 Fortify Rights, “Tools of Genocide,” p. 41. See also, U.N. Human Rights Council, Report of the Detailed Findings of the Independent International Fact-Finding Mission on Myanmar, U.N. Doc. A/HRC/39/CRP.2, September 17, 2018, para. 484. Advisory Commission on Rakhine State, Towards a Peaceful, Fair, and Prosperous Future for the People of Rakhine, August 2017, http://www.rakhinecommission.org/ app/uploads/2017/08/FinalReport_Eng.pdf, p. 27. 148 Independent Rakhine Initiative, Freedom of Movement in Rakhine State, 2020, pp. 12-13. 149 U.N. Human Rights Council, Report of the Detailed Findings of the Independent International Fact-Finding Mission on Myanmar, U.N. Doc. A/HRC/39/CRP.2, September 17, 2018, paras. 482, 484. 150 Fortify Rights, “Tools of Genocide,” p. 42. 151 Republic of the Union of Myanmar, Office of the President, “Formation of the Steering Committee for Issuance of National Verification Card (NVC) in Rakhine State for Those Who Will Undergo Verification for Citizenship,” Notification No. 21/2017, February 8, 2017, https://www.moi.gov.mm/moi:eng/?q=announcement/14/11/2018/id-9873. 152 The Republic of the Union of Myanmar President Office, “NV Process is First Step Towards Citizenship,” October 29, 2017, http://www.president-office.gov.mm/en/?q=issues/rakhine-state-affairs/id-7868. 153 Photographs of Rohingya NVCs from Rakhine State Myanmar and Cox’s Bazar District, Bangladesh. See also, Fortify Rights, “Tools of Genocide,” p. 44. 154 In addition to the Rohingya, according to the FFM in 2018, the Myanmar authorities reportedly issued NVCs to other communities in Shan and Karen states. The FFM noted, “[a]s of January 2017, over 16,000 NVCs had been issued in Shan State and 3,500 in Kayin. In both states, more than a quarter of the population do not have identity documents.” Human Rights Council, Report of the Detailed Findings of the Independent International Fact-Finding Mission on Myanmar, U.N. Doc. A/HRC/39/CRP.2, September 17, 2018, https://www.ohchr.org/Documents/HRBodies/HRCouncil/FFMMyanmar/A_HRC_39_CRP.2.pdf, p. 117, fn. 1082. 155 Poppy McPherson, “Three Years After Exodus, Myanmar Erases Names of Rohingya Villages, UN Map Makers Follow Suit,” Reuters, September 11, 2020, https://www.dailysabah.com/world/asia-pacific/myanmar-erases-names-ofrohingya-villages-un-says.