On June 18, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated a network of individuals and entities that allegedly supported U.S.-designated Respublika Srpska (“RS”) President Milorad Dodik and his family – an action that undermines the peace and stability of Bosnia and Herzegovina (“BiH”). Dodik was designated by the U.S. in 2017 under Executive Order 13304 for actively obstructing or posing a significant risk of obstructing the Dayton Peace Accords (“DPA”), and then again in 2022 under EO 14033, which targets those responsible for or complicit in threatening the implementation of any regional peace or cooperation agreement related to the Western Balkans. In 2023, Dodik’s adult children, Igor and Gorica Dodik, were also designated pursuant to EO 14033 for materially assisting their father, a person whose property and interests in property had been blocked under EO 14033.
OFAC’s new designations were imposed upon two individuals and seven entities for their alleged roles in Dodik’s efforts to direct RS government contracts to private companies under his son Igor’s control. For example, in 2024, Igor and Dodik allegedly pressured BiH government officials to draft a state budget that enabled Prointer ITSS d.o.o. Banja Luka Clan Infinity International Group – a company under Igor’s control – to obtain a state-level contract outside of the competitive process. Specifically, OFAC designated BIH-based holding company Infinity International Group d.o.o. Banja Luka, allegedly under Igor’s control, as well as five companies owned or majority owned by Infinity, including Prointer. OFAC also designated Sirius 2010 d.o.o. Banja Kuka, an IT company within the Dodik family network, and two individuals – Djordje Djuric and Milenko Cicic – who reportedly have ownership and management positions in the network.
OFAC also issued three general licenses under Western Balkans Stabilizations Regulations (“WBSR”), 31 CFR part 588, to authorize certain transactions involving certain newly-designated entities. General License 3A authorizes transactions with certain designees, including Infinity and Sirius, if the transactions involve agricultural commodities, medicine and medical devices, software updates and clinical trials, while General License 4 temporarily permits wind down transactions with Infinity and Sirius until August 17, 2024. OFAC also issued General License 5 to authorize certain transactions involving pumps manufactured by newly-designated Kaldera Company EL PGP d.o.o., provided that the transaction relates to the treatment or distribution of drinking water.
U.S. Department of Treasury Press Release | General License 3A | General License 4 | General License 5