On January 17, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control imposed sanctions under the Western Balkans sanctions regime upon supporters of Republika Srpska (“RS”) President Milorad Dodik (“Dodik”). Republika Srpska is one of two entities that make up Bosnia and Herzegovina (“BiH”). OFAC sanctioned five individuals and one entity that facilitated acts of corruption in RS that have allegedly enabled Dodik and his family to benefit financially from his official position. OFAC also designated eight individuals that held “Republika Srpska Day” events at Dodik’s direction in contravention of the Dayton Peace Agreement. Dodik was initially designated by the United States in 2017 under Executive Order 13304 for obstructing or posing a significant risk of obstructing the Dayton Peace Accords (“DPA”) and then again in 2022 under EO 14033, which targets those who threaten the implementation of any regional peace or cooperation agreement related to the Western Balkans.
According to OFAC, the Dodik family has used a corrupt patronage network, including individuals and entities directly controlled by Dodik’s son Igor Dodik, to enable businesses that they own or control to benefit financially at the public’s expense. OFAC reported that many Dodik-affiliated entities, including Global Liberty d.o.o. Laktasi (“Global Liberty”), received lucrative incentives from the RS budget. Pavele Corovic, the director of Global Liberty, is among the new designees. OFAC reports that Corovic also happens to be married to Dodik’s daughter Gorica. Gorica and Global Liberty were previously designated by OFAC in 2023 for supporting Dodik’s acts of corruption. OFAC also designated eight government officials who organized and held RS Day celebrations, events that the BiH Constitutional Court deemed unconstitutional for violating the BIH constitutional obligation of non-discrimination. Among the newly-designated officials are RS Minister of Interior Sinisa Karan and President of the RS Constitutional Court Dzerard Selman.
All of the new designations were imposed pursuant EO 14140, that was recently issued on January 8, 2025 to expand the U.S. governments ability to sanction efforts to undermine regional peace and the rule of law in the Western Balkans. As a result of these designations, all property and interests in property of the designees within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving the designated persons. Entities owned 50 percent or more by one or more blocked persons are also blocked. U.S. and foreign persons may also face civil or criminal penalties for violating Western Balkan sanctions.