On October 20, 2023, the US Department of the Treasury’s Office of Foreign Assets Control designated 2 individuals and 4 entities that form a core part of Republika Srpska (“RS”) President Milorad Dodik’s patronage network, which facilitates ongoing corruption by Dodik in Bosnia and Herzegovina’s (“BiH”) RS entity and enables him to enrich himself and his family with public funds at the expense of BiH citizens there. In 2017, Dodik was designated in the US pursuant to Executive Order 13304 and then again in 2022 under EO 14033 for efforts to obstruct or threaten the Dayton Peace Agreement (“DPA”), an agreement that forms the framework of the BiH government. According to OFAC, Dodik continues to undermine the DPA and recently sponsored the passage of a law in June 2023 that attempted to declare decisions of the BiH’s Constitutional Court inapplicable in the RS. Despite the BiH High Representative’s nullification of the law, Dodik signed the law into effect in July 2023. In response, the BiH’s highest court has brought an indictment against Dodik.
OFAC reports that Dodick’s adult children are members of the corrupt network, and the newest designees are Dodik’s son Igor Dodik and daughter Gorica Dodik whose involvement in the political and businesses activities in the RS has increased since 2021. Dodik has reportedly conspired with Igor to bribe political officials, polling station members, and election observers in order to win a recent election in RS. In addition, Gorica, at Dodik’s direction, has allegedly taken ownership of several entities in RS – entities that receive preferential treatment in the RS in the form of government assistance simply for being owned by a member of Dodik’s family. The four newly designated entities are commercial businesses based in the BiH that receive government assistance for being owned or controlled by Igor and Gorica.
The designations were imposed pursuant to Executive order 14033 for engaging in efforts that violate or threaten the implementation of the DPA. 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 US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned 50 percent or more by one or more blocked persons are also blocked. US persons may also face civil or criminal penalties for violating EO 14033.