Using expanded sanctions authorities, Treasury sanctions Republika Srpska President Dodik’s patronage network and individuals in Bosnia and Herzegovina for undermining regional peace and rule of law
WASHINGTON – On January 8, 2025, the President issued Executive Order (E.O.) 14140, an amendment to E.O. 14033, which expanded the United States government’s ability to curtail activity that undermines, or attempts to undermine, regional peace frameworks and the rule of law in the Western Balkans and efforts to circumvent U.S. sanctions.
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating five individuals and one entity that facilitate Republika Srpska (RS) President Milorad Dodik (Dodik) and his family’s efforts to enrich themselves at the public’s expense. Today’s action also targets eight individuals who, at Dodik’s direction, organized and executed the commemoration of “Republika Srpska Day” (RS Day) in January 2024, in contravention to the principles of the Dayton Peace Agreement (DPA) and which the Bosnia and Herzegovina (BiH) Constitutional Court (CC) ruled unconstitutional.
“Today’s action highlights Dodik’s continued efforts to undermine the democratic and multiethnic framework that defines modern-day Bosnia and Herzegovina,” said Acting Under Secretary of the Treasury for Terrorism and Financial Intelligence Bradley T. Smith. “The United States, leveraging our expanded authorities, remains committed to disrupting any attempts by Dodik and his cronies to enrich themselves and destabilize the region.”
SIGNIFICANT ACTORS CONTRIBUTING TO THE DODIK FINANCIAL NETWORK
The Dodiks’ efforts to enrich themselves led to OFAC’s October 20, 2023, June 18, 2024, November 6, 2024, and December 18, 2024 designations of core parts of the Dodiks’ corrupt patronage network, including several entities and individuals under the direct control of Dodik’s son, Igor Dodik (Igor). While Igor controls many of the companies in this network, he obfuscates his personal connection to the companies by relying on distinct owners and nominal directors. Today’s action builds on OFAC’s recent designations and utilizes the expanded authorities of E.O. 14033, as amended, to hinder attempts to circumvent sanctions.
BiH and Serbian national Pavle Corovic (Corovic) is the husband of Dodik’s U.S.-designated daughter, Gorica Dodik (Gorica), and the director of U.S.-designated and RS-based Global Liberty d.o.o. Laktasi (Global Liberty) (both designated on October 20, 2023). Along with other Dodik-affiliated entities, Global Liberty has received lucrative incentives from the RS budget.
OFAC is designating Corovic pursuant to E.O. 14033, as amended, for owning or controlling, directly or indirectly, Global Liberty, a person whose property and interests in property are blocked pursuant to E.O. 14033.
BiH-based Radmila Bojanic (Bojanic)and Nemanja Reljin (Reljin) are the director and owner, respectively, of U.S.-designated Nimbus Innovations d.o.o. Banja Luka (Nimbus) (designated on December 18, 2024). Previously, both Bojanic and Reljin served in the same roles for Sirius 2010 d.o.o. Banja Luka (Sirius) (designated on June 18, 2024) before it formally merged with Nimbus. Both Nimbus and Sirius were designated for being controlled by Igor. Bojanic provided Igor with business updates and solicited Igor’s approval before moving forward with business decisions.
OFAC is designating Bojanic and Reljin pursuant to E.O. 14033, as amended, for owning or controlling, directly or indirectly, Nimbus, a person whose property and interests in property are blocked pursuant to E.O. 14033. Bojanic is also being designated pursuant to E.O. 14033, as amended, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Igor, a person whose property and interests in property are blocked pursuant to E.O. 14033.
To benefit from the businesses both directly and indirectly under his control, Igor relies upon strategic insights from associates responsive to his interests. For example, BiH national Sinisa Dodik (Sinisa) has reported to Igor on numerous high-level developments and has advised him on business opportunities. Igor and Serbian national Marko Gujanicic (Gujanicic) were publicly identified in a scheme related to media research and public polling in BiH wherein they sought to capitalize on a recent rule change, that was subsequently annulled by a BiH court for being unlawfully restrictive and contrary to the public interest. Both Igor and Gujanicic were involved in the formation of Cyprus-based SEE Media Research LTD (SEE Media Research) and local operations in BiH. Igor worked with associates between at least September 2023 and July 2024 to ensure that his preferred company would have a monopoly on measuring TV viewership. Additionally, Gujanicic informed Igor of a strategy to manipulate TV survey responses to further their goals.
OFAC is designating Sinisa and Gujanicic pursuant to E.O. 14033, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Igor, a person whose property and interests in property are blocked pursuant to E.O. 14033.
OFAC is designating SEE Media Research pursuant to E.O. 14033, as amended, for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Gujanicic, a person whose property and interests in property are blocked pursuant to E.O. 14033, as amended.
ORGANIZERS OF REPUBLIKA SRPSKA DAY
On January 8–10, 2024, the RS government organized celebrations of RS Day in defiance of prior BiH Constitutional Court (CC) decisions that held that the commemoration of January 9 unconstitutional due to its violation of the BiH constitutional obligation of non-discrimination. These events were explicitly organized by the RS government. Specifically, Dodik personally oversaw and directed efforts to organize and commemorate RS Day 2024. In response to these commemorations of January 9, the High Representative stated that the celebration of January 9 as RS Day represented “a clear and direct failure to implement the final and binding decisions of the BiH CC” and noted that such non-compliance with BiH CC rulings constituted a criminal offense under the BiH criminal code. By openly defying the decisions of both the BiH CC and High Representative — two bodies whose authorities are enshrined in the Dayton Peace Agreement (DPA) and are critical to upholding it — the actions undertaken by the RS government, and directed by Dodik, undermine the DPA.
BiH-based RS Minister of Interior Sinisa Karan (Karan), Chief of Staff in the Office of the RS President Danijel Dragicevic (Dragicevic), Head of the RS Protocol Office Goran Rakovic (Rakovic), RS Secretary General Dalibor Panic (Panic), Director of Radio Television Republika Srpska Dijana Milankovic (Milankovic), President of the RS Constitutional Court Dzerard Selman (Selman), President of the RS Academy of Arts and Sciences Rajko Kuzmanovic (Kuzmanovic), and Chief of Cabinet to the RS National Assembly (RSNA) Speaker Goran Filipovic (Filipovic) — alongside three additional members of the 2024 RS Day Organizing Committee whom the United States designated on March 13, 2024 — proposed, adopted, and implemented the plan of events for the 2024 commemoration of RS Day.
Beyond his lead role in overseeing the 2024 event, Dodik more recently directed the planning of RS Day 2025. To assist in planning RS Day 2025, Dodik directed public officials — including Dragicevic, Karan, Milankovic, Selman, and Panic — to support various organizing efforts. All of these officials agreed to follow Dodik’s instructions and worked to ensure RS Day 2025 events were organized according to his wishes. Karan, Dragicevic, Rakovic, Panic, Milankovic, Selman, and Kuzmanovic were formally appointed to serve on the 2025 RS Day Organizing Committee by the RSNA. In spite of repeated declarations by the BiH CC and the High Representative, these officials have continued to engage in behavior that undermines the DPA.
In addition to these efforts, in 2024, Dodik instructed several Alliance of Independent Social Democrats (SNSD) officials to convene a working group to draft a plan for the RS to secede from BiH. Both Karan and Panic were part of this secessionist working group that drafted the secession plan for Dodik.
OFAC is designating Karan, Dragicevic, Rakovic, Panic, Milankovic, Selman, Kuzmanovic, and Filipovic pursuant to E.O. 14033, as amended, for being responsible for or complicit in, or having directly or indirectly engaged or attempted to engage in, a violation of, or an act that has obstructed or threatened the implementation of, any regional security, peace, cooperation, or mutual recognition agreement or framework or accountability mechanism, or posing a significant risk of committing such an act, related to the Western Balkans, including the Prespa Agreement of 2018; the Ohrid Framework Agreement of 2001; United Nations Security Council Resolution 1244; the Dayton Accords; or the Conclusions of the Peace Implementation Conference Council held in London in December 1995, including the decisions or conclusions of the High Representative, the Peace Implementation Council, or its Steering Board; or the International Criminal Tribunal for the former Yugoslavia, or, with respect to the former Yugoslavia, the International Residual Mechanism for Criminal Tribunals.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC or exempt, U.S. sanctions generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities with designated or otherwise blocked persons.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
For identifying information on the individuals and entity sanctioned today, click here.
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