Washington, December 18, 2024
Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating three individuals and four entities in Bosnia and Herzegovina (BiH) that form part of U.S.-designated Republika Srpska (RS) President Milorad Dodik’s (Dodik) financial network and enable the Dodik family’s continued attempts to evade sanctions. Today’s action also targets a BiH politician who serves as a key enabler of Dodik’s corruption and destabilizing political agenda.
For years, Dodik has used his official position to accumulate personal wealth through companies linked to himself and his son, U.S.-designated Igor Dodik (Igor). This corruption, in tandem with Dodik’s continued drive to destabilize BiH’s governing institutions, undermines public confidence in BiH state institutions and the rule of law.
“Dodik and his family continue to rely on trusted associates to obfuscate their involvement in new business ventures, enriching themselves and their cronies while trying to circumvent U.S. sanctions,” said Acting Under Secretary of the Treasury for Terrorism and Financial Intelligence Bradley T. Smith. “The United States will continue to expose these efforts and hold accountable the individuals enabling these schemes.”
The Dodik family continues its efforts to obfuscate its control of entities by manipulating management structures and re-registering companies under new names. Today’s action builds on previous designations against the Dodik family by exposing their deliberate attempts to evade U.S. sanctions and targeting the individuals supporting these activities.
Dodik family’s financial network and attempts to evade U.S. sactions
The United States designated Dodik on January 5, 2022 pursuant to Executive Order (E.O.) 14033 for being responsible for or complicit in, or having directly or indirectly engaged in, a violation of, or an act that has obstructed or threatened the implementation of, the Dayton Peace Accords (DPA), as well as corruption related to the Western Balkans. The United States also previously designated Dodik on July 17, 2017 pursuant to E.O. 13304 for obstructing or threatening to obstruct the DPA. Additionally, the United States designated Dodik’s adult children, Igor and Gorica Dodik, on October 20, 2023 pursuant to E.O. 14033 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Dodik, a person whose property and interests in property are blocked pursuant to E.O. 14033.
The Dodiks’ efforts to enrich themselves led to OFAC’s October 20, 2023, June 18, 2024, and November 6, 2024 designations of core parts of the Dodiks’ corrupt patronage network, including several entities and individuals under Igor’s direct control. Dodik used his official position to direct RS government contracts to a network of private companies that he and Igor oversee. While Igor controls many of the companies in this network, he obfuscates his personal connection to the companies by relying on distinct nominal owners and directors.
Nimbus Innovations d.o.o. Banja Luka (Nimbus) is a BiH-based information technology services company formed after the United States designated Igor-controlled Sirius 2010 d.o.o. Banja Luka (Sirius) on June 18, 2024. In the wake of Sirius’s designation, Nimbus was formally established at the same address as Sirius and publicly announced that it would assume all of Sirius’s assets, operations, and liabilities. Nimbus also retained Sirius’s management and is owned by the same individual. Despite the change in name, Igor exercised control over the director of Nimbus, who provided Igor with business updates and solicited Igor’s approval on business decisions.
OFAC is designating Nimbus pursuant to E.O. 14033 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.
Igor uses family members to enable entities in his patronage network. In November 2023, Dodik’s cousin and BiH national Aleksandar Dobric (Aco) established RS-based Best Service d.o.o. Banja Luka (Best Service), under its original name, Agape Best d.o.o. Banja Luka. The United States designated RS-based Agape Gorica Dodik i Ivana Dodik S.P. Banja Luka (Agape) on October 20, 2023 pursuant to E.O. 14033 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Gorica Dodik. Best Service is registered at the same address as Agape and, like Agape, operates in the restaurant and food service provider sector of the RS. Aco executed instructions from Igor on Best Service operations. Additionally, Aco agreed to direct his father, Mirko Dobric (Mirko), to conduct business actions.
OFAC is designating Aco pursuant to E.O. 14033 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.
OFAC is designating Best Service pursuant to E.O. 14033 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Aco, a person whose property and interests in property are blocked pursuant to E.O. 14033.
Igor and BiH national Mirko are the owners of U.S.-designated Fruit Eco d.o.o. Gradiska (Fruit Eco), and Mirko also serves as its director. In April 2024, following Fruit Eco’s designation, RS-based Zelena Jabuka d.o.o. (Zelena Jabuka) was established with Mirko as its sole owner and director. Zelena Jabuka is registered at the same address as Fruit Eco and both entities are involved with orchard fruit production. Following Igor’s instructions, Mirko assisted Igor with a business proposal. The United States designated Fruit Eco d.o.o. Gradiska (Fruit Eco) on October 20, 2023 pursuant to E.O. 14033 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Igor Dodik, a person whose property and interests in property are blocked pursuant to E.O. 14033.
OFAC is designating Mirko pursuant to E.O. 14033 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.
OFAC is designating Zelena Jabuka pursuant to E.O. 14033 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Mirko, a person whose property and interests in property are blocked pursuant to E.O. 14033.
BiH national Vlatko Vukotic (Vukotic) is a former employee of U.S.-designated Alternativna Televizija d.o.o. Banja Luka (ATV), recent employee of U.S.-designated Prointer ITSS d.o.o. Banja Luka Clan Infinity International Group (Prointer), and the owner and director of RS-based Vorto d.o.o. (Vorto). Igor instructed Vukotic on financial obligations that Vukotic needed to fulfill. Vukotic sought Igor’s guidance on a debt Vukotic’s public relations firm Vorto owed. Additionally, following Igor’s directions, Vukotic agreed to pressure entities that have taken measures against Igor’s patronage network. Vukotic advised Igor on how to reduce scrutiny of U.S.-designated entities.
OFAC is designating Vukotic pursuant to E.O. 14033 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 Vorto pursuant to E.O. 14033 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Vukotic, a person whose property and interests in property are blocked pursuant to E.O. 14033.
The United States designated both ATV and Prointer, on January 5, 2022 and June 18, 2024, respectively, pursuant to E.O. 14033 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.
BiH politician enabling Dodik’s corruption and destabilizing activity
Stasa Kosarac (Kosarac) is the BiH Minister of Foreign Trade and Economic Relations, the Vice Chair of the BiH Council of Ministers (CoM), and a high-ranking member of Dodik’s political party, the Alliance of Independent Social Democrats (SNSD). In these roles, Kosarac is often tasked by Dodik to abuse his official position for Dodik’s benefit.
As a BiH state-level minister and the vice chair of the BiH CoM, Kosarac has the access and authority to impact political and budgetary processes. For instance, Kosarac conspired to use his position to undermine the efficacy of state-level institutions to Dodik’s benefit. For example, through at least October 2024, Kosarac planned to block the normal functioning of the BiH CoM to secure the appointment of a Dodik nominee. Additionally, Kosarac’s positions afford him the ability to influence financial decision-making at the highest levels. On one occasion, Kosarac misused his official position to manipulate the BiH state budget to ensure that state-level funding could be directed to Prointer, an entity controlled by Igor; and on another occasion, Kosarac blocked efforts to pass the BiH 2024 state budget while Dodik planned to siphon off a portion of these funds for use by the SNSD in the 2024 local elections in BiH. Furthermore, these positions grant Kosarac credibility and political power, which he has used to Dodik’s benefit. In 2023, Kosarac organized a meeting of senior Bosnian Serb officials where they pledged to support Dodik and, if ordered by Dodik, withdraw from BiH state institutions. Finally, Kosarac voted for a bill in the BiH CoM that would benefit Dodik politically by securing him favors from a high-level official.
OFAC is designating Kosarac pursuant to E.O. 14033 for being owned or controlled by, or having acted or purported to act for or on behalf of, directly or indirectly, Dodik, a person whose property and interests in property are blocked pursuant to E.O. 14033.
Additional Russia-related action
Viktor Pavlovich Perevalov (Perevalov) is the First Deputy Director of U.S.-designated VAD, AO (VAD), a Russia-based construction company that has built infrastructure throughout Russia, as well as highways in Russia-occupied Crimea. OFAC previously designated Perevalov on January 26, 2018 pursuant to E.O. 13685 for having acted or purported to act for or on behalf of, directly or indirectly, VAD. Today, OFAC is designating Perevalov pursuant to E.O. 14024 for operating or having operated in the construction sector of the Russian Federation economy.
Sanctions implications
As a result of today’s action, all property and interests in property of the persons 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, 50 percent or more by one or more blocked persons are also blocked. All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC, or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as from engaging in conduct that evades U.S. sanctions. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation.
In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the 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 entities sanctioned today, click here.
Source – U.S. Treasury