Treasury Expands Sanctions on Republika Srpska Network Evading U.S. Sanctions

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating one individual and one entity who support a corrupt patronage network in Bosnia and Herzegovina (BiH) that is attempting to evade U.S. sanctions. This network is directly linked to U.S.-designated Igor Dodik (Igor), the son of Milorad Dodik (Dodik), the U.S.-designated President of BiH’s Republika Srpska (RS), one of two entities that make up BiH. For years, Dodik has used his official position to accumulate personal wealth through companies linked to himself and Igor. This corruption has contributed to an undermining of public confidence in BiH state institutions and the rule of law. 

“RS President Milorad Dodik, his associates, and his enablers continue to use their privileged position to erode public confidence in the regional peace frameworks and institutions that have brought stability and security to Bosnia and Herzegovina,” said Acting Under Secretary of the Treasury for Terrorism and Financial Intelligence Bradley T. Smith. “The United States remains committed to exposing the efforts of Dodik and his family to maintain their corrupt patronage networks.” 

Today’s action bolsters previous designations against the Dodiks by exposing Igor’s blatant attempts to evade U.S. sanctions and targeting the individuals who enable the family’s activities that hinder democratic development in the RS. 

IGOR DODIK’S FINANCIAL NETWORK AND ATTEMPT TO EVADE THE EFFECTS OF U.S. SANCTIONS

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 Agreement (DPA), as well as for corrupt activities. 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 and June 18, 2024 designations of core parts of the Dodiks’ corrupt patronage network, including several entities and individuals under Igor’s direct control. Since the designations, the Dodik network has pursued an aggressive strategy to attempt to circumvent the effects of sanctions, namely by restructuring and reestablishing corporate entities to obfuscate his control and transfer company assets from designated entities. 

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. One of these individuals is Vladimir Perisic (Perisic), the general director of Prointer ITSS (Prointer), designated by OFAC on June 18, 2024. As the general director of Prointer — an entity controlled by Igor — Perisic provided updates to Igor, solicited Igor’s approval and guidance, and executed business decisions based on Igor’s instructions. Additionally, Perisic proposed and followed through on a corrupt kickback scheme involving Prointer after receiving instructions and approval from Igor.

After Kaldera Company’s (Kaldera) designation on June 18, 2024, Igor directed U.S.-designated Milenko Cicic (Cicic) (designated on June 18, 2024) to establish Elpring d.o.o. Laktasi (Elpring), which would serve as a replacement for Kaldera. With Igor’s approval, Cicic established Elpring and coordinated the transfer of all of Kaldera’s assets and operations, to include Kaldera’s employees, to Elpring. Throughout this process, Cicic routinely requested Igor’s approval to make key business decisions and ensured that both Igor and himself would have an account for Elpring which they could exercise control over.

Perisic and Elpring are being designated 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.

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.

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