June 18, 2024
WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating a network of two individuals and seven entities that provide major sources of revenue for U.S.-designated Republika Srpska (RS) President Milorad Dodik (Dodik) and his family. Dodik has used his official position to accumulate personal wealth through companies linked to himself and to Igor Dodik (Igor). For example, in 2024, Igor and Dodik exercised their control over senior Bosnia and Herzegovina (BiH) government officials to manipulate the draft BiH state budget so that a state-level contract could be awarded to Prointer ITSS d.o.o. Banja Luka Clan Infinity International Group—an entity in the network—outside of the competitive process.
“The United States condemns Dodik’s continued efforts to erode the institutions that have ensured peace and stability for Bosnia and Herzegovina and the region,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “We will continue to expose the fraudulent schemes that enable Dodik and his family to exploit their own people for their personal benefit.”
BACKGROUND
Dodik not only robs the people of BiH through his corrupt behavior but also threatens their safety and security through his repeated threats to pursue secession of the RS from BiH. Dodik’s recent announcement of a formal decision to propose RS “disassociation” from BiH is a continuation of blatantly anti-Dayton Peace Accords (DPA) activity and threatens the peace and stability of the region. Through his corruption and secessionist rhetoric, Dodik continues to undermine BiH institutions and enrich his family at the people’s expense, further risking BiH’s future in Euro-Atlantic institutions.
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 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.
DODIK FAMILY’S PATRONAGE NETWORK AND TIES TO PUBLIC TENDERS
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. Infinity International Group d.o.o. Banja Luka (Infinity) is a holding company in BiH that directly or indirectly owns or is the majority owner of at least five other BiH-based companies: Prointer ITSS d.o.o. Banja Luka Clan Infinity International Group (Prointer), Kaldera Company El PGP d.o.o. (Kaldera), Infinity Media d.o.o. (Infinity Media), K-2 Audio Services Banja Luka d.o.o. (K-2), and Una World Network d.o.o. (Una).
Additionally, Sirius 2010 d.o.o. Banja Luka (Sirius) is an information technology (IT) company that operates within the Dodik family network. Along with Prointer and Kaldera, Sirius is well-known in BiH for being awarded lucrative government contracts. Together, Prointer and Sirius provide IT goods and services to organizations across the RS and BiH governments, while Kaldera primarily operates in the engineering sector.
For many of these entities, Igor is often involved in business operations behind the scenes. For example, in April 2024, Sirius’ then-director resigned and Igor was involved in hiring a replacement. Igor was ultimately responsible for ensuring that each company — including Prointer, Sirius, and Kaldera — made payments to meet its financial obligations. Additionally, Igor approved a plan to settle Kaldera’s debt with a local bank, and subsequently a loan between Prointer and Kaldera was promptly executed. Igor was also involved in organizing a meeting to discuss new contracts with his associates and Prointer’s general manager.
Relatedly, this Dodik network often restructures corporate ownership to both hide the family’s involvement in companies and to evade sanctions. For example, Prointer took ownership of Alternativa Televizija d.o.o. (ATV) in 2021 but quickly transferred ownership to Infinity Media and K-2 after OFAC designated ATV on January 5, 2022, 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. As of early 2024, K-2 was in the process of merging with ATV, at which point K-2 would absorb and retain all of ATV’s assets and ATV would cease to exist.
Although Djordje Djuric (Djuric) and Milenko Cicic (Cicic) occupy ownership and management positions within the Network, respectively, Igor ultimately manages the financial decisions for network companies, including Prointer and Kaldera, and Igor’s approval is needed on business decisions. Djuric, as the ultimate owner of Infinity and its subsidiaries, is a close collaborator of Igor’s who frequently assists him in financial activities. For example, Djuric and Igor deliberately took steps to obfuscate their involvement in an offshore bank account and entity over which they shared control, probably enabling Igor to move millions of euros overseas.
Cicic is the general director of Kaldera. In this role, Cicic and the general manager of Prointer reported to Igor about Kaldera and Prointer’s business activities. Additionally, on one occasion, Cicic represented Igor at a meeting with some of Igor’s business partners and completed a series of financial transactions on Igor’s behalf with those same business partners. It is important to note that the “Milenko Cicic” being designated today is a different person than the “Milenko Cicic” who was the sole owner of Kaldera until its sale to Prointer at the end of December 2019.
Prointer, Kaldera, Sirius, and Cicic 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.
Djuric is being designated 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.
Infinity is 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, Djuric, a person whose property and interests in property are blocked pursuant to E.O. 14033.
Infinity Media is 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, Infinity, a person whose property and interests in property are blocked pursuant to E.O. 14033.
K-2 and Una 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, Infinity Media, 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 the 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, OFAC’s regulations 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.
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 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. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
Click here for more information on the individuals and entities sanctioned today.
https://home.treasury.gov/news/press-releases/jy2414
