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Sanctions for destabilizing and corrupt activity

The US Treasury’s announcement today of sanctions on Milorad Dodik and Alternativna TV merits reprinting in full. I don’t expect this will have any immediate effect on Dodik or his TV station, both of which presumably anticipated it. Dodik probaby does most of his personal business in cash anyway. The TV station may have some trouble with international transfers. But more importantly this decision will have a PR and psychological effect. It is a clear and unequivocal signal that the United States wants Dodik gone and a warning to those politicians who support his destabilizing activities. The impact will be greater if European Union member states join in:

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Milorad Dodik (Dodik), who is a member of the Presidency of Bosnia and Herzegovina (BiH), as well as one entity under his control, Alternativna Televizija d.o.o. Banja Luka, in response to Dodik’s corrupt activities and continued threats to the stability and territorial integrity of BiH.

Today’s action, the first designations under E.O. 14033, builds on the Biden Administration’s commitment to promote accountability for those who, among other things, undermine the stability of the Western Balkans region through corruption and threats to long-standing peace agreements. Dodik has undermined BiH institutions by calling for the seizure of state competencies and setting in motion the creation of parallel institutions in BiH’s Republika Srpska (RS) entity. Furthermore, Dodik has used his official BiH position to accumulate personal wealth through graft, bribery, and other forms of corruption. His divisive ethno-nationalistic rhetoric reflects his efforts to advance these political goals and distract attention from his corrupt activities. Cumulatively, these actions threaten the stability, sovereignty, and territorial integrity of BiH and undermine the Dayton Peace Accords, thereby risking wider regional instability.

“Milorad Dodik’s destabilizing corrupt activities and attempts to dismantle the Dayton Peace Accords, motivated by his own self-interest, threaten the stability of Bosnia and Herzegovina and the entire region,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will not hesitate to act against those who pursue corruption, destabilization, and division at the expense of their own people, as well as against those who enable and facilitate this behavior.”

DODIK’S DESTABILIZING AND CORRUPT ACTIVITIES

The Dayton Peace Accords (DPA), signed by the Presidents of Bosnia and Herzegovina, Croatia, and Serbia in 1995, brought an end to ethnic conflict in BiH and established the present-day constitution of BiH. Treasury previously designated Dodik on January 17, 2017, pursuant to E.O. 13304, for having actively obstructed or posed a significant risk of actively obstructing the DPA. Today’s actions build on this legacy by targeting his ongoing destabilizing activity with respect to the DPA, as well as his abuse of his official position to engage in widespread corruption, which undermines state institutions in BiH.

Dodik has also openly called for, and has taken action toward, the unilateral transfer of state competencies from the BiH government to the Republika Srpska (RS), one of two entities that comprise BiH along with the Brcko District. Dodik has also publicly opposed the internationally appointed High Representative for BiH and the composition of the BiH Constitutional Court. Additionally, Dodik has publicly denigrated other ethnic and religious groups within BiH, further sowing division and political gridlock. Dodik, therefore, is being designated pursuant to 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.

Dodik is also being designated pursuant to E.O. 14033 for being responsible for or complicit in, or having directly or indirectly engaged in, corruption related to the Western Balkans. Specifically, he has established a patronage network in BiH from which he and his associates benefit. As one example of his corrupt actions, Dodik has provided government contracts and monopolies in the RS directly to close business associates. With his corrupt proceeds, Dodik has engaged in bribery and additional corrupt activities to further his personal interests at the expense of citizens in the RS.

DODIK’S PERSONAL MEDIA STATION

Alternativna Televizija d.o.o. Banja Luka (ATV), a media outlet based in Banja Luka, RS, is privately owned by a company closely linked to Dodik’s family. However, Dodik himself exerts personal control over ATV behind the scenes, such as by requiring personal approval on media stories related to politically sensitive topics. Dodik acquired ATV to deliberately and expressly further his own agenda, which includes his efforts to denigrate other political figures, burnish his public image, and advance his own personal and political goals.

Dodik has awarded ATV-related contracts directly to members of his family, which he has used as yet another avenue for corruption. He has funneled money directly from public companies to ATV for corrupt purposes. Dodik has substantially increased funding for ATV in recent years and engaged in malign social media influence campaigns through ATV to publish content that advances his political and personal goals.

ATV 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, Dodik.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individual and entity 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. Unless authorized by a general or specific license issued by OFAC, or exempt, 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 are generally prohibited. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.

For identifying information on the individual and entity designated today.