Balkans

Various sanctions have been imposed in relation to the break-up of the former Yugoslavia dating to the early 1990s, by OFAC, the EU and the UN. Two programmes currently remain in force: one OFAC programme targeting individuals tied to ethnic violence and war crimes in the 1990s and an EU programme focussed on protecting the territorial integrity of Bosnia and Herzegovina.

 

On 25th March 2024 the EU renewed its Balkans sanctions program until 31st March 2026.

Sanction Name

Council Decisions Concerning Restrictive Measures In Bosnia And Herzegovina

First Imposed

March 22, 2011

Last updated

March 25, 2024

Targets

Asset Freeze and Travel Ban:
• No individuals are currently listed although the legislative framework remains in place.

Exemptions

1. Exemptions can be granted on a case-by-case basis for humanitarian grounds or in relation to the attendance of inter-governmental meetings.

On 8th January 2025, the President signed a new Executive Order, an amendment to EO14033, in view of events in the Western Balkans, including continued attempts by individuals to challenge the sovereignty and territorial integrity of Western Balkans nations, to undermine post-war agreements and institutions, to engage in significant corruption that erodes the rule of law and trust in democratic governance, and to evade United States Government sanctions.

On 17th January 2025, OFAC designated five individuals and one entity that facilitate Republika Srpska (RS) President Milorad Dodik and his family’s efforts to enrich themselves at the public’s expense. The action also targeted eight individuals who, at Dodik’s direction, organised and executed the commemoration of “Republika Srpska Day” (RS Day) in January 2024, in contravention to the principles of the Dayton Peace Agreement and which the Bosnia and Herzegovina Constitutional Court ruled unconstitutional.

Sanction Name

Blocking of Persons Who Threaten International Stabilization Efforts in the Balkans

SANCTIONS

Specially Designated National, Asset Freeze, Travel Ban,

First Imposed

June 27, 2001

Last updated

January 17, 2025

Targets

Specially Designated National:
• Individuals and entities linked to violence, acts of aggression, and those deemed to be undermining democratic institutions and processes for political gain.

Exemptions

1. US lawyers are permitted to represent persons whose property, or interests in property, have been blocked as part of cases heard in the International Criminal Tribunal for the former Yugoslavia.

2. Transactions relating to the manufacture, distribution, operation, installation, or maintenance and repair of pumps manufactured or distributed by Kaldera Company EL PGP are authorised.

Links 1

Western Balkans Stabilization Regulations
Executive Order 13219 - Blocking Property of Persons Who Threaten International Stabilization Efforts in the Western Balkans (27/06/2001)
Executive Order 13304 - Termination of Emergencies With Respect to Yugoslavia and Modification of Executive Order 13219
Executive Order 14033 - Blocking Property and Suspending Entry into the United States of Certain Persons Contributing to the Destabilizing Situation in the Western Balkans (08/06/2021)
Executive Order 14140 - Taking Additional Steps With Respect to the Situation in the Western Balkans
General License 1 - Legal Representation in Matters Pending before the International Criminal Tribunal the former Yugoslavia
General License 2 - Authorising the Wind Down of Transactions Involving Orka Holding AD
General License 3A - Authorising Certain Transactions Related to Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, Software Updates, or Medical Prevention, Diagnosis, or Treatment, or Clinical Trials Involving Certain Blocked Entities
General License 4 - Authorising the Wind Down of Transactions Involving Certain Entities Blocked on June 18, 2024
General License 5 - Authorising Certain Transactions Involving Pumps Manufactured or Distributed by Kaldera Company EL PGP d.o.o. for the Treatment or Distribution of Drinking Water
General License 5A- Authorising Certain Transactions Involving Pumps Manufactured or Distributed by Kaldera Company EL PGP d.o.o. or Elpring d.o.o. Laktasi for the Treatment or Distribution of Drinking Water