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Financial Services Law Insights and Observations

OFAC sanctions persons in Bosnia and Herzegovina

Financial Crimes Of Interest to Non-US Persons Department of Treasury OFAC OFAC Sanctions OFAC Designations Bosnia Herzegovina SDN List

Financial Crimes

On October 3, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 14033 against two individuals and one business entity in Bosnia and Herzegovina (BiH). According OFAC, these designations follow OFAC’s September 26 designation of a corrupt state prosecutor in BiH and build on other recent sanctions imposed on individuals and entities in the region (covered by InfoBytes here). Collectively, OFAC noted that “these actions underscore the United States’ willingness to hold accountable those enabling divisive and destabilizing activities in the Western Balkans.” OFAC further noted that one of the designated individuals is one of the wealthiest individuals in BiH and is the longtime owner of a large engineering firm. According to OFAC, the individual and the firm “have been linked to corruption in the construction sector.” The sanctions also target the Prime Minister of the Federation of Bosnia and Herzegovina for “misus[ing] pensioner data for the benefit of his own political party and contrary to BiH law.” As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals and entities subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” OFAC further noted that “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,” which “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.”