The United States (US) has 398 active sanctions on individuals, companies and organizations from the Western Balkans, as of January 31, 2025, according to research by Voice of America.
By far the highest number of sanctions applies to Bosnia and Herzegovina (BiH) – 177, followed by Serbia (80), Kosovo (60), North Macedonia (46), Albania (23) and Montenegro (11). One punitive measure applies to a person from Croatia.
Voice of America has created the first searchable database that includes all sanctions imposed by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) and sanctions imposed by the State Department from 2017 to 2024.
“Sanctions are one of the most important tools of U.S. foreign policy,” says Richard Nephew, a sanctions expert who until recently served as the State Department’s coordinator for global anticorruption. “They give us the ability to engage with hostile actors and to pressure those we want to make a particular policy decision.”
John Smith, former director of OFAC, says that the primary goal of US sanctions is “to deter and stop certain activities of concern and to get individuals to change their behavior.” He adds that it is important to note that most US sanctions, including those for the Western Balkans, are not aimed at entire countries but at individuals and organizations.
The US has imposed sanctions on the Western Balkans mainly in two periods. Between 2001 and 2004, they were imposed for war crimes, destabilization of countries, and threats to peace after the breakup of Yugoslavia. After a long period with only a few sanctions per year, these foreign policy measures have become relevant again since 2021, and mainly relate to corruption, threats to peace and stability, and Russia's invasion of Ukraine.
Among others, in the past four years, numerous high-ranking officials have been sanctioned, such as the President of Republika Srpska in BiH Milorad Dodik, Ministers in the Serbian Government Aleksandar Vulin and Nenad Popović, former Prime Minister of North Macedonia Nikola Gruevski, former President of Serbia and Montenegro Svetozar Marović, and former Prime Minister of the Federation of BiH Fadil Novalić.
"Over the past few years, we have seen many different actors in the Western Balkans threatening the stability of the countries in the region. They can do this in a variety of ways, from undermining democratic processes, to threatening human rights, or by engaging in corruption that drains these countries," says Nefew, who is now a senior fellow at Columbia University.
Voice of America found that the remaining sanctions on the Western Balkans were most often imposed for terrorism, organized crime, and drug trafficking.
Most recent sanctions for Dodik and associates
Since the wars in the former Yugoslavia, US presidents have renewed the state of emergency for the Western Balkans every year, which makes it easier to maintain old sanctions and impose new ones. Sanctions are also imposed for reasons that threaten US national security, based on legislative acts or presidential decrees.
Most of the sanctions in the Voice of America database were imposed by OFAC – 341 – and are classified into different lists. The largest is the “Balkans” list with 152 individuals and 16 companies and organizations. Among others, it includes war criminals Radovan Karadžić, Veselin Šljivančanin, Milan Martić and Ratko Mladić, members of Slobodan Milošević’s family, as well as organizations such as the Chetnik Ravna Gora Movement and the Kosovo Liberation Army.
All sanctions on the "Balkans" list – except for Milorad Dodik – were imposed in the period 2001-2004.
Dodik was first sanctioned in January 2017 for obstructing the Dayton Peace Agreement, and was the first BiH official sanctioned under the regulation "EO 14033", in January 2022. The reasons given at the time were undermining the institutions of BiH, working to create parallel institutions in RS, corrupt activities, and ethno-nationalist rhetoric.
Including Dodik, OFAC’s “EO 14033” list includes a total of 76 individuals and entities, mostly from Bosnia and Herzegovina – and mostly Dodik’s associates and family members. Among them are BiH Presidency Member Željka Cvijanović, Dodik’s children Igor and Gorica, as well as a number of individuals and companies with whom they are associated.
The sanctions on that list were introduced based on the executive order of the same name, with which then-US President Joe Biden expanded sanctions authority in the Western Balkans in June 2021. In addition to threatening stability and peace agreements, "widespread corruption" was cited for the first time as a potential reason for US punitive measures.
At a press conference on January 23, 2025, Dodik stated that US sanctions had proven to be unsuccessful and pointless. However, the events of the past 12 months do not fully support this claim.
Since US authorities warned banks in BiH in March 2024 that they should not do business with sanctioned individuals and companies, banks have begun closing their accounts. One consequence is that officials, including Dodik, have no longer been able to receive their salaries.
“Part of our goal is to warn banks that there are bad actors out there and that they need to be concerned about that and that they risk being exposed [to sanctions] themselves,” Nefew explains. “A lot of these banks may not have an opinion about a particular individual, but they do have an opinion about their ability to access the American financial system. That’s a power we can use.”
Smith, who is now a partner at the law firm Morrison Forester, in charge of national security, says it's a common practice: "And during my time at OFAC, we would travel around the world and recommend to banks and other reputable companies not to do business with those who were sanctioned."
In an attempt to circumvent the sanctions, new companies were opened in the RS with a different name and similar or identical ownership structure to those under sanctions. However, US authorities actively detected such attempts and imposed new sanctions.
On January 18, 2025, Gorica Dodik announced on the Eks website that she was closing the Agape restaurant because its accounts had been closed, making it impossible to pay employees. Agape was sanctioned in October 2023, and in December 2024, OFAC also listed Best Service, stating that it was "registered at the same address as Agape, and like Agape, operates in the restaurant and food services sector in the RS."
"The consequences are multiple. We have a large number of companies where people have lost their jobs, which have ceased operations precisely because their accounts have been closed," says Ivana Korajlić, executive director of Transparency International BiH.
"What I would say is a positive effect that we can only expect in the long term, and that is that it will be increasingly difficult for the corrupt regime to ensure the obedience of its party colleagues who will probably have to think more carefully when entering into certain 'deals' or making certain decisions, that they really cannot be protected in that respect, that they will not be subject to sanctions and that they will not suffer such consequences as the inability to have a bank account and the inability to conduct financial business," adds Korajlić.
State Department sanctions and US entry ban
Apart from the "Balkans" and "EO-14033" lists, the largest number of those from the Western Balkans sanctioned by OFAC are on the "GLOMAG" (52) and "Russia-EO 14024" (18) lists.
GLOMAG sanctions are imposed for human rights violations, corruption and crime, based on the Magnitsky Act, named after the lawyer Sergei Magnitsky who died in a Russian prison after investigating potential tax fraud. The list includes companies and individuals from Serbia and Kosovo.
For example, in December 2021, Zvonko Veselinović was sanctioned, whom the Secretariat of Finance stated was the leader of an organized crime group and “one of the most notorious corrupt figures in Kosovo.” The same list also included Milan Radoičić, the former vice president of the Serbian List, against whom Kosovo authorities in 2024 indicted him for terrorism and endangering the constitutional order of Kosovo, for an attack on the police in Banjska.
Smith says that corruption as a reason for sanctions began to be cited around the time of the Magnitsky Act, in 2012, "when the government realized that if you have corruption, it often leads to a lot of other related concerns, often where you have officials or those associated with officials stealing resources from the state or unfairly exploiting their positions."
According to him, another reason why corruption is increasingly used as a reason for sanctions is that it is easier to prove because it is regulated by law: "Most countries do not allow you to steal public funds or abuse your position, so it is easier for people to understand what sanctions are."
The sanctions on the "Russia-EO 14024" list were imposed for Russia's invasion of Ukraine and support for Russia's malign activities against the United States and its partners, including assistance to the Russian military industry and violations of international law.
The most prominent name on that list is the Oil Industry of Serbia (NIS), listed on January 10, 2025, as a subsidiary of Russia's Gazpromneft. In early February, NIS requested a 90-day reprieve from OFAC.
Sometimes sanctions are imposed in parallel by both OFAC and the State Department, for example in the cases of the former director of the Intelligence and Security Agency of Bosnia and Herzegovina, Osman Mehmedagić, or the former director of the secret service of North Macedonia, Saša Mijalkov.
Unlike OFAC measures, which primarily relate to the prohibition of economic and financial activities and the blocking of assets, the State Department prohibits sanctioned officials and their family members from entering the United States, based on Section 7031(c) of the State Department Appropriations Act.
The Voice of America database includes 57 such State Department measures.
Nefew explains that both US institutions that impose sanctions on the Western Balkans follow a similar process. This includes gathering information, making a case, determining that sanctions can be imposed in accordance with US regulations, consulting with other parts of the government and considering the type of sanctions, and ultimately making a decision.
According to him, the process can sometimes be quick – as in the case of imposing sanctions on the Gaddafi family in Libya, which took about 12 hours – and sometimes it can take a very long time "because it is more difficult to find evidence, there is disagreement about the legal basis" or for other reasons.
"I don't know if there's a perfect average, but I think you can always assume it's going to take at least a few months, three or four months or something like that," Nefew says.
How effective are sanctions?
When imposing sanctions, the most common explanations include a ban on entry into the US, the blocking of assets and businesses in the US, as well as a ban on doing business with American companies and citizens.
Considering that those sanctioned from the Western Balkans most often do not have property or financial interests in the US, and that in a large number of cases they continue to participate in public life, run for office and receive thousands of votes in elections, and hold important positions, the public often questions the effectiveness of sanctions.
Ruggiero Scaturo, a senior analyst at the Global Initiative against Transnational Organized Crime, is one of the authors of a report on the effectiveness of sanctions in the Western Balkans, published in December 2024. He tells Voice of America that the impact of sanctions is not the same in all countries.
For example, says Skaturo, in Albania and North Macedonia there have been situations where ruling politicians and parties distanced themselves from sanctioned individuals in order to protect their own reputations.
"In contrast, in countries like Bosnia and Herzegovina and Serbia, we definitely identified completely different scenarios, where individuals have advanced to senior ministerial positions and more important roles than they had when they were sanctioned," Scaturo adds, noting that this contributes to the perception that US sanctions have limited effectiveness.
Aleksandar Vulin was placed on OFAC's "EO 14033" list in July 2023, when he was head of the Security and Intelligence Agency of Serbia (BIA), for "involvement in transnational organized crime, illegal narcotics operations, and abuse of public office." He resigned in November, stating that it was a concession to prevent the US and the European Union (EU) from blackmailing Serbia. However, in April 2024, he became Deputy Prime Minister of Serbia.
Scaturo says his analysis has shown that many individuals under sanctions abuse this and "present themselves as victims of political discrimination by the US or the UK", while in countries like Bosnia and Herzegovina public support for those sanctioned sometimes grows, "especially when sanctions are seen as politically motivated or unjust".
Korajlić states that in BiH, the justification of sanctions for corruption is generally not questioned "except in the part where there is a clear perception that these sanctions do not cover everyone who should be covered", but the sanctions are being manipulated due to destabilization and non-compliance with the Dayton Peace Agreement and officials are presenting them "as an attack on the entire people".
According to her, before banks started closing accounts, sanctions were considered a kind of public warning: "Only then was it actually taken seriously in some way and only then did it have an effect, if nothing else, at least a warning for future decisions that potentially any public office holder could make."
The sanctions have not changed the behavior of Dodik and his supporters much. For example, RS officials have continued to celebrate RS Day on January 9th – even though the Constitutional Court of Bosnia and Herzegovina has twice ruled it unconstitutional, which is why some of the sanctions were imposed.
“The simplest way to say that we use sanctions is to change behavior. If you impose sanctions on a person who is involved in terrorism, you want them to stop being a terrorist and engaging in terrorism,” Nefew says. “They’re probably not going to do that. So there’s another goal, which is to make it harder to engage in terrorism.”
Voice of America interlocutors state that one of the consequences of US sanctions should be a reaction from local institutions, which would potentially conduct investigations into the allegations in the justification for the sanctions. In practice, this rarely happens.
In September 2024, Transparency International BiH filed a lawsuit against the Prosecutor's Office of BiH for withholding information about whether the prosecutor's office had investigated OFAC's allegations of officials' involvement in corruption.
“Ultimately, individuals can often act without concern for legal or even reputational consequences,” says Skaturo. “Sanctions can bring about some form of behavioral change, but their success is really limited by local political dynamics.”
Nefew says that sometimes it’s simply important to label “some of these individuals as corrupt actors.” He adds that there have been cases in Albania where authorities have investigated sanctioned individuals, and that this shows that a single U.S. punitive measure “may not have a large financial impact on the bad actor, but it can have a much broader impact on a particular country and the justice system.”
Voice of America interlocutors agree that US sanctions would be more effective if they were also introduced by the European Union, where officials and companies have property and financial interests, but also travel to European countries much more frequently.
However, so far, EU members have not agreed on sanctions for the Western Balkans. For example, Hungary and its Prime Minister Viktor Orban oppose sanctions against Dodik, even though the European Parliament has proposed it.
The State Department and OFAC did not respond to Voice of America's questions about the effectiveness of the sanctions.
How often does OFAC update the data?
OFAC data is not always complete and accurate, so some names are misspelled, and many older sanctions do not list the country or, for example, list “Serbia and Montenegro.” In those cases, VOA added data to its database based on the place of birth or the country in which the person or company conducted activities for which they were sanctioned.
OFAC occasionally – but not regularly – updates the information on its lists, for example, when a person on the list dies, or when other reasons arise for lifting sanctions.
Slobodan Stanković, once one of the most powerful businessmen in Bosnia and Herzegovina, was sanctioned in October 2022 for his support for Milorad Dodik and “connections to corruption.” He died in February of the following year, after which OFAC removed him from the list.
The reason for removal from the sanctions list may also be a court decision. Aleksandar Karadžić, son of Radovan Karadžić, was removed from the "Balkans" list after suing OFAC.
Bonus video:
