What Did America Get for Lifting Sanctions on Milorad Dodik? - Congressional Issue Brief
JEDNA BiH | CONGRESSIONAL POLICY BRIEF
JEDNA BiH • ISSUE BRIEF
OCTOBER 2026

What Did America Get for Lifting Sanctions on Milorad Dodik?

Nearly a year after Washington lifted sanctions, Dodik says he sought both sanctions relief and the departure of the High Representative, Christian Schmidt. The public record raises questions about what was agreed, what Washington gained, and whether U.S. policy still protects the Dayton Peace Agreement.

$8.9M FARA Disclosed

Paid by the Republika Srpska government to 11 lobbying firms since January 2025, according to OCCRP's review of U.S. Justice Department filings. Those paid include people from President Trump's political circle.1,2

Source: U.S. DOJ FARA & OCCRP ⚜

WHAT WE ARE ASKING CONGRESS TO DO

  1. 1 Follow up on the March 27 letter and get a written answer on whether a determination on Dodik has been made under the sanctions law.
  2. 2 Obtain the full record of the October 2025 decision to lift his sanctions.
  3. 3 Back renewal of the EUFOR peacekeeping mission and a permanent High Representative.
Legislative Priorities for Oversight ⚜
⚜

HOW THE DEAL UNFOLDED

May 29, 2025

Bosnia's Constitutional Court annuls the RS laws behind the crisis5

Oct 29, 2025

U.S. lifts sanctions after RS repeals the already-annulled laws3

Mar 18, 2026

Deadline in the sanctions law passes without action on Dodik15

Jul 1, 2026

High Representative Christian Schmidt leaves office8

⚜ THE CENTRAL QUESTION

What did the United States get in return?

On October 29, 2025, the United States lifted sanctions on Milorad Dodik. The State Department credited "constructive actions" by the Republika Srpska National Assembly, which had repealed laws that Bosnia and Herzegovina's Constitutional Court annulled about five months earlier.3,4,5

In a televised interview this October, Dodik said he had also demanded the removal of Christian Schmidt, the international High Representative who oversees the Dayton Peace Agreement, and that U.S. officials agreed.6 Schmidt later told Germany's Tagesspiegel that the American side clearly expected him to end his mandate.7 He announced his resignation in May 2026 and left office on July 1.8

Taken alone, these accounts do not establish the terms of a formal agreement. They do raise a question the Administration has not answered in public: what commitments, if any, came with sanctions relief, and what did the United States get in return? That question is harder to set aside given how much Republika Srpska has spent on Washington lobbying, the White House access its lobbyists arranged, and Dodik's continued alignment with Moscow.

⚜

WHAT HAPPENED AND WHEN?

Date Event & Documentation
May 29, 2025 Bosnia's Constitutional Court annuls the Republika Srpska laws at the center of the crisis.5
Aug 1, 2025 An appeals court upholds Dodik's conviction for defying the High Representative: a year in prison, later converted to a fine, and a six-year ban from office. Five days later he is stripped of the Republika Srpska presidency.9,10,11
Oct 28, 2025 Dodik meets Russian Foreign Minister Sergei Lavrov in Minsk and reaffirms their strategic partnership.12
Oct 29, 2025 The United States lifts sanctions on Dodik and his associates. RRB Strategies, the firm of former Illinois Governor Rod Blagojevich, reports receiving $700,000 from the RS government the same day. Dodik later said he learned of the decision as he landed in Moscow, and that all that was left was to find a good tavern with Serbian music and celebrate.3,13,14
Mar 18, 2026 Deadline for sanctions under the Western Balkans Democracy and Prosperity Act, as cited by members of Congress, passes without action on Dodik.15
May 2026 Schmidt announces his resignation. An RS delegation led by Dodik, including RS President Siniša Karan and Assembly Speaker Nenad Stevandić, meets Putin in Moscow. The RS Assembly adopts a declaration calling for the High Representative's office to be closed.2,8,16
Jul 1, 2026 Schmidt leaves office. His deputy, Louis Crishock, becomes acting High Representative.8
Sep 29, 2026 Putin publicly backs Dodik's ruling coalition, five days before Bosnia's general election.17
Oct 4, 2026 After his coalition wins, Dodik thanks both Putin and Trump in his victory speech.18
⚜

What the Administration has told Congress

Dodik's version comes from his own description of the negotiations, and he has reasons to overstate his success. Schmidt's account is separate from Dodik's and partly corroborates it.6,7

The Administration's public explanation is different. In December 2025, responding to House Foreign Affairs Committee Democrats William Keating and Gregory Meeks, the State Department credited its own diplomacy with ending the crisis.2

At a September 15 hearing of the House Europe Subcommittee, Deputy Assistant Secretary of State Daniel Lawton said U.S. diplomacy led the RS Assembly to drop most of its anti-Dayton laws, which removed the main reason for the sanctions.19,20 Neither statement mentions that the Constitutional Court had already annulled those laws, and neither addresses what Schmidt said about Washington's expectations.

“
THE STATE DEPARTMENT TO CONGRESS
DECEMBER 3, 2025
"The Administration engaged in decisive, discreet diplomacy to de-escalate the situation."

Response to Reps. Keating and Meeks, reproduced in the Europe Subcommittee minority report.2

⚜

QUESTIONS THE PUBLIC RECORD LEAVES OPEN

?

What did Washington require of Dodik before lifting sanctions?

?

Were any commitments made about Schmidt or the Office of the High Representative?

?

Who took part in the negotiations, on both sides?

?

What did U.S. officials expect the Assembly's repeal to accomplish, given that the court had already struck those laws down?

⚜

LOBBYING TO DIVIDE BIH

Lobbying Campaign Aims and Scope

According to OCCRP's review of Justice Department filings, the RS government paid at least $8.9 million to 11 lobbying firms from January 2025 onward. The campaign's aims included lifting Dodik's sanctions, removing Schmidt and building support in Washington for Republika Srpska's illegal independence.1

In September, Bosnia's Constitutional Court ruled that RS lobbying for aims contrary to the constitution is unconstitutional and barred payments under the Dickens & Madson contract.21,22 Some of the other payments disclosed in filings and reporting are listed below.

“
A STATED GOAL OF ONE RS LOBBYING CONTRACT
"...remove Christian Schmidt as High Representative in Bosnia Herzegovina…"

Contract between Republika Srpska's representative office in Vienna and Dickens & Madson Canada Inc., a Montreal firm, as reported by OCCRP.1,18

The filings and reporting also show how far that access reached. Continental partner Alex Garcia, a former deputy political director of Trump's presidential campaign, was in Republika Srpska on election day.24,26 The firm's September 30 FARA filing says he helped arrange meetings with White House officials Walker Barrett, Jarrod Agen and Richard Walters.13,24 A White House official confirmed that Garcia arranged a September meeting between Chief of Staff Susie Wiles and Željka Cvijanović, the Serb member of Bosnia's presidency and a close Dodik ally.26

SELECTED PAYMENTS IN THE FILINGS AND REPORTING Disclosed Amount
Dickens & Madson, a Canadian lobbying firm, founded by former Israeli military intelligence officer Ari Ben-Menashe, contracted with RS Oct 3, 2025.33
$1 million to sign in 2025
$4 million total contract worth34
Zell & Associates International Advocates, founded by Israeli-American lawyer Marc Zell, contracted with RS on Jan 13, 2025.35 $1 million
RRB Strategies, the firm of former Illinois Governor Rod Blagojevich, reported received on October 29, 202510 $700,000
Michael Flynn, former national security adviser, as a consultant to RRB Strategies (October 2025 filing)10 $100,000 a month
McGinnis Lochridge, Austin, Texas (one-year contract signed January 2026)20 About €1.5 million
Continental Strategy, Washington21 $35,000 a month
James Blair and Chris LaCivita, advising Dodik's campaign before the October 4 election19,22 Hundreds of thousands each, as reported

Disclosed RS Lobbying & Advisory Commitments (2025–2026)

The New York Times reported that Blair, who runs MAGA Inc., and LaCivita, co-manager of Trump's 2024 campaign, were paid to advise Dodik's campaign through a Washington law firm hired by the RS government.22,25 Semafor reported that Continental helped arrange their trip, which the firm disputes.24 CBS News verified a photo of Katie Wiles, the Chief of Staff's daughter and a Continental partner, at a shooting range in Republika Srpska with RS Interior Minister Željko Budimir. Continental said her two-day August trip was for a U.S. client's feasibility study and that she has not discussed RS with U.S. officials. The White House said Susie Wiles does not discuss work with her daughters.26

None of this proves that lobbying produced the sanctions decision or Schmidt's departure. Establishing that would take the communications, agreements and decision records behind both, and Congress has the standing to ask for them.

⚜

Concern in both parties

Republicans have raised concerns as well. GOP operatives told Politico the Blair and LaCivita trip was "legitimately shocking," and Steve Bannon called for an accounting of the money the two were paid.22,27 On October 7, Trump wrote on Truth Social that "if there's a conflict, I will terminate them, immediately!" He also said the two were outside consultants who are allowed to have multiple clients.22,28

Concern about Dodik on Capitol Hill predates this administration's decision. In March 2025, Senate Foreign Relations Chairman Jim Risch and Senator Chuck Grassley joined Senator Jeanne Shaheen and others in urging Secretary Rubio to expand sanctions on Dodik over his moves toward secession.29 After the deadline in the sanctions law passed, Republicans Grassley, Roger Wicker, Thom Tillis, Mike Turner and Ann Wagner joined Democrats Shaheen, Dick Durbin and Elizabeth Warren in a March 27, 2026 letter pressing Secretaries Rubio and Bessent to impose sanctions on him.15

⚜

Dodik's ties to Moscow

The sanctions decision did not produce any visible break with Russia. The day before sanctions were lifted, Dodik met Lavrov in Minsk.12 His September 29 meeting with Putin in Moscow was, by European Western Balkans' count, their eleventh since Russia's full-scale invasion of Ukraine. He used it to propose annual joint sessions of the Russian and RS governments, and said Republika Srpska would not allow sanctions on Russia, NATO membership for Bosnia, or visas for Russian citizens.17,30

At the same meeting, Dodik promoted Russian interest in Orao, an aircraft maintenance and overhaul company in Bijeljina, and Moscow promised to keep RS's gas at the same price.17,30 Bosnia's constitution gives foreign policy to state institutions, not to either entity, so formal annual sessions between the RS and Russian governments would amount to a parallel foreign policy.

Dodik has kept these ties while also receiving sanctions relief and access in Washington, and he credits both capitals for his position. In his October 4 victory speech he thanked Putin and Trump.18

⚜

Why Congress should act now

Several decisions about Bosnia's future are coming due at once. Bosnia has had only an acting High Representative since July 1, and the State Department told Congress in September that there was no consensus on a successor.8,19 In May, the RS Assembly adopted a declaration calling for the High Representative's office to be closed.2

The UN Security Council's authorization of EUFOR Althea, the EU-led peacekeeping mission in Bosnia, also comes up for renewal this fall. The current authorization was adopted unanimously on October 31, 2025.31 Russia holds a veto on the Council and is openly backing Dodik's coalition, and the High Representative's office has no permanent leader, which gives Moscow an opening to bargain over the renewal.

Congress has already given the Administration the tools to act. The Western Balkans Democracy and Prosperity Act, enacted in December 2025 as part of the FY2026 National Defense Authorization Act, requires the President to impose sanctions on those he determines are threatening peace, stability or territorial integrity in the Western Balkans. It set a 90-day deadline, which passed on March 18, 2026. Any waiver requires advance notice to Congress.15,32 We have found no public statement from the Administration on whether it has made a determination on Dodik under the law.

⚜

What Congress should do

1

Enforce the law Congress passed

Seven months after the March 18 deadline, Congress still does not know where the Administration stands on Dodik. The signers of the March 27 letter to Secretaries Rubio and Bessent should ask for a written answer within 30 days: has the President made a determination on Dodik under the Act, and has a waiver been issued? If Dodik meets the law's criteria, the Administration already has the authority to act and should use it. Congress should also require advance notice before executive-order sanctions on Western Balkans actors are lifted, as the Act already does for its own sanctions.

2

Demand the full record of the October 2025 decision

Most of what is public about the October decision comes from Dodik, on television, and from Schmidt, in a German newspaper. Members should ask the State Department for a briefing now on who negotiated the delisting, what was agreed and why, and what, if anything, Dodik committed to in return. It should also cover every contact between U.S. officials and the lobbyists Republika Srpska has paid.

3

Protect Dayton and regional security

Bosnia has had only an acting High Representative since July, and EUFOR's mandate comes back to the UN Security Council this fall, where Russia holds a veto. Congress should press the Administration to back the renewal and to work with European allies on appointing a permanent High Representative.

⚜

Sources

35 Documented References
  1. OCCRP, "Serb Separatists Paid Millions in Lobbying Campaign that Targeted Diplomat Tasked with Protecting Peace in Bosnia," May 15, 2026. occrp.org/en/feature/serb-separatists-paid-millions-in-lobbying-campaign-that-targeted-diplomat-tasked-with-protecting-peace-in-bosnia
  2. House Foreign Affairs Committee Minority, Subcommittee on Europe (Rep. William Keating), "Pay for Play in the Balkans," Sep 15, 2026, including the State Department's Dec 3, 2025 response to Reps. Keating and Meeks (Annex 2). keating.house.gov/sites/evo-subsites/keating-evo.house.gov/files/evo-media-document/keating-bosnia-report.pdf
  3. RFE/RL, "US Removes Pro-Russian Bosnian Serb Politician Milorad Dodik And Allies From Sanctions List," Oct 29, 2025. rferl.org/a/us-pro-russian-bosnian-serb-dodik-sanctions-list/33576314.html
  4. Beta Briefing, "State Department: Sanctions against Dodik Cancelled Owing to RS Assembly's Constructive Measures," Oct 30, 2025. betabriefing.com/news/region/32948
  5. bne IntelliNews, "Bosnia's top court annuls secessionist laws passed by Republika Srpska," May 30, 2025. intellinews.com/bosnia-s-top-court-annuls-secessionist-laws-passed-by-republika-srpska-383700
  6. Dodik television interview on the sanctions negotiations, October 2026.
  7. N1, "Schmidt za Tagesspiegel: Amerikanci su tražili moj odlazak," Jul 1, 2026 (Bosnian, citing Der Tagesspiegel). n1info.ba/vijesti/schmidt-za-tagesspiegel-amerikanci-su-trazili-moj-odlazak-dodik-placao-milione-lobistima-protiv-mene
  8. European Western Balkans, "Louis J. Crishock appointed as the Acting High Representative for BiH," Jul 1, 2026. europeanwesternbalkans.com/2026/07/01/louis-j-crishock-appointed-as-the-acting-high-representative-for-bih
  9. Al Jazeera, "Bosnia appeals court upholds Bosnian Serb leader's sentence," Aug 1, 2025. aljazeera.com/news/2025/8/1/bosnia-appeals-court-upholds-bosnian-serb-leaders-sentence
  10. Al Jazeera, "Separatist Bosnian Serb leader Dodik removed from office," Aug 6, 2025. aljazeera.com/news/2025/8/6/separatist-bosnian-serb-leader-dodik-sacked-from-office-by-bosnia-officials
  11. European Western Balkans, "The Court of BiH replaces a prison sentence for Milorad Dodik with a fine," Aug 13, 2025. europeanwesternbalkans.com/2025/08/13/the-court-of-bih-replaces-a-prison-sentence-for-milorad-dodik-with-a-fine/
  12. CeSPI, "Dodik met Lavrov to strengthen partnership between Banja Luka and Moscow," Oct 28, 2025. cespi.it/en/node/3266
  13. U.S. Department of Justice, FARA filings on behalf of Republika Srpska: RRB Strategies, Registration No. 7562 (short form for Michael Flynn, Oct 12, 2025, $100,000 monthly fee: efile.fara.gov/docs/7562-Short-Form-20251012-1.pdf; supplemental statement May 12, 2026, $700,000 received Oct 29, 2025: efile.fara.gov/docs/7562-Supplemental-Statement-20260512-2.pdf); Continental Strategy (Feb 16, Mar 30 and Sep 30, 2026); McGinnis Lochridge.
  14. Borba, Dodik interview on learning of the sanctions decision in Moscow, Sep 28, 2026 (Serbian). borba.me/dodik-otkrio-da-je-bio-u-moskvi-kada-je-saznao-da-su-mu-amerikanci-ukinuli-sankcije-trebalo-je-naci-dobru-kafanu-srpsku-muziku-i-to-proslaviti
  15. Senate Foreign Relations Committee, "Senators Shaheen, Grassley, Wicker, Durbin, Tillis, Warren, Representatives Turner and Wagner Press Administration to Impose Sanctions on Milorad Dodik," Mar 27, 2026, citing Section 8335 of the FY2026 NDAA (P.L. 119-60). foreign.senate.gov/press/dem/release/senatorsshaheen-grassley-wicker-durbin-tillis-warren-representativesturnerand-wagnerpress-administration-to-impose-sanctions-on-milorad-dodik
  16. N1, "RS entity officials: Moscow visit confirms strong ties with Russia and calls for closure of OHR," May 11, 2026. n1info.ba/english/news/rs-entity-officials-moscow-visit-confirms-strong-ties-with-russia-and-calls-for-closure-of-ohr
  17. European Western Balkans, "Dodik meets Putin in Moscow," Sep 30, 2026. europeanwesternbalkans.com/2026/09/30/dodik-meets-putin-in-moscow-2
  18. Euronews, "Serb separatist politician Milorad Dodik thanks Trump, Putin as he declares victory in contested Bosnia vote," Oct 5, 2026. euronews.com/2026/10/05/serb-separatist-politician-milorad-dodik-thanks-trump-putin-as-he-declares-victory-in-cont
  19. RFE/RL Balkan Service, "U Kongresu SAD-a zabrinutost zbog ruskog i kineskog utjecaja na Zapadnom Balkanu," Sep 15, 2026 (Bosnian; on the testimony of Deputy Assistant Secretary of State Daniel Lawton). slobodnaevropa.org/a/saslusanje-kongres-balkan-lawton-sigurnost-sad-politika/33855933.html
  20. House Foreign Affairs Committee, Europe Subcommittee hearing, "U.S. Policy and Regional Security Challenges in the Western Balkans," Sep 15, 2026. foreignaffairs.house.gov/committee-activity/hearings/us-policy-and-regional-security-challenges-in-the-western-balkans
  21. Balkan Insight, "Bosnia court blocks Republika Srpska from funding secessionist lobbying," Sep 25, 2026. balkaninsight.com/2026/09/25/bosnia-court-blocks-republika-srpska-from-funding-secessionist-lobbying
  22. Al Jazeera, "What were Trump operatives doing for pro-Russian politician Dodik in Bosnia?," Oct 8, 2026. aljazeera.com/features/2026/10/8/what-were-trump-operatives-doing-for-pro-russian-politician-dodik-in-bosnia
  23. N1, "Bosnia's RS entity invigorates US lobbying with new €1.5m contract," Feb 26, 2026. n1info.ba/english/news/bosnias-rs-entity-invigorates-us-lobbying-with-new-15m-contract
  24. Semafor, "Trump-tied firm helped organize political advisers' Balkans travel," Oct 8, 2026. semafor.com/article/10/08/2026/trump-tied-firm-helped-organize-political-advisers-balkans-travel
  25. The New York Times, report on James Blair and Chris LaCivita in Republika Srpska, Oct 6, 2026. nytimes.com/2026/10/06/us/politics/trump-advisers-republika-srpska.html
  26. CBS News, "Photo shows top Trump aide's daughter with pro-Russia politician in Bosnia," Oct 8, 2026. cbsnews.com/news/russia-trump-susie-wiles-milorad-dodik-bosnia-serbia
  27. Politico, report on GOP reaction to the Blair and LaCivita trip, Oct 8, 2026. politico.com/news/2026/10/08/lacivita-blair-balkans-trump-01111482
  28. Donald J. Trump, post on Truth Social, Oct 7, 2026. truthsocial.com/@realDonaldTrump/posts/117400465758567373
  29. Senate Foreign Relations Committee, "Shaheen, Grassley, Risch, Colleagues Urge Secretary Rubio to Combat Western Balkans Leader's Secessionist, Destabilizing Actions," Mar 12, 2025. foreign.senate.gov/press/dem/release/shaheen-grassley-risch-colleagues-urge-secretary-rubio-to-combat-western-balkans-leaders-secessionist-destabilizing-actions
  30. RFE/RL Balkan Service, "Dodik nakon dolaska iz Moskve poručio da je RS strateški partner Rusije," Sep 30, 2026 (Bosnian). slobodnaevropa.org/a/dodik-rusija-rs/33867177.html
  31. UN Security Council Resolution 2795 (2025), renewing the authorization of EUFOR Althea for 12 months, adopted unanimously Oct 31, 2025. digitallibrary.un.org/record/4092088
  32. Western Balkans Democracy and Prosperity Act, P.L. 119-60, div. H, § 8335 (Dec 18, 2025), codified at 22 U.S.C. § 10704 (90-day requirement in subsection (a); waiver and notice to Congress in subsection (g)).
  33. U.S. Department of Justice, FARA Registration No. 6200, Exhibit A & B to Registration Statement for Dickens & Madson Canada Inc. on behalf of Republika Srpska, filed Oct 3, 2025. efile.fara.gov/docs/6200-exhibit-ab-20251003-23.pdf
  34. Vijesti, "The Republic of Srpska is lobbying the US for independence with millions." en.vijesti.me/world-a/balkan/819092/The-Republic-of-Srpska-is-lobbying-the-US-for-independence-with-millions
  35. U.S. Department of Justice, FARA Registration No. 7517, Registration Statement for Zell & Associates International Advocates, LLC on behalf of Republika Srpska, filed Jan 13, 2025. efile.fara.gov/docs/7517-Registration-Statement-20250113-1.pdf
JEDNA BiH • Legislative Issue Brief • October 2026