Public Trust Tracker

INV-050 · Money & ethics · Government deals

Dodik sanctions lifted and a Trump-ally firm's Bosnia pipeline deal

Stage 2 of 5: Inquiry · Letters and records requests · Last development 16 Oct 2026

In October 2025 the Treasury removed U.S. sanctions on Bosnian Serb leader Milorad Dodik, his two adult children and dozens of associates. A month later AAFS Infrastructure and Energy, a new company set up by Joseph Flynn (Michael Flynn's brother) and Trump-affiliated lawyer Jesse Binnall, was formed, and with U.S. embassy support it was written into Bosnian law as the investor for a pipeline concession the House Foreign Affairs minority values at over $1 billion. Democrats say the two decisions rewarded Trump allies. Separately, Trump-connected lobbying firms are paid by the Republika Srpska government; one of them, Continental Strategy, employs the daughter of White House Chief of Staff Susie Wiles, who met a senior Srpska official at the White House in September.

The 'pay for play' link is the House Foreign Affairs minority's conclusion, not an official finding. The administration says the sanctions were lifted to prevent instability in the Balkans. The White House and Continental Strategy say Katie Wiles did not lobby the U.S. government on Srpska and played no role in her mother's meeting; no evidence has been published that Susie Wiles acted for the firm.

Marco RubioScott Bessent
People
Milorad Dodik, Joseph Flynn, Jesse Binnall, Michael Flynn, Susie Wiles, Continental Strategy, Marco Rubio, Scott Bessent, Chris LaCivita, James Blair
Agencies
Treasury Dept (OFAC), State Dept, White House
Reviewed by
House Foreign Affairs (minority), Rep. Dina Titus and other House members

Money involved

  • $1 billion Bosnian pipeline concession awarded to the new firm ("over $1 billion", House Foreign Affairs minority estimate of its value, not money paid) (Other amounts, not totaled, estimate) [1]
  • $100,000 Michael Flynn's fee for one month of lobbying for Republika Srpska (FARA, per the minority report) (Other amounts, not totaled) [1]
  • $35,000 Continental Strategy's monthly fee from Republika Srpska (per DOJ filings cited by the NYT) (Other amounts, not totaled) [5]

Timeline

  1. Members of Congress, in a letter shared by Rep. Dina Titus, ask the President whether the White House, State Department or US embassy knew of or guided paid election work in Republika Srpska by Trump advisers James Blair and Chris LaCivita, and whether Susie Wiles' daughter helped arrange Wiles' September meeting with Cvijanović. Answers are due 23 October. [7]

  2. The NYT reports the executive on Katie Wiles' trip was John V. Calce, whose America First Refining is partly owned by Donald Trump Jr., and that Continental arranged the visit at the Srpska government's request. [5]

  3. After a New York Times report that Trump advisers Chris LaCivita and James Blair advised Republika Srpska's government on its elections, Trump says he will ask them about their other clients. [8]

  4. Susie Wiles meets Željka Cvijanović, a Dodik ally on Bosnia's presidency, at the White House; a White House official says Continental partner Alex Garcia set it up. [4]

  5. House Foreign Affairs Europe subcommittee Democrats publish 'Pay for Play in the Balkans', calling for subpoenas, reimposed sanctions and a pause in U.S. support for AAFS. [1]

  6. Katie Wiles, a Continental Strategy partner, visits Republika Srpska with a U.S. energy executive exploring a pipeline deal; a photo shows her with interior minister Željko Budimir. [4]

  7. AAFS is named in Federation of Bosnia and Herzegovina legislation as the pipeline's investor. Keating writes privately to Rubio about the award; State replies. [1]

  8. Continental Strategy registers under FARA to represent the Republika Srpska government ($35,000 a month, per DOJ filings cited by the NYT). [3]

  9. Joseph Flynn and Jesse Binnall register AAFS in Wyoming, four days after U.S. embassy officials discussed an American company taking over the Southern Interconnection pipeline. [1]

  10. Reps. Keating and Meeks write to Rubio and Bessent opposing the delisting and asking what changed in Dodik's behavior. [1]

  11. Treasury's OFAC removes Dodik, his children Igor and Gorica, and dozens of affiliates from the sanctions list, after removing four affiliates on 17 Oct. [2]

  12. Michael Flynn reports in a FARA filing that he was paid $100,000 for one month of lobbying for the Republika Srpska government (per the House Foreign Affairs minority report). [1]

Responses

  • White House: An administration official said the sanctions were lifted to prevent instability in the Balkans; a White House official said Susie Wiles does not discuss work matters with her daughters. [4]
  • Continental Strategy: Said Katie Wiles has not spoken with any U.S. government official about Srpska, that Alex Garcia alone handles U.S. government contacts and reports them under FARA, and that the firm meets every ethical and legal requirement. [4]
  • Donald Trump (Truth Social, 7 Oct 2026): Said LaCivita and Blair "do not work for me, other than as outside consultants" and "if there's a conflict, I will terminate them, immediately!" [8]
  • Caroline Wren, registered lobbyist for Republika Srpska: Said the two were on the ground about 36 hours and that the entity's interest is closer ties with the Trump administration, not Russia; LaCivita and Blair did not comment directly. [8]

Who is acting on it

  • Letter Rep. Bill Keating (D-MA), Rep. Gregory Meeks (D-NY): Asked Rubio and Bessent what changed in Dodik's behavior to justify lifting sanctions (12 Nov 2025, No reply or result recorded yet)
  • Letter Rep. Bill Keating (D-MA): Wrote privately to Rubio about the pipeline award (Apr 2026, What happened next)
  • Report House Foreign Affairs Democrats: "Pay for Play in the Balkans" report calling for subpoenas, reimposed sanctions and a pause in U.S. support for the firm (15 Sep 2026, Published)
  • Letter Rep. Dina Titus (D-NV): Letter from members of Congress (shared by Titus; other signers not named) asking Trump whether the White House, State Department or embassy guided Blair and LaCivita's paid election work in Republika Srpska (16 Oct 2026, No reply or result recorded yet)

Sources

  1. House Foreign Affairs Committee minority, 'Pay for Play in the Balkans', 15 Sep 2026
  2. Treasury OFAC, Balkans-related designation removals, 29 Oct 2025
  3. DOJ FARA eFile, Continental Strategy LLC (reg. 7545), foreign principals
  4. CBS News, 8 Oct 2026
  5. New York Times, 15 Oct 2026 (paywalled; via Raw Story)
  6. Raw Story, 15 Oct 2026
  7. N1 Sarajevo, 18 Oct 2026
  8. Axios, 7 Oct 2026

Cite this case

Public Trust Tracker. "Dodik sanctions lifted and a Trump-ally firm's Bosnia pipeline deal" (INV-050). Last updated 16 Oct 2026. https://publictrusttracker.org/case/inv-050-dodik-sanctions-lifted-and-a-trump-ally-firms-bosnia/

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