OFAC publishes Western Balkans Stabilization Regulations general licenses 3A, 4, and 5 (humanitarian, wind-down, Kaldera water-pump carve-outs)

Mechanism

OFAC administers the Western Balkans Stabilization Regulations under authorities ultimately deriving from Executive Order 14033 (2021), codified at 31 CFR Part 588. The three general licenses formalised in this Federal Register notice were operationally available on OFAC's website from 18 June 2024 — the date of OFAC's tranche of new Balkans-related SDN designations targeting persons in the network supporting Republika Srpska President Milorad Dodik. The 23 October 2024 publication brings the GLs into the formal regulatory record.

• **GL 3A (Authorizing the Exportation or Reexportation of Agricultural

Commodities, Medicine, Medical Devices, Replacement Parts and Components, Software Updates, or Services for Medical Prevention, Diagnosis, Treatment, or Clinical Trials).** Supersedes GL 3 of 16 November 2023. Standard OFAC-modal humanitarian-trade GL — aligns the WBSR humanitarian carve-out with the post-2022 General Counsel template now used across counter-terrorism, Russia, DPRK, Venezuela, Syria/PAARSS, and other programs.

• GL 4 (Wind-Down). Authorises U.S. persons to engage in

transactions ordinarily incident and necessary to the wind down of pre-existing dealings with entities blocked under WBSR on 18 June 2024, through a specified cut-off date. Standard new- designation operational easement.

• GL 5 (Kaldera water-pump carve-out). Functional carve-out

preserving water-infrastructure continuity: authorises transactions ordinarily incident and necessary to the manufacture, distribution, operation, installation, or maintenance and repair of pumps manufactured or distributed by the WBSR-blocked Bosnian Serb entity Kaldera Company EL PGP d.o.o. (and any entity it owns ≥50%, directly or indirectly), that are currently or are intended solely for use in the treatment or distribution of drinking water. Does NOT authorise any transactions otherwise prohibited by the WBSR involving other blocked persons (e.g., Dodik-network designees) unless separately licensed. GL 5 was subsequently updated to GL 5A on 6 November 2024, filed via the 6 December 2024 Federal Register notice (FR Doc 2024-28470, separate filing).

Downstream implications

• Bosnia-Herzegovina / Republika Srpska compliance posture.

GLs 3A and 4 are the standard humanitarian + wind-down twin used to insulate municipal-level humanitarian flows and pre-existing commercial counterparties from the secondary-effects shock of sanctioning a politically-connected industrial conglomerate.

• Water-utility risk pattern. GL 5 is the unusual GL here — it is a

named-entity functional carve-out for a single Bosnian Serb industrial group, narrowly scoped to drinking-water-pump manufacture/maintenance. Pattern resembles OFAC's prior named-entity carve-outs (e.g., the August 2024 GL for certain Belarus-program potash-trade activities). Signals OFAC has accepted that fully blocking Kaldera would risk water-supply disruption in Republika Srpska municipalities — a humanitarian-spillover risk the agency is policing through narrow functional authorisations rather than delisting.

• Compliance-program update burden. Financial institutions and

exporters with Bosnia/Western-Balkans exposure must update screening workflows to apply GL 3A to humanitarian flows, GL 4 to wind-down transactions through the cutoff, and GL 5 to drinking-water-pump transactions involving Kaldera and its ≥50%-owned affiliates.

Open questions

• Whether GL 4 has expired or has been extended (Federal Register

publication does not amend the underlying GL text and effective dates set on 18 June 2024).

• Whether OFAC will issue additional functional carve-outs as the

Dodik-network designations age (analogous pattern observed in the Belarus and Russia programs where named-entity GLs proliferate over ~12–24 months as supply-chain frictions surface).

• Whether the GL 5 / GL 5A scope captures spare-parts and software

updates from non-U.S. OEM suppliers whose products are integrated into Kaldera-distributed pump systems.