Only hours ahead of a Sept. 15 House subcommittee hearing on the direction of U.S. policy in the Western Balkans, the office of U.S. Rep. William R. Keating released a report on behalf of a group of Democrats on the House Foreign Affairs Committee entitled “Pay for Play in the Balkans: How the Trump Administration’s Bosnia Policy Enriches the President’s Personal Allies and Shortchanges the American People.” It focuses on the Trump administration’s contentious recent interventions in Bosnia and Herzegovina.
The report’s central allegations are that the administration has made “two corrupt decisions that have netted more than $1 billion for President Trump’s political allies, undermined Bosnia’s path to European integration, and threatened the stability of the entire region.” The deal at issue involves recognizable names in the United States – Trump-pardoned convicted felons Michael Flynn and Rod Blagojevich – as well as a Trump campaign lawyer and a gas pipeline.
The report comes less than a month ahead of Bosnia and Herzegovina’s next general elections on Oct. 4, and less than two months ahead of the U.S. midterms. In Bosnia, its contents will provide fodder for opponents of separatist Bosnian Serb leader Milorad Dodik, including ethnic Serbs who hope to end his party’s 20-year dominion over the majority-Serb “entity,” Republika Srpska (the RS), created under the 1995 Dayton Peace Agreement that ended a war that killed more than 100,000 people. In the United States, should Democrats regain control of the House, the report could serve as the foundation for a probe into the administration’s melding of foreign policy and business.
The Keating report is a complex read, fitting for a country like Bosnia, which is often said to have the most convoluted constitutional regime in the world. But its chief thesis is about U.S. national security interests. It alleges “U.S. government resources are being wasted in Bosnia and Herzegovina” to “enrich a lucky few within the President’s inner circle,” and that “President Trump and his cronies are upending…30 years of U.S. policy towards the region,” and that the president “has rewarded his affiliates with taxpayer-funded settlements and support.”
Specifically, the report asserts that when the Trump administration “removed longstanding bipartisan sanctions from Bosnian Serb leader Milorad Dodik, his family, and his friends” in October 2025, it did so at the behest of MAGA-aligned lobbyists, including Flynn and Blagojevich, both convicted felons who were pardoned by Trump. The United States at the time defended the lifting of sanctions as a reward for Dodik’s governing SNSD party withdrawing an omnibus secessionist law in the RS entity assembly – even though the same law had already been struck down by the Bosnian courts.
But in the aftermath, the administration allegedly “concurrently facilitated the awarding of a concession worth over $1 billion for Bosnia’s politically sensitive Southern Interconnection Gas Pipeline (SIC) to a company [AAFS Ltd.] with no regional or sectoral experience,” according to the Keating report. Though the company apparently lacked relevant experience, it does have connections: it is operated by direct associates of both Dodik and Trump – namely, Joseph Flynn, who is Michael Flynn’s brother and a 2020 election denier, and Jesse Binnall, a Trump campaign lawyer who was also the lead attorney for Michael Flynn’s $1.25 million settlement earlier this year with the Trump Justice Department.
Ousting an Overseer
The report goes on to note that, following the lifting of sanctions on Dodik and the most senior members of his longtime Russian-backed secessionist regime in the RS, U.S. officials reportedly engineered the ouster of the country’s internationally appointed high representative, Christian Schmidt. Dodik held Schmidt responsible for his removal from office by the Court of Bosnia and Herzegovina in 2025, after the former German Minister had imposed legislation criminalizing defiance of the country’s courts and the decisions of the Office of the High Representative. The office acts as a supervisory body created by the 1995 U.S.-brokered Dayton Peace Agreement that ended the war in Bosnia and is charged with overseeing the terms of the accord. The 55-country Peace Implementation Council that appoints the high representative has repeatedly extended the term of the Office, largely as a counter to persistent secessionist pressure from Banja Luka.
Schmidt’s ejection, Keating’s analysis asserts, had two purposes. First, Dodik publicly embraced the SIC project, while the U.S. Embassy in Sarajevo improperly pushed authorities in the country’s other entity created by the peace accords, the majority Bosniak-Croat Federation, to directly write AAFS into the relevant legislation authorizing the pipeline’s construction. The legislation passed in the Federation entity assembly in record time, with the support of Dodik’s allies in the Croat nationalist political party HDZ, who had long obstructed previous iterations of the legislation when it still reserved the core concession to the local public utility, BH Gas.
The second purpose of jettisoning Schmidt, Keating’s report states, is that the newly appointed high representative would have as his primary assignment by the United States the imposition of a new state property regime, which would not only allow for the construction of the SIC, but also allow the Dodik government to sell off huge swathes of public lands in the RS entity. The implication of the report is that the Flynn and Trump families, including the president’s son Don Jr., Binnall, and other political allies, would directly profit from the construction of this pipeline and the eventual sale of Bosnian public lands. And once that was all signed, the OHR would close, leaving the Bosnian state bereft of key competencies, more susceptible than ever before to renewed Serb secessionist adventurism, and thus undermining regional peace and stability.
As reported elsewhere, it is that prospect of a rapid closure of the OHR without substantive rationalizing reforms to the country’s governance regime that has especially alarmed the European allies and convinced them to block the U.S. push for a new high representative. For Brussels and other European capitals, the Trump administration’s dramatic reset of relations with one of the most militant leaders on the continent, combined with its apparent drive to defang one of the last tools available to the international community to deal with Dodik’s persistent brinkmanship, was a threat to their own security interests.
In sum, the United States succeeded in pushing Schmidt out, but it has not been able to secure his replacement. Successive American-imposed deadlines have passed, and the Europeans are no closer to acquiescing to the appointment of Antonio Zanardi Landi, an Italian diplomat backed by Washington, and who Keating’s report suggests would be inclined to “do Dodik’s bidding.”
Rare Bipartisan Push in Congress
Keating, a 15-year congressional veteran, is hardly alone in raising concerns about U.S. policy in Bosnia. Both Democrats and multiple Republicans have repeatedly raised questions about the White House’s decision to lift sanctions on Dodik and his associates. And in recent days, spurred by the state-sponsored funeral of the genocidaire Mladic in neighboring Serbia’s capital Belgrade, the bipartisan U.S. Helsinki Commission has explicitly called on “the Administration to fully implement existing U.S. sanctions authorities, including by restoring or imposing targeted sanctions against individuals whose actions threaten Bosnia and Herzegovina’s peace and stability.”
For the White House, the prospect of a congressional investigation should Democrats return to power on Capitol Hill may be uncomfortably similar to the circumstances that led to Trump’s first impeachment in 2019, in which the president’s effort to pressure the government of Ukraine to raise charges against his then-political rival Joe Biden resulted in a nearly two-month long trial in the U.S. House. To be sure, Democrats leading Congress will have plenty of grist for the mill, and this may not alone rise to the top.
But should the administration find itself consumed by such an investigation, it would be the result of an unforced error. No U.S. national security interest was ever advanced by providing a political extremist like Milorad Dodik with sanctions relief. And while even Keating’s report concurs that advancing U.S. business interests in the region is a desirable goal, doing so via what is in effect a shell company was always going to result in political blowback.
