EU sanctions misstep? A Belarus-registered holding evades restrictions through clone company

In December 2020, the European Union imposed sanctions on Dana Holdings, a Cypriot firm linked to the Karić family, a prominent Serbian business dynasty with close ties to Belarusian President Alexander Lukashenko. The sanctions, intended to target the Karić family’s construction empire in Belarus for its support of Lukashenko’s regime, were mistakenly applied to a decoy Belarusian company, allowing the real Dana Holdings to escape restrictions.

This error, detailed by EUalive’s partner, the Belarusian Investigative Center (BIC), with support from the Organized Crime and Corruption Reporting Project (OCCRP), highlights flaws in the EU’s sanctions enforcement and the Karić family’s adept manoeuvres to protect their assets.

Sanctions misdirected to a clone

The EU’s December 2020 sanctions list included “Dana Holdings/Dana Astra,” seemingly targeting both the Cyprus-based Dana Holdings, which controlled the Karić family’s Belarusian assets, and its Belarusian subsidiary, ZTAA Dana Astra, a major real estate developer. However, the sanctions list provided identifying details – address and taxpayer number – only for Dana Astra, omitting specifics for Dana Holdings. This oversight suggested that the European External Action Service (EEAS), responsible for drafting sanctions, may have conflated the two entities, a confusion possibly fuelled by real estate websites occasionally merging their names.

In March 2021, the EU attempted to correct this by listing Dana Holdings separately, but the entry referenced a Belarusian company, TAA Dana Holdings, which did not exist when the original sanctions were imposed on 17 December 2020. This entity was a renamed firm, TAA Torghozstroy, a construction materials company in Berazino, Belarus, owned by Mikhail Kazakevich, with no apparent Karić ties. On 8 February 2021, Dana Astra acquired Torghozstroy and rebranded it as TAA Dana Holdings, creating a clone of the Cypriot parent company. By 27 March 2021, the EU replaced the original Dana Holdings entry with this Belarusian clone, retroactively applying sanctions to a firm that was irrelevant at the time of the initial listing.

A 2024 Luxembourg court ruling clarified that the EU initially targeted the Cyprus-based Dana Holdings, rejecting Bogoljub Karić’s appeal to lift sanctions due to his ties to “Dana Holdings and its former subsidiary Dana Astra.” Yet, the sanctions were never enforced on the Cypriot entity, allowing it to continue operations. The UK similarly sanctioned the Belarusian clone, not the Cyprus-based Dana Holdings, further enabling the Karić family to evade restrictions.

Strategic asset protection

Anticipating sanctions, the Karić family took preemptive steps. In early December 2020, just before the EU sanctions, Dana Holdings sold its five Cypriot shell companies – Russelville Limited, Triworst Limited, Rodrick Limited, Elaiva Trading Limited, and Ozalco Holding Limited – to Enterprise Developments Holding, a UAE-based firm. This entity is likely a front, owned by Mostafa El-Tobgy, whose name closely resembles Mustafa Al Tobghi, a former Dana Holdings CEO and Karić family associate. The €700 million sale, vastly exceeding the €21,550 book value of the firms, bore hallmarks of money laundering, with funds classified as “other accounts receivable,” allowing Dana Holdings to extract significant cash.

Post-sanctions, Russelville Limited, one of these Cypriot firms, received €1.2 million in dividends from Belarusian subsidiaries in 2021, demonstrating continued profit flow despite sanctions. Successor companies in Belarus, such as TAA City View, TAA Capital Palace, and TAA Grand Atrium, took over operations like managing Dana Mall, remaining unsanctioned and owned via the same Cypriot shells now under UAE control.

In August 2021, the US sanctioned Dana Holdings and Nebojša Karić, Bogoljub’s son, but lifted these restrictions on August 21, 2025, after the Cypriot Dana Holdings entered liquidation on June 20, 2025. British barrister Alex Prezanti noted that a company’s liquidation often removes grounds for sanctions, explaining the delisting.

Implications of the mistake

The EU’s error in sanctioning a clone company allowed the Karić family to maintain their lucrative Belarusian operations, including the Minsk World project, unimpeded. This misstep underscores the need for precise identifying data in sanctions lists and raises questions about the EEAS’s due diligence. While US sanctions briefly targeted Dana Holdings, their lifting in 2025, combined with the EU’s ongoing failure to sanction the Cypriot entity, highlights a broader challenge in enforcing sanctions against sophisticated actors using offshore networks.

Background on the Karić Family

The Karić family, led by brothers Bogoljub and Dragomir, is a powerful Serbian business dynasty with extensive regional influence. Rising to prominence in the 1990s by supporting Slobodan Milošević’s regime, they built a construction and investment empire through Dana Holdings, founded in 2006. In Belarus, they became major real estate developers, overseeing projects like Minsk World, a 3-million-square-meter complex.

Their close ties to Lukashenko, including employing his daughter-in-law Liliya Lukashenko at Dana Astra (2014–2016) and receiving $1 billion in land grants and tax exemptions, fuelled their success. Bogoljub, a former Serbian presidential candidate, fled tax evasion charges in Serbia in 2006, finding refuge in Belarus, where he obtained citizenship in 2010. Dragomir serves as Belarus’s honorary consul in Belgrade. Despite EU and US sanctions in 2020–2021 for supporting Lukashenko, the family’s strategic use of Cypriot and UAE shell companies has allowed them to evade restrictions, continuing to profit from Belarusian ventures.

A longer original version of this article can be found here.

Caption: Belarusian President Alexander Lukashenko attends a meeting in an expanded composition of the Supreme Eurasian Economic Council within the framework of the Eurasian Economic Union summit in Minsk, Belarus, 27 June 2025. EPA/SERGEI BOBYLEV / SPUTNIK / KREMLIN POOL