-      Samir Keserović, born on 12 November 1984 in Velika Kladuša, where he also resides, with prior convictions, a citizen of Bosnia and Herzegovina, and

-      Elvis Muratović aka Elko, born on 17 September 1987 in Varoška Rijeka, resident of the Municipality of Bužim, with prior convictions, a citizen of Bosnia and Herzegovina.

These accused persons are charged with acting jointly in a sequence of mutually agreed and interconnected actions, as members of a group for organized crime established for the purpose of acquiring illegal material gain, from November 2010 to January 2011, and with smuggling a larger number of persons, mostly citizens of the Republic of Turkey, from Bosnia and Herzegovina to the Republic of Croatia, Republic of Slovenia and further to the countries of the European Union, which is in violation of the current legal regulations in Bosnia and Herzegovina and contrary to the United Nations Convention against Transnational Organized Crime, Protocol against the Smuggling of Migrants by Land, Sea and Air and Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children.

The accused Samir Keserović and Elvis Muratović are suspected of becoming members of the group for organized crime for the purpose of acquiring illegal material gain, which group committed or attempted to commit the criminal offense by joint action, by transporting across the state border persons who do not meet the requirements for a legal entry across the state border, or enabling others to cross the state border illegally, out of personal gain, whereby they committed the criminal offense of Organized Crime, as referred to in Article 250, Paragraph 4, of the Criminal Code of Bosnia and Herzegovina, in conjunction with the criminal offense of Smuggling of Persons, as referred to in Article 189, Paragraph 1 of the Criminal Code of Bosnia and Herzegovina.