Crypto asset service providers must now register before operating, though transitional provisions are absent, creating uncertainty until the Register of Crypto Asset Service Providers is established within nine months. Gambling operators face lowered due diligence thresholds, requiring checks on deposits of €20 or more, down from €2,000.
Enhanced client identification allows video-electronic verification and cross-referencing with databases for accuracy. Beneficial owners are redefined to include those exerting control “by other means,” such as voting rights or informal agreements. Fines for non-compliance rise significantly, with penalties up to €40,000 for financial institutions and new misdemeanor provisions for delayed reporting.
The amendments aim to align Montenegro with international standards, improving financial transparency and accountability. However, critics note crypto regulations should have been addressed via standalone legislation.
In this article, authors Lana Vukmirović Mišić, Senior Partner, and Mina Čogurić, Associate from JPM Podgorica office, highlight these changes as pivotal steps toward robust AML/CFT frameworks, despite unresolved gaps in transitional crypto rules.
