Key Documents

Montenegro Redevelops Law on the Prevention of Money Laundering and Terrorist Financing

December 21, 2007

Montenegro Publishes Amended Banking Law

July 16, 2010

Montenegrin Government Issues National Payment Systems Law

October 13, 2008

Important Facts

The U.S. State Department identifies Montenegro as a major money laundering jurisdiction. The country continues to improve its capacity to prevent and address money laundering and organized crime. However, a number of factors inhibit the fight against money laundering, including corruption, insufficient capacity to conduct financial investigations, a weak collaboration between government agencies and a judicial system susceptible to political influence. Sophisticated international narcotics trafficking enterprises and other criminal organizations have a presence in Montenegro. Criminal groups in the jurisdiction use its ports to unload illicit cargo and traffic stolen cars, narcotics, cigarettes and counterfeit products. The proceeds of narcotics trafficking, tax evasion, internet fraud and other illegal activities are often laundered through Montenegro's construction and real estate industries. Local criminals launder money by depositing illicit proceeds into offshore financial institutions and then reclaiming the funds in the form of loans, which they never repay. Most illicit proceeds come from Russia, Estonia, Switzerland, Cyprus and the British Virgin Islands. The absence of a non-conviction-based asset forfeiture law, weak financial crimes enforcement, lack of monetary controls over currency usage and the use of cash in many commercial transactions also contribute to and increase Montenegro's vulnerability to money laundering. Emerging information technology, cyber currencies and other payment methods have made it harder for Montenegro to detect potential money laundering and terrorist financing.
KYC Covered Entities: Banks, savings banks, savings and loan institutions, and loan brokers and intermediaries; post offices and organizations performing payment, e-money, or credit card transactions; stock brokers, securities depositories, and investment and pension fund managers; insurance brokers, intermediaries, and companies dealing with life insurance; company formation, marketing, consulting, fiduciary, and management service providers; organizers of lotteries and special games of chance; exchange offices; pawnshops; audit companies, independent auditors, accountants, and tax advice services; humanitarian, nongovernmental, religious, and other non-profit organizations; sellers and purchasers of claims; financial proxies; safekeeping, custodial, and guaranty firms; property managers; factoring, forfeiture, and financial leasing companies; sports organizations; catering and tourism service providers; real estate agents, investors, and intermediaries; construction companies; motor vehicle, vessel, and aircraft dealers; credit agencies; auctioneers and traders of works of secondary raw materials, art, high-value goods, and precious metals and stones
STR Covered Entities: Banks, savings banks, savings and loan institutions, and loan brokers and intermediaries; post offices and organizations performing payment, e-money, or credit card transactions; stock brokers, securities depositories, and investment and pension fund managers; insurance brokers, intermediaries, and companies dealing with life insurance; company formation, marketing, consulting, fiduciary, and management service providers; organizers of lotteries and special games of chance; exchange offices; pawnshops; audit companies, independent auditors, accountants, and tax advice services; humanitarian, nongovernmental, religious, and other non-profit organizations; sellers and purchasers of claims; financial proxies; safekeeping, custodial, and guaranty firms; property managers; factoring, forfeiture, and financial leasing companies; sports organizations; catering and tourism service providers; real estate agents, investors, and intermediaries; construction companies; motor vehicle, vessel, and aircraft dealers; credit agencies; auctioneers and traders of works of secondary raw materials, art, high-value goods, and precious metals and stones
Enhanced Due Diligence Procedures for PEPs: Foreign: Yes; Domestic: Yes
Money Laundering Criminal Prosecutions/Convictions: Prosecutions: 0 (2015); Convictions: 2 (2015)

Source: 2017 International Narcotics Control Strategy Report (INCSR)

Rankings

FATF i | 2013 Methodology

Technical	Effectiveness
Compliant : 2	High : 0
Largely Compliant : 19	Substantial : 2
Partially Compliant : 18	Moderate : 9
Non-Compliant : 1	Low : 0

BASEL i

Rank : 126/141

Score : 3.75/10

TRANSPARENCY INTERNATIONAL i

Rank : 67/179

Score : 45/100

Tax Justice Network i

Rank : 119/133

Score : 60/100

Montenegro

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