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Montenegro Country Summary

Medium-High Risk

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Sanctions

Higher Concern

FATF AML Deficient List

Lower Concern

Terrorism

Medium Concern

Corruption

Medium Concern

US State ML Assessment

Medium Concern

Criminal Markets (GI Index)

Medium Concern

EU Tax Blacklist

Medium Concern

Offshore Finance Center

Lower Concern

Please note that although the below Summary will give a general outline of the AML risks associated with the jurisdiction, if you are a Regulated entity then you may need to demonstrate that your Jurisdictional AML risk assessment has included a full assessment of the risk elements that have been identified as underpinning overall Country AML risk. To satisfy these requirements, we would recommend that you use our Subscription area.

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Anti Money Laundering

FATF Status

Montenegro is not on the FATF List of Countries that have been identified as having strategic AML deficiencies

Compliance with FATF Recommendations

The last Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Montenegro was undertaken in 2025. According to that Evaluation, Montenegro was deemed Compliant for 2 and Largely Compliant for 31 of the FATF 40 Recommendations. It was deemed Highly Effective for 0 and Substantially Effective for 2 with regard to the areas of Effectiveness of its AML/CFT Regime.

Sanctions

Several jurisdictions have imposed targeted sanctions on Montenegro-related individuals and entities rather than sanctioning Montenegro as a state; notable examples include Miodrag "Daka" Davidovic for money laundering and corruption, Branislav "Brano" Micunovic for organized crime, and Sergey Kokorev and his company International Business Corporation Bar for sanctions evasion related to Russia. There are no comprehensive country-wide sanctions against Montenegro by the UN, EU, UK, or other major powers; instead, remaining restrictions are limited to legacy claims from the 1990s Yugoslav conflicts and targeted sanctions on specific individuals, with several jurisdictions having lifted country-level measures.

Criminality

Rating

0 (bad) - 100 (good)
Transparency International Corruption Index 46
World Bank: Control of Corruption Percentile Rank 52

Montenegro faces significant challenges related to corruption and crime, with pervasive issues affecting both the public and private sectors. Despite recent efforts to combat corruption, including the establishment of a National Council for the Fight against Corruption and the adoption of new anti-corruption laws, the effectiveness of these measures is hampered by political instability, limited resources, and a fragmented judicial system.

The country also serves as a transit point for various criminal activities, including human trafficking, arms trafficking, and drug smuggling, with organized crime groups exerting considerable influence. While there have been some improvements in law enforcement and judicial investigations, the overall resilience to crime remains weak due to corruption, lack of political will, and ineffective implementation of existing laws.

Economy

Montenegro's economy is characterized by a stable, liberal framework with full capital mobility and no restrictions on foreign ownership, positioning it as an attractive destination for investment, particularly in tourism, energy, and agriculture. The government is committed to EU accession by 2028, which drives ongoing reforms and has led to a notable reduction in public debt from 105% of GDP in 2020 to 61.3% in 2024, alongside a 3.2% economic growth rate. Despite these positive developments, challenges remain, including judicial inefficiencies and regulatory transparency, which necessitate that investors engage local advisors to navigate the complexities of the investment landscape effectively.

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