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Montenegro Country Summary

Sanctions

Limited EU and US restrictions

FATF AML Deficient List

No

Terrorism
Corruption
US State ML Assessment
Criminal Markets (GI Index)
EU Tax Blacklist
Offshore Finance Center

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 2023. According to that Evaluation, Montenegro was deemed Compliant for 2 and Largely Compliant for 19 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

Montenegro, as a United Nations member, is obligated to support UN sanctions aimed at maintaining international peace and security. The UN Security Council has established various sanctions regimes since 1966, which include economic sanctions, arms embargoes, and travel bans, with a focus on protecting the rights of those targeted by these measures.

As an EU candidate country, Montenegro aligns with EU sanctions, which include prohibitions related to contracts affected by UN measures. Recent expansions in sanctionable conduct in the Western Balkans include actions undermining democratic processes and serious human rights abuses, with specific prohibitions on US persons engaging with designated parties.

Bribery & Corruption

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

Corruption remains a significant issue in Montenegro, affecting both public and private sectors, with a corruption perceptions index of 46. Despite some progress in combating corruption, including the establishment of a National Council and ongoing high-level investigations, foreign investors still view corruption as a major obstacle. The regulatory environment is complex and inconsistently applied, particularly at the municipal level, leading to widespread bribery and a lack of effective integrity mechanisms.

Economy

Montenegro's economy is primarily driven by tourism, energy, and agriculture, with tourism contributing approximately 25% to GDP. The country is undergoing significant energy sector transformations aimed at increasing renewable energy reliance, while infrastructure development, including highway construction, is a government priority. Despite a decline in foreign direct investment in 2023, Montenegro has seen a GDP growth of 6%, aided by strong private consumption and a robust tourism season.

Montenegro's investment climate is characterized by a legal framework that encourages foreign direct investment (FDI), allowing foreign entities to own 100% of domestic companies and repatriate profits without restrictions. However, the country faces challenges such as a reliance on imports, a significant grey economy, and ongoing issues with corruption and the rule of law, which hinder the establishment of a fully liberal business environment. Despite these obstacles, Montenegro has made strides in simplifying business registration and improving transparency, aiming to attract more foreign investment, particularly in the tourism, energy, and agriculture sectors.

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  • Key Findings
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