Montenegro’s amendments to its Law on the Prevention of Money Laundering and Terrorist Financing, in force since May 2026, prohibit individuals and businesses from making or receiving cash payments of 10,000 euros or more, including through linked transactions. The restriction covers payments, receipts and cash payouts, while payments of the same value through the banking system remain possible under the applicable rules.
The law applies to legal entities, companies, entrepreneurs and individuals. It prohibits them from receiving a payment, making a payment or paying out winnings in cash at or above the threshold. The amendments also cover loans, so parties cannot divide a loan of 10,000 euros or more into smaller cash handovers to avoid the restriction.
Transactions cannot be treated as separate simply because they are split into instalments. The prohibition also applies when two or more connected cash transactions add up to 10,000 euros or more. That means the relevant amount is the total of the linked payments, not the value of each individual handover.
For example, a buyer cannot pay 15,000 euros in cash as part of a 150,000-euro apartment purchase, even if the remaining 135,000 euros is paid through an account. Splitting the cash component into two connected payments of 7,500 euros would not make the arrangement permissible. The general cash restriction applies alongside, rather than instead of, the rules specific to property transactions.
The same principle applies to other purchases and private loans. A used car bought from another individual for 18,000 euros cannot be paid for entirely in cash, nor can the buyer divide the amount into two connected cash payments of 9,000 euros. A person also cannot hand a friend or family member a 12,000-euro loan in cash, or split it into two connected handovers of 6,000 euros each.
For a car or another purchase worth 15,000 euros, neither two cash payments of 7,500 euros nor three cash instalments of 5,000 euros avoid the ban. The law treats linked transactions as covered when their combined amount reaches the threshold. The restriction is on cash dealings, however, and does not prohibit all transactions worth 10,000 euros or more.
Those larger transactions can be carried out through the banking system, subject to the rules applying to the parties and the transaction. For property purchases priced at 10,000 euros or more, at least one participant in the legal transaction must make a payment to or from a transaction account held at a credit institution in Montenegro. That is an additional requirement and does not exempt a property deal from the general cash-payment limit.
Property payments and bank checks
The property rules also require notaries to reject the preparation or certification of a notarial instrument that would enable parties to avoid using the national payment system. If payment under a sale agreement, preliminary agreement or another transaction acquiring or transferring property rights has already been made before certification, the notary must obtain proof that the payment was completed.
A participant’s statement that the property transaction has been completed is not, by itself, proof of payment. The rule therefore distinguishes between a declaration by the parties and evidence that the relevant payment was carried out. For property transactions covered by the requirement, the relevant account must be held at a credit institution in Montenegro.
Bank transfers may also lead to requests for documents explaining the purpose of a payment. A person who transfers 15,000 euros from their account to a property seller could be asked by their bank to provide the sale agreement or another document explaining the transfer. Banks are obliged to monitor client activity under the law and must collect and record information about the purpose, aim and nature of business relationships and transactions.
Banks must assess whether a transaction is consistent with a customer’s profile and the usual scale and type of that customer’s business. Depending on its assessment of risk, a bank may ask for a sale agreement, preliminary agreement, loan agreement or other material showing the transaction’s economic purpose. It may also request further evidence about the source of the funds.
The documents address different questions. A sale agreement can explain why money was transferred, while evidence about the source of funds can show how the customer obtained the money used for payment. The law does not require a bank automatically to request a sale agreement for every transfer of 15,000 euros; its response depends on the transaction, information it holds about the customer and its risk assessment.
The cash-payment restriction does not prevent an individual from depositing 10,000 or 20,000 euros in cash into their own account. The law provides an exception for depositing funds with credit institutions and other payment service providers. That exception concerns depositing cash, not making a cash payment to another party that would otherwise fall under the ban.
A cash deposit does not remove the bank’s obligations to check the customer and monitor transactions. The bank may seek information or documents about the source of the money, and it is not required to accept a deposit without carrying out checks. The amount being deposited is therefore distinct from a cash payment between parties, but the bank’s customer-monitoring requirements still apply.
Fines for individuals
Individuals who receive or make a cash payment of 10,000 euros or more can face a fine of 1,000 to 8,000 euros. The penalty provision also covers payment through two or more connected cash transactions whose combined value reaches the threshold. Splitting a prohibited payment into smaller amounts does not remove the potential penalty when the payments are linked.
The law’s controls therefore operate at several points in a transaction: the cash threshold applies to individuals and businesses, property transactions carry an additional national-payment-system requirement, and banks monitor the purpose and consistency of activity on customer accounts. For property deals where payment precedes notarisation, the notary must obtain evidence that the payment took place; a statement from the participants alone does not meet that requirement.
