Montenegro is currently operating without a dedicated financial police unit and lacks effective oversight regarding cryptocurrency activities, highlighting significant institutional deficiencies in its ability to combat financial crime and uphold anti-money-laundering regulations. Despite ongoing announcements and strategic initiatives, the necessary legal and organizational frameworks to address complex financial offenses, particularly those involving digital assets, have yet to be established.
Efforts to create a financial police force modeled after Italy’s Guardia di Finanza have not resulted in tangible legislative or operational developments. Although high-level discussions have taken place regarding collaboration with Italian financial authorities, Montenegro has not yet enacted laws that would provide a domestic financial police unit with clear investigative mandates and enforcement capabilities. While the concept of such a unit appears in government policy documents, there remains an absence of legal definitions outlining its authority, institutional procedures, or mechanisms for cooperation with prosecutors and other relevant agencies.
Simultaneously, the rapid increase in cryptocurrency usage—both legitimate and illicit—has outstripped Montenegro’s ability to effectively regulate this emerging sector. Amendments to the anti-money laundering legislation implemented in March 2025 have brought certain crypto asset activities under basic regulatory frameworks; however, there is still no comprehensive national legislation governing virtual assets or an official registry of licensed crypto service providers. This regulatory gap allows substantial portions of cryptocurrency trading and exchanges to occur in grey market conditions, frequently outside formal oversight or record-keeping practices.
The absence of formal regulation for cryptocurrencies poses practical challenges for law enforcement agencies. Authorities trained in blockchain analysis reportedly lack the means to seize or manage digital assets due to the absence of established protocols for accessing national crypto wallets, confiscating digital property, or incorporating these assets into criminal investigations. Consequently, investigators face limitations even when suspicious activities are identified, making it difficult to pursue significant international cases involving cryptocurrencies within Montenegro’s legal framework.
International assessments by research and law enforcement agencies have identified Montenegro as susceptible to the misuse of digital assets for money laundering and unlawful transfers. These evaluations suggest that criminal organizations exploit existing legal gaps to facilitate cross-border fund movements with minimal oversight. In particular, decentralized and pseudonymous cryptocurrency transactions conducted outside regulated exchanges enable rapid and challenging-to-trace transfers, complicating efforts to identify and disrupt illicit financial flows.
The Montenegrin authorities have prioritized the establishment of new supervisory structures, assigning the Capital Market Commission with the responsibility of organizing cryptocurrency oversight within a designated timeframe. The government has also indicated plans to finalize comprehensive legislation concerning virtual assets by 2026. However, until these reforms are realized and implemented, both the capabilities of financial police and regulatory supervision over digital currencies will remain constrained, leaving law enforcement agencies at a disadvantage in addressing sophisticated financial crimes and cyber-enabled offenses.
