Montenegro is entering the final phase of establishing a registry for service providers linked to crypto assets, even as the country still lacks a dedicated crypto law. While institutions are working to build a robust system, the domestic cryptocurrency market continues to operate in a partially unregulated, grey space.
Željko Drinčić, President of the Capital Market Commission, explained that under recent amendments to the Law on Prevention of Money Laundering and Terrorist Financing, the Commission has been designated as the authority responsible for creating and managing the crypto service providers registry.
“The process is in its final stages, including staff training, capacity building, hiring additional oversight personnel, and ensuring adequate IT support to monitor these entities. The registry is expected to go live by mid-December,” Drinčić said.
The Commission has been granted new powers, including inspection rights, while legal provisions outline sanctions for non-compliance.
A working group involving the Ministry of Finance, the Central Bank, and the Capital Market Commission has recently started drafting a dedicated crypto law, with UNDP experts assisting in aligning the legislation with international standards. However, the law is not yet on the government’s agenda for 2025.
The Central Bank continues to emphasize that cryptocurrencies are not legal tender, and there are no plans for this to change in the near future. Consequently, Montenegro has a limited legal framework—mainly focused on anti-money laundering and counter-terrorism measures—but lacks comprehensive regulation covering the full spectrum of crypto activity, including token issuance, payments, and provider oversight.
Despite regulatory gaps, crypto activity is already present in Montenegro. Interest in paying for real estate with crypto is growing, local exchanges are emerging, and cases of crypto mining equipment imports and ATM installations have been reported. Regulators warn that the absence of rules increases the risk of misuse. Harmonizing with EU standards such as MiCA (Markets in Crypto-Assets) remains a major challenge. The 2023 arrest of Hjeong Do Kwon in Podgorica highlighted vulnerabilities in the system that can attract illicit activity.
Dušan Drakić, Director of the Anti-Corruption Agency, noted that the new Anti-Corruption Law now explicitly includes digital assets within public officials’ asset declarations. Officials must report the type, quantity, and market value of digital assets, including cryptocurrencies, ensuring transparency. Only transactions affecting asset holdings, such as sales or purchases, require updates. Drakić emphasized that monitoring digital assets globally is challenging due to the lack of centralized data, but the Agency is enhancing international cooperation and developing tools for effective oversight.
Montenegro’s crypto market remains in a transitional phase—caught between regulatory uncertainty and efforts to establish a clear legal framework. For those operating in the sector, staying abreast of legislative developments and assessing risks carefully is crucial. With proper regulation, Montenegro has the potential to emerge as a regional hub in digital finance—but for now, legal certainty is still a work in progress.
