Montenegro
Retail_Trading_Status
- Analysis ID
- #733
- Version
- Latest
- Created
- 2025-12-12 04:53
- Run
- 27230656...
- History
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- Workflow Stage
- Step 1
Executive Summary
Retail cryptocurrency trading is legal in Montenegro and has recently transitioned into a regulated framework through amendments to the Anti-Money Laundering (AML) law. Effective March 2025, these amendments require all Virtual Asset Service Providers (VASPs) to register with the Capital Market Authority (CMA) and comply with strict KYC/AML obligations. While a comprehensive 'Law on Digital Assets' aligned with the EU's MiCA regulation is still in the drafting phase, the current AML framework establishes a mandatory registration regime, moving the sector out of a legal gray area, although the official registry is only just becoming operational as of late 2025.
Key Pillars
Capital Market Authority (CMA) designated as the primary supervisor for the crypto sector.
Mandatory registration for all Crypto Asset Service Providers (CASPs/VASPs) operating in the country.
Strict AML/KYC requirements for transactions, with specific thresholds (e.g., €1,000) triggering enhanced due diligence.
Oversight by the Financial Intelligence Unit (FIU) regarding suspicious transactions.
Landmark Laws
Law on Prevention of Money Laundering and Terrorist Financing (Amendments) (Official Gazette of Montenegro No. 2025/XX) - Enacted: 2025-02-28
- Introduced the first formal definition of crypto assets and established a mandatory registration regime for service providers. Designated the Capital Market Authority as the supervisor and imposed KYC obligations on crypto transactions.
- Source
Law on Digital Assets (Draft) (Draft / Proposed)
- A comprehensive bill currently under development, intended to fully align Montenegro's framework with the EU Markets in Crypto-Assets (MiCA) regulation. It will cover token issuance, stablecoins, and broader consumer protections once enacted.
Considerations
Implementation Lag: While the law requires registration, the actual registry was reported to be launching in mid-December 2025, creating a temporary operational gap.
Taxation: There is no specific capital gains tax for individual crypto holdings; however, a 9% corporate tax applies to businesses.
Banking Access: Banks are permitted to process crypto-related transactions but often exercise high caution; OTC trading remains common.
Gray Market Risks: Regulators explicitly warn that unregistered 'street' or Telegram-based exchanges are illegal and unsupervised.
Notes
The 'Allowed-Regulated' status is assigned based on the enacted legislation requiring registration. However, the practical environment is still maturing, and the 'Law on Digital Assets' is expected to replace or significantly expand the current AML-focused regime in 2026.
Remaining Uncertainties
- Has the VASP registry officially gone live as of today (Dec 12, 2025), or is it delayed further?
- When will the comprehensive 'Law on Digital Assets' be presented to Parliament?
- Are there any entities that have successfully completed the registration process yet?
Detailed Explanation
Detailed Explanation
Retail cryptocurrency trading is legal and regulated in Montenegro. The country's regulatory framework for crypto assets has recently transitioned from a legal gray area into a formal, regulated environment through amendments to its Anti-Money Laundering (AML) law, which took effect in March 2025. These amendments, formally the Law on Prevention of Money Laundering and Terrorist Financing (Official Gazette of Montenegro No. 2025/XX), enacted on 2025-02-28, introduced the first formal definition of crypto assets and established a mandatory registration regime for all Virtual Asset Service Providers (VASPs), also referred to as Crypto Asset Service Providers (CASPs). The Capital Market Authority (CMA) has been designated as the primary supervisor for the sector, overseeing this registration process. Concurrently, the Financial Intelligence Unit (FIU) maintains oversight of suspicious transactions. All service providers must comply with strict KYC/AML obligations, with specific transaction thresholds, such as €1,000, triggering enhanced due diligence. While this AML-based framework provides the current legal foundation, a more comprehensive 'Law on Digital Assets' is in the drafting phase and is intended to fully align Montenegro's regulations with the EU's Markets in Crypto-Assets (MiCA) regulation, covering token issuance, stablecoins, and broader consumer protections once enacted, likely in 2026.
Despite the enacted law, there has been an implementation lag in practice. The mandatory registration requirement was active from March 2025, but the official registry for VASPs was only reported to be launching in mid-December 2025, creating a temporary operational gap. Regulators explicitly warn that unregistered 'street' or Telegram-based exchanges are illegal and unsupervised, highlighting the risks in the gray market. For taxation, there is no specific capital gains tax for individual crypto holdings; however, businesses operating in the sector are subject to a standard 9% corporate tax. Banking access for crypto-related transactions is permitted, but financial institutions often exercise high caution, which has contributed to the continued prevalence of over-the-counter (OTC) trading. The country's status as 'Allowed-Regulated' is therefore based on the enacted legislation, though the practical environment is still maturing as the registry becomes operational and the sector awaits the future comprehensive digital asset law.
Summary Points
Cryptocurrency Regulatory Analysis: Montenegro
I. Regulatory Status
- Retail cryptocurrency trading is legal and regulated.
- The sector has transitioned from a legal gray area into a regulated framework.
- The status is designated as Allowed-Regulated.
II. Key Regulatory Bodies
- Capital Market Authority (CMA): Designated as the primary supervisor for the crypto sector and the VASP registration process.
- Financial Intelligence Unit (FIU): Oversees suspicious transaction reporting and AML compliance.
III. Important Legislation
- Law on Prevention of Money Laundering and Terrorist Financing (Amendments) (Official Gazette of Montenegro No. 2025/XX)
- Enacted: 2025-02-28.
- Introduced the first formal definition of crypto assets.
- Established a mandatory registration regime for all Virtual Asset Service Providers (VASPs/CASPs).
- Designated the Capital Market Authority (CMA) as the supervisor.
- Imposed KYC obligations on crypto transactions.
- Law on Digital Assets (Draft)
- Currently a draft/proposed bill.
- Intended to be a comprehensive law fully aligning with the EU's Markets in Crypto-Assets (MiCA) regulation.
- Will cover token issuance, stablecoins, and broader consumer protections.
IV. Compliance Requirements
- Mandatory registration for all Crypto Asset Service Providers (CASPs/VASPs) operating in Montenegro with the CMA.
- Strict AML/KYC requirements for all transactions.
- Specific transaction thresholds (e.g., €1,000) trigger enhanced due diligence.
- Businesses are subject to a 9% corporate tax (no specific capital gains tax for individuals).
V. Notable Restrictions or Limitations
- Implementation Lag: The law requiring registration was effective March 2025, but the official VASP registry was only reported to be launching in mid-December 2025, creating a temporary operational gap.
- Gray Market Risks: Regulators explicitly warn that unregistered 'street' or Telegram-based exchanges are illegal and unsupervised.
- Banking Access: Banks are permitted to process crypto-related transactions but often exercise high caution; OTC trading remains common.
VI. Recent Developments or Notes
- The 'Allowed-Regulated' status is based on the enacted AML amendments requiring registration.
- The practical regulatory environment is still maturing as the registry becomes operational.
- The comprehensive 'Law on Digital Assets' is expected to replace or significantly expand the current AML-focused regime in 2026.
Full Analysis Report
Full Analysis Report
As of December 2025, Montenegro classifies retail cryptocurrency trading as 'Allowed-Regulated,' marking a significant shift from its previous 'Allowed-UnRegulated' status. The pivotal change occurred with the adoption of amendments to the Law on Prevention of Money Laundering and Terrorist Financing in February 2025, which came into effect in March 2025. These amendments formally recognized crypto assets and designated the Capital Market Authority (CMA) as the competent regulatory body responsible for supervising the sector. This move was driven largely by the need to align with MONEYVAL recommendations and EU accession requirements.
The core of the current regulatory framework is a mandatory registration regime for Virtual Asset Service Providers (VASPs). Any entity providing crypto exchange, custody, or transfer services must register with the CMA. The law imposes rigorous Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) obligations, requiring service providers to verify customer identities (KYC) for transactions, particularly those exceeding €1,000. This effectively illegalizes the previously rampant unregulated 'street' trading and anonymous crypto-ATM usage, placing them firmly in the category of illicit activity if conducted without registration.
Despite the legal clarity, operational implementation has faced delays. Reports from late 2025 indicate that the CMA's registry for crypto service providers was in the 'final phase' of establishment, with a target launch date of mid-December 2025. Consequently, while the legal requirement to register exists, the market has been in a transitional state where enforcement is ramping up but the infrastructure for compliance is just coming online. This has led some observers to describe the market as still practically 'gray' despite the clear black-and-white letter of the law.
Looking ahead, the government is working on a standalone 'Law on Digital Assets' to provide a more comprehensive framework beyond just AML compliance. This upcoming legislation is being drafted with support from international partners and aims to mirror the European Union's Markets in Crypto-Assets (MiCA) regulation. Until this comprehensive law is passed, the AML amendments serve as the primary regulatory anchor, ensuring that while retail trading is permitted, it must occur through compliant, registered intermediaries.
As of December 2025, Montenegro classifies retail cryptocurrency trading as 'Allowed-Regulated,' marking a significant shift from its previous 'Allowed-UnRegulated' status. The pivotal change occurred with the adoption of amendments to the Law on Prevention of Money Laundering and Terrorist Financing in February 2025, which came into effect in March 2025. These amendments formally recognized crypto assets and designated the Capital Market Authority (CMA) as the competent regulatory body responsible for supervising the sector. This move was driven largely by the need to align with MONEYVAL recommendations and EU accession requirements. The core of the current regulatory framework is a mandatory registration regime for Virtual Asset Service Providers (VASPs). Any entity providing crypto exchange, custody, or transfer services must register with the CMA. The law imposes rigorous Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) obligations, requiring service providers to verify customer identities (KYC) for transactions, particularly those exceeding €1,000. This effectively illegalizes the previously rampant unregulated 'street' trading and anonymous crypto-ATM usage, placing them firmly in the category of illicit activity if conducted without registration. Despite the legal clarity, operational implementation has faced delays. Reports from late 2025 indicate that the CMA's registry for crypto service providers was in the 'final phase' of establishment, with a target launch date of mid-December 2025. Consequently, while the legal requirement to register exists, the market has been in a transitional state where enforcement is ramping up but the infrastructure for compliance is just coming online. This has led some observers to describe the market as still practically 'gray' despite the clear black-and-white letter of the law. Looking ahead, the government is working on a standalone 'Law on Digital Assets' to provide a more comprehensive framework beyond just AML compliance. This upcoming legislation is being drafted with support from international partners and aims to mirror the European Union's Markets in Crypto-Assets (MiCA) regulation. Until this comprehensive law is passed, the AML amendments serve as the primary regulatory anchor, ensuring that while retail trading is permitted, it must occur through compliant, registered intermediaries.
Source Evidence
Primary and secondary sources cited in this analysis
"Montenegro has adopted amendments to its Law on Prevention of Money Laundering and Terrorist Financing, effective 20 March 2025... Crypto asset service providers must now register before operating."
"The Parliament of Montenegro has adopted amendments to its Anti Money Laundering (“AML”) law on 28 February 2025... The Capital Market Commission will manage an online register of all entities offering crypto-related services."
"The registry is expected to go live by mid-December... under recent amendments to the Law on Prevention of Money Laundering and Terrorist Financing, the Commission has been designated as the authority."
"The cryptocurrency market was only partially affected by the February amendments... transactions continue to pass 'under the radar'."
Web Sources (5)
Sources discovered via web search grounding
Search queries used (9)
- Montenegro AML law virtual assets
- Montenegro cryptocurrency regulation status 2024 2025
- Montenegro Law on Digital Assets adopted
- Central Bank of Montenegro cryptocurrency warnings
- Capital Market Authority Montenegro crypto regulation
- Montenegro crypto exchange register list 2025
- Capital Market Authority Montenegro crypto register live
- "Law on Digital Assets" Montenegro status December 2025
- "Capital Market Authority" Montenegro "digital assets" register
https://www.karanovicpartners.com/news/montenegros-first-ever-crypto-regulation/
https://casinosblockchain.io/crypto-gambling-regulations-in-europe/
https://open4business.com.ua/en/million-dollar-cryptocurrency-transactions-in-montenegro-pass-attention-of-regulators/
https://monte.business/montenegro-nears-launch-of-crypto-service-providers-registry-amid-regulatory-gaps/
https://www.jpm.law/montenegro-updates-aml-laws-for-crypto-regulation/