The Central Bank of Montenegro (CBCG) imposed fines of around 2024 thousand euros on Montenegrin banks for money laundering for the first time since its establishment in 800. In the first six months of 2025, the amount of fines was five times higher, approximately four million euros, the CBCG announced.
Due to strict legal procedures, from the Central Bank of Montenegro for Center for Investigative Journalism of Montenegro (CIN-CG) They did not say which banks were involved. Unofficially, we learned that several banks were sanctioned, and that some of them had to pay millions in fines. Money laundering fines are imposed on banks, for example, for large transactions that do not have coverage.
"The total amount of funds sanctioned by the Central Bank of Montenegro based on established irregularities in the field of preventing money laundering and terrorist financing and non-compliance with international restrictive measures amounted to over 4,6 million euros. Such decisive and lawful action marked a turning point in institutional practice, as the Central Bank of Montenegro had never previously applied financial sanctions of this type, despite its legal authority," she told CIN-CG. Gordana Kalezić, Director of the Directorate for the Prevention of Money Laundering and Terrorist Financing and the Protection of Clients of Credit Institutions and Users of Financial Services.
"Vijesti" recently reported that the Central Bank of Montenegro imposed a fine of 3,6 million euros on Adriatic Bank for violating the Law on the Prevention of Money Laundering and Financing of Terrorism, and that a court case is underway. This was stated in the report of the external auditor on the financial statements of Adriatic Bank...
Although Montenegro has been a money laundering country for decades, few institutions have addressed this. The current sanctions on banks were initiated at a meeting of the Committee of Experts on the Evaluation of Measures against Money Laundering and the Financing of Terrorism - MONEYVAL, which took place in December 2023. It warned of the long-standing problems that Montenegro has in the field of money laundering. And Montenegro narrowly avoided being placed on the grey list of this permanent body of the Council of Europe, thanks to the adoption of the Law on the Prevention of Money Laundering and the Financing of Terrorism.
For the year and a half of the governor's term Irene Radović, the Central Bank of Montenegro, in cooperation with experts from the Netherlands and Belgium, and experts from the International Monetary Fund (IMF), worked to improve the banking supervision system. This was necessary because a higher level of control over money laundering and financial abuses in the banking sector was one of the prerequisites for joining the European payments system.
Success in SEPA integration
The Central Bank of Montenegro has managed to overcome this challenge, and from the autumn Montenegro will be the only country in the Western Balkans to have reached this level in the field of payment transactions. All banks operating in Montenegro will join the Single Euro Payments Area (SEPA) from 6 October 2025. This will enable citizens and businesses to pay and receive money in euros within Europe faster and cheaper, without intermediary banks and additional fees.
Former governor of CBCG Ljubiša Krgović, Chairman of the Advisory Board of the Central Bank of Montenegro, estimates that the total direct benefits for users from joining SEPA, due to reduced payment transaction costs, will amount to 150 to 170 million euros per year. Namely, bank clients will no longer pay high commissions for money transfers - there will be no commission for transactions up to 200 euros, and for amounts up to 20 thousand euros they will pay 1,99 euros, while for amounts above 20 thousand they will pay 3,99 euros.
However, despite the results achieved by the Central Bank of Montenegro in the fight against money laundering, in conducting negotiations with the European Union (EU) for chapters 4, 9 and 17, as well as in joining the SEPA system, the Parliament of Montenegro is making the work of the Central Bank of Montenegro more difficult - without any explanation. The Parliament has not elected the vice governors that Radović proposed at the end of last year. In early September 2024, the Governor sent a letter to the Parliament of Montenegro, in which she proposed the following as the first associates - vice governors: Gordana Kalezić i Milan Remiković.
First, the election was waited for eight months, and when the proposal was put to a vote, there was no majority, which independent experts interpreted as a blow by the majority against Radović.
"Montenegro should ensure a transparent election of members of the Central Bank Council, including vice governors, based on the professional competencies of the candidates and through a procedure that is in line with the Law on the Central Bank," the EU warned a week before the vote on the vice governors in the Parliament.
Although Article 50 of the CBM Law clearly stipulates that “vice governors are appointed by the Parliament, upon the proposal of the governor”, the deputies did not accept the governor's proposal. Without explanation. She is currently the only vice governor in a full term Zorica Kalezić, whose term expires in December this year.
Although the governor cannot work without a vice governor who is professional and trustworthy, according to unofficial information from CIN-CG, the speaker of the parliament, the prime minister, and the president of the state have proposed their candidates for the position of vice governor to the governor. She has refused.
She also resented the majority for criticizing the Fiscal Strategy and the Development Bank Act.
In 2025, the European Commission (EC) published the Assessment of the Economic Reform Program of Montenegro for the period 2025-2027, a week before the (non-)appointment of the Vice Governor in the Parliament.
"The 2025 budget targets a deficit of 3,5 percent, due to the full effect of the implementation of the Europe Now 2 program, including a large reduction in pension contributions, accelerated capital investments and certain compensatory measures such as an increase in indirect taxes," the EC Assessment says.
In the same document, the EC points out that the austerity plans are not realistic or detailed enough, and although the debt currently appears to be lower, this is due to economic growth, not real debt reduction. The debt will likely grow again and remain above the permitted level.
"The expected budget savings appear overly optimistic and are not sufficiently supported by concrete measures in the program. The public debt-to-GDP ratio, which has been significantly reduced in previous years mainly due to strong nominal GDP growth, is projected to fall to 60,2 percent in 2025 and then increase to 64,6 percent in 2027, remaining above the fiscal rule limit," the EC document states.
The Central Bank of Montenegro's criticisms were somewhat milder on the Fiscal Strategy for the period 2025-2027, but the opinions of the CBCG's expert service generally coincided with those of the EC.
"The CBCG generally supports the Government's fiscal policy aimed at planning a current surplus and borrowing exclusively for capital projects, which is in line with EU recommendations. However, it expresses concern about the projected public debt remaining above 60 percent of GDP throughout the period, as well as the lack of analysis of adverse scenarios," the opinion on the proposal for the fiscal strategy of Montenegro for the period 2024-2027 states.
The Central Bank of Montenegro, as well as the EC, warn that the Fiscal Strategy leads to a violation of the Maastricht Treaty, as well as European integration, because public debt must not exceed 60 percent of GDP.
The strategy does not include “stress scenarios” or an assessment of the impact of potential negative shocks (e.g., the departure of non-residents, the overhaul of the Pljevlja thermal power plant), although they have already been analyzed in the Economic Reform Program. According to this document, an increase in living standards is expected, but also a potential growth of the shadow economy due to the burden of increasing minimum wages, especially for small and medium-sized enterprises. It warns of possible inflationary pressures due to the increase in wages, excise duties and VAT, noting that the effect is mitigated by high imports. There is no clear strategy for the reform and optimization of public administration. It is recommended to use the IMF methodology for assessing public spending.
The Central Bank of Montenegro's objective criticism of the government's strategy has further cooled the ruling majority's relationship with the governor. According to unofficial information from CIN-CG, not a single meeting between the prime ministers has taken place so far. Milojko Spajić and governors.
Criticism of the Law on the Development Bank
Currently, there are a total of 11 banks operating in Montenegro, of which the four largest - CKB, Hipotekarna, NLB and Erste - together control over 68 percent of the market, indicating a high concentration in the banking sector. These four banks hold the majority of the entire sector's loan portfolio (73,35 percent), as well as the deposit portfolio with 66,65 percent.
Montenegrin banks generated a total profit of 2024 million euros in 161,4, which is 10,57 percent more than the year before, when profit amounted to almost 146 million euros.
In August 2024, the Parliament adopted the Law on the Development Bank, opting for a hybrid and unusual model. According to the Law, the Development Bank would operate as a company that would handle payment transactions and deposits, outside the control of the Central Bank of Montenegro. The Law also stipulates that the Development Bank will not invest in the deposit protection fund, which is mandatory for other banks.
This model allows the Development Bank to violate the principle of competition. If this institution were to operate as envisioned in parliament, the Development Bank would be the third largest bank in Montenegro, with a more favorable position compared to commercial banks, as the regulatory requirements and fees that they must comply with do not apply.
Criticism of the chosen model came from the EC, as well as from the Central Bank of Montenegro.
"A development bank should operate in accordance with best practices when it comes to governance, as well as with appropriate supervision and regulation that applies to other institutions that collect deposits, in order to ensure transparency, sound lending practices, adequate deposit protection, and a level playing field in the banking sector," the EU Delegation told CIN-CG.
The EC opinion, published on May 13, 2025, indicates that the Law on the Development Bank violates various EU directives.
"In this regard, we point out that the recital of Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on the taking up and prudential supervision of credit institutions, amending Directive 2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC (the so-called CRD) states that the scope of application of the regulation relating to credit institutions should be as broad as possible and include all institutions whose business is to receive repayable funds from the public in the form of deposits or other forms."
At the end of August 2024, the Central Bank of Montenegro issued an opinion on the Law on the Development Bank. The opinion states that the Central Bank supports the establishment of the Development Bank of Montenegro:
"However, despite the above, the Central Bank considers it important to point out certain solutions that it believes should be further reviewed before the adoption of the law in question."
The Central Bank of Montenegro advocated for a model that is closer to Croatia and Slovenia. In case you want to take a deposit, or rather, to take money, e.g. savings from individuals and legal entities, only credit institutions can do that, and that is banks. In order to do that, you must be licensed under our law, the Central Bank of Montenegro must license you and verify you. The Central Bank of Montenegro has great powers, it can change the entire management of banks with one decision. It can revoke the license forever, the Central Bank of Montenegro explained to CIN-CG.
Another issue is that the Development Bank would not invest funds in the Deposit Protection Fund. The Central Bank of Montenegro explained to CIN-CG:
“In the event of a crash, the Fund can compensate clients who have deposits. In the case of the Development Bank, they do not fall under that system. That is a problem because in that case the state would probably have to take over.”
Negotiators for chapters closed by the Central Bank of Montenegro replaced
The Central Bank of Montenegro played a key role in the negotiations for Chapters 4 - Free Movement of Capital, 9 - Financial Services, and 17 - Economic and Monetary Union, as well as the remaining six chapters in which it participates. According to unofficial information from CIN-CG, the Central Bank of Montenegro completed its obligations related to the negotiation chapters last year and some of the chapters could have been closed as early as December 2024. Instead of closing them, the Government replaced the negotiators in February, even though they are par écselance. chapters of the Central Bank of Montenegro.
"From the formal start of Montenegro's negotiations with the European Union in 2012, i.e. from the opening of Chapter 4 - Free Movement of Capital on 24 June 2014 at the Intergovernmental Conference in Brussels, until March 2025, the Central Bank of Montenegro managed this chapter, through the engagement of the Director of the Sector for Financial Stability, Research and Statistics Marijane Mitrović-Mijatović", who served as the head of the Working Group during that period. Since the beginning of March 2025, the management of the Working Group has been under the jurisdiction of the Ministry of Finance," the Central Bank of Montenegro told CIN-CG.
They emphasized that the Central Bank of Montenegro has fulfilled all obligations within its jurisdiction required for the closure of this chapter, through full contribution in the areas of payment transactions and the prevention of money laundering and the financing of terrorism (AML/CFT), and that the results achieved, especially in the area of payment transactions, are already visible through SEPA membership, which will enable Montenegrin businesses and citizens to freely open accounts, make savings, invest, pay and collect foreign liabilities in the same way as businesses and citizens in the 27 EU member states. The Central Bank of Montenegro believes that the closure of Chapter 4 - Free Movement of Capital can be expected by the end of this year.
Since March this year, the Ministry of Finance has also taken over Chapter 9 - Financial Services, which was previously managed by the Central Bank of Montenegro. The same happened with negotiating Chapter 17 - Economic and Monetary Union, in which the Central Bank of Montenegro has so far completed the majority of its obligations.
Milica Kilibard from the Center for Macroeconomic and Financial Research of the Central Bank of Montenegro and negotiator for Accession Chapter 17 until March this year, estimates that this chapter will be the last to be closed, hopefully temporarily at the end of 2026. She also points out the problem:
"In accordance with the Law on the Central Bank of Montenegro, at the end of August 2024, the Governor submitted to the Parliament of Montenegro proposals to appoint two vice-governors to the vacant positions from among independent professionals with many years of experience working in the Central Bank in systemically important positions, free from political influence - all in accordance with the provisions of the Law on the Central Bank of Montenegro. However, due to the abstention of three out of eight political majority parties, the Parliament of Montenegro did not elect the proposed candidates."
Kilibarda also explains that in addition to the two vice governors (positions vacant for over 30 months, since the beginning of March 2023) who are proposed by the Governor of the Central Bank of Montenegro under the Law, the positions of four external members of the Council who are not employed by the Central Bank have also been vacant since July 2024, and who are proposed by the Parliament of Montenegro upon the proposal of the competent parliamentary committee.
The Ministry of Finance told CIN-CG that cooperation with the Central Bank of Montenegro is excellent.
"In terms of cooperation, we would like to point out that the Ministry of Finance has continuous and excellent cooperation with the Central Bank, in all areas of cooperation and the negotiation process of Montenegro's accession to the European Union."
Is the governor's replacement being prepared?
The failure to elect a vice governor has seriously shaken the further work of the Central Bank of Montenegro. According to CIN-CG's findings, the Central Bank of Montenegro also suspects that Governor Radović is being prepared to be replaced.
Although it was announced for the end of July, the election of external members of the CBCG Council has been postponed. If the election of the four new members were solely at the discretion of the ruling parties, then the parties would have the upper hand in the Council, and the dismissal of the Governor could be initiated.
Krgović reminds that Governor Radović has already been dismissed once in the same way, but from the position of Vice Governor:
"The government launches an initiative, an inquiry committee is formed in the Parliament, which prepares a report, and then she is dismissed. And she was dismissed based on the governor's proposal. So, they didn't respect the dismissal mechanism even then."
In addition, the Central Bank of Montenegro suspects that the political majority could initiate amendments to the Law on the Central Bank of Montenegro in order to adapt this institution to its interests.
According to two unofficial sources for CIN-CG, the Prime Minister's office, with members of the former CBCG governor's staff, is behind the attack on the governor. Radoje ŽugićThe former forces have joined forces with currents from the new government who want to bring this institution under their control.
CIN-CG was told by multiple sources that the governor had been threatened, even by government officials. The CBCG asked for an assessment of her security. They received a response from the ANB that everything was fine.
A clear sign that Governor Radović has international support is the visit of the Executive Director of the International Monetary Fund (IMF) Jeruna Klika The Central Bank. On September 9, at a working breakfast with journalists, he expressed optimism about the Montenegrin economy, noting that "good policies bring economic growth, but there is still a lot of potential for progress."
At the aforementioned event, Governor Radović addressed the failure to elect a vice governor, saying that the laws are clear and that the experts she proposed fully meet the legal criteria:
"No one heard a single word that would dispute their biographies and not a single vote was against," said Radović, adding that she would contact all parliamentary groups again and ask them to present the candidates.
The political response arrived the very next day. On September 10, the Parliamentary Committee on Economics did not vote on the Central Bank's reports for 2022, 2023, and 2024 because at the end of the debate, only two of the 13 MPs who were members of the Committee were in the room.
Bank licensing
Two applications for a bank license in Montenegro have been submitted to the Central Bank of Montenegro since December 2023. These are applications for “Zeren Bank AD Podgorica” (Republic of Turkey) and “Dobra banka AD Podgorica” (United Arab Emirates).
On March 15, 2024, the Turkish “Zeren Group” submitted its first application for a bank license in Montenegro.
Zeren Group is a company that operates with 16 brands in seven sectors and in five countries - Turkey, Montenegro, the Netherlands, the United Kingdom and the United Arab Emirates, according to their official website. There is no bank in any of these countries.
This group, whose Montenegrin headquarters are in Capital Plaza Podgorica, has opened three companies in Montenegro in the past two years - "Zeren Group Investment", "Zeren Motors" and "Zeren Food".
The owner of the Zeren Group is a businessman close to the family of Turkish President Recep Tayyip Erdogan, Mustafa Yigit Zeren, who, according to media reports in Turkey and Europe, participated in a dubious scheme to evade sanctions on Russian oil exports.
"During the decision-making process, based on the submitted documentation, it was determined that the group does not meet the legally prescribed conditions for obtaining a license. Zeren Group was notified of this in a timely manner and in accordance with the Law, after which it withdrew its request on September 20, 2024, and the Central Bank suspended the procedure for issuing a bank license on the same day," Milan Remiković, Director of the Control Sector at the Central Bank of Montenegro, told CIN-CG.
On March 12th of this year, Zeren Group submitted a new application for the issuance of a license to operate Zeren Bank Montenegro AD.
"The decision-making process on this request, as well as the assessment of whether all the prescribed conditions for issuing a license for the operation of this bank have been met, is ongoing. The applicant completed the legally prescribed documentation for the decision-making process on July 16, 2025. This brought the request into line with the provisions of the Law on Credit Institutions and started the 180-day decision-making period, in accordance with Article 68 of the Law on Credit Institutions, which expires on January 12, 2026," explains Remiković.
The application for the issuance of a license to operate "Dobra banka AD Podgorica" was submitted to the Central Bank of Montenegro on May 15, 2024, by one legal entity from the United Arab Emirates and one natural person from the United Kingdom of Great Britain and Northern Ireland, resident in the United Arab Emirates.
Remiković says that during the decision-making process, it was determined that the applicants did not meet the legally prescribed conditions for issuing a license. After being notified of this, in accordance with the Law, on September 24, 2024, they withdrew their application, and on September 26, 2024, the Central Bank suspended the procedure for issuing a bank license.
According to reliable sources from CIN-CG, a group from Serbia, gathered around the current main banking magnate in this country, Davor Macura, owner of the Alta Group, is also interested in opening a bank in Montenegro.
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