"Last year, the Gaming Authority and the Electronic Communications Agency (EKIP) blocked over 450 internet sites for organizing games of chance that did not have licenses to operate in Montenegro, and through which multi-million-dollar turnovers were discovered in recent years," the Gaming Authority told "Vijesti".
The administration, together with the Ministry of Finance and the Central Bank, has been blocking payments to foreign illegal websites from bank accounts and payment cards from Montenegro for three years.
However, the interlocutor of "Vijesti" says that all this brings limited results because illegal sites easily and quickly change IP addresses and continue to operate, while some sites have connected cryptocurrency exchanges to their system, so a citizen from Montenegro does not pay for games of chance but formally buys cryptocurrencies and these transactions cannot be blocked now. Also, if he makes a profit, he is paid in cryptocurrency to his e-account, which he can convert into money. This, as he said, avoids paying the newly introduced profit tax, but also monitoring the flow of money from payments and winnings.
Over 130 thousand transactions annually
In the past two or three years, the state has increased concessions to legal organizers by 30-40 percent, introduced a profit tax and an obligation for the financial police to monitor all players who pay 20 euros or more in one or more related transactions (while in the EU the limit has been increased to 3.000), as well as limited advertisements by domestic organizers in domestic media, while not limiting or controlling advertisements for foreign and illegal shows on cable television and social networks visible from Montenegro.
In the periods before the introduction of the ban on bank card payments for illegal sites, in 2022 and 2023, according to data from the Gambling Authority, officially visible payments to these sites amounted to over six million annually, with over 130 thousand transactions in which around five thousand payment cards of domestic banks were used.
Management also warns of fraud
The Directorate for Games of Chance told "Vijesti" that they are conducting continuous surveillance activities and taking measures to combat illegal games of chance, including the activities of illegal and foreign internet platforms that offer their services to citizens of Montenegro without the necessary approval. They point out that they are having difficulties because illegal organizers quickly change IP addresses or use cryptocurrencies, but they also warn citizens that fraud also occurs on these sites and that the state cannot protect them if they pay money or other valuables to unregistered organizers.
"The Administration obtains information about the existence of illegal websites through regular monitoring activities, reports from citizens and other institutions, as well as through intensive inter-institutional and international cooperation. After identifying websites that offer unauthorized games of chance services, the Administration for Games of Chance sends requests to the competent regulatory authority in the field of electronic communications - the Agency for Electronic Communications and Postal Services (EKIP), for further action, in accordance with Article 80 of the Law on Games of Chance, and for the purpose of technically blocking access to those websites on the territory of Montenegro by electronic communications operators. The Administration for Games of Chance regularly updates and expands the list of IP addresses, domains and other related resources for access to illegal organizers. During 2025, in cooperation with EKIP, over 450 websites that illegally organized games of chance and were available to users in Montenegro were blocked, which represents a significant step forward in combating the shadow economy in this area and protecting the interests of citizens," the Director of the Administration told "Vijesti" They save Papić.
IP address changes and crypto payments
He states that they face challenges when illegal organizers, after the blockade, try to continue their work by registering new domains, changing IP addresses, or using other technical solutions to circumvent the ban.
"The Administration continuously monitors such phenomena and, in cooperation with EKIP and other competent institutions, takes additional measures to promptly identify and sanction such forms of illegal activity. Also, in cooperation with competent bodies of other countries, we can initiate blocking of access to illegal organizers of games of chance through international exchange of information. A major problem is the mass registration of the aforementioned platforms in countries such as Curacao, Anjouan, etc., from whose regulatory authorities it is quite difficult to obtain information about the registration and existence of the aforementioned platforms," Papić stated.
When it comes to websites that allow payments via cryptocurrencies, such as bitcoin, or other forms of payment that do not go through bank accounts, Papić points out that such methods of organizing games of chance are not provided for by the current Law on Games of Chance in Montenegro.
"Therefore, this type of payment or organization of games of chance is considered illegal, and their possible operation would pose an additional challenge in terms of monitoring financial flows. It is important to point out that the Gaming Authority does not have statutory jurisdiction in this area, and the Gaming Authority's information system that performs online supervision over organizers only monitors transactions carried out in the official currency of the euro. In Montenegro, games of chance can only be organized by legal entities that have the appropriate approval from the competent authority and operate in accordance with domestic regulations. Internet platforms that are not registered in Montenegro and do not have the approval of the Gaming Authority are not subject to the domestic regulatory framework, which is why the use of such sites carries serious risks for citizens, including the possibility of fraud, loss of deposited funds and unpaid winnings," Papić stated.
With the help of the Central Bank of Montenegro, they block transactions
In order to protect citizens and strengthen the institutional response to illegal games of chance, the Gambling Administration, as he said, is continuously cooperating with the Central Bank of Montenegro (CBCG).
"This cooperation is particularly important in the part related to financial flows and payment transactions to illegal foreign platforms. Accordingly, through the joint work of the Ministry of Finance, the Central Bank of Montenegro and the Gaming Authority, the decision of the Gaming Authority to prohibit payment transactions to unauthorized organizers of games of chance has been successfully implemented, in accordance with the Law on Gaming. Accordingly, all banks and other payment service providers in Montenegro are obliged to reject payment transactions where the payee is a foreign legal entity using the Merchant Category Code (MCC) 7995, and which were initiated from accounts in Montenegrin commercial banks. Based on data obtained by the Central Bank of Montenegro from all credit institutions operating in Montenegro, it was determined that during 2022, 132.109 transactions were carried out with 4.911 payment cards, with a total value of 6.315.019,61 euros, while in 2023, 133.445 transactions with 5.118 payment cards, totaling 6.183.943,93 euros. In the first quarter of 2024, 30.367 transactions with 1.998 payment cards were registered, totaling 1.296.541,45 euros. The indirect control of the Central Bank of Montenegro confirmed that all banks operating in the territory of Montenegro acted in accordance with legal requirements and completely blocked transactions identified as payments to unauthorized foreign organizers of games of chance," said Papić.
He states that this measure was implemented through joint action by the Ministry of Finance, the Central Bank of Montenegro and the Administration, which further limited the financial operations of illegal organizers and significantly improved consumer protection and the integrity of the financial system of Montenegro.
Legal restrictions, illegals easily change IP addresses and advertise themselves publicly
An interlocutor of "Vijesti" from this business said that in recent years, the associations of legal Montenegrin editors and their group in the Chamber of Commerce have repeatedly pointed out to the public and authorities the problem of the existence of illegal websites, and that they have sent the Administration and Inspection several reports of their IP addresses, as well as their advertising in Montenegro.
"The bottom line is that when one IP address is revoked, they, so-called, 'mirror' it to another and so on and so forth... When it comes to blocking payment cards of banks for payments, it is true that it gave results at the time, but they go through 'payment' alternatives so that everything goes in circles there too. I think that there must be a strong systemic response here with a prior better understanding of this area and trends in the industry because the Law on Games of Chance significantly raised the levies on legal organizers, profits were taxed, but it remains 'up in the air' how strong mechanisms will be created to combat illegal organizing that is present, as evidenced by all these illegal sites that advertise much more than the adoption of the new Law on Games of Chance, and not only that, but they also use our influencers for these purposes, and the state does not deal with this topic of advertising but regulates and additionally burdens those who work legally," said the interlocutor of "Vijesti".
EKIP informed the Coordination Body about the problems and the need for changes to the law
The Electronic Communications Agency (EKIP) told "Vijesti" that in December last year they submitted to the Coordination Body for the Protection and Promotion of Public Interest in the Field of Organizing Games of Chance Information regarding the challenges in the field of supervision and suppression of illegal organizing of games of chance via the internet.
"The information points to significant challenges in the implementation of the current legal framework, especially due to the need for further harmonization of the Law on Electronic Communications and the Law on Games of Chance, as well as the need for a clearer demarcation of jurisdiction between institutions, in order to improve legal certainty and more efficient action in this area," EKIP stated.
EKIPA told "Vijesti" that Article 143, paragraph 4, item 1 of the Electronic Communications Law of 2024 stipulates that internet access service providers may not block, slow down, modify, restrict, interfere with, degrade or discriminate against certain content, applications or services or certain categories thereof, unless such content is prohibited by law or based on court decisions or other institutions that have been granted appropriate authorization.
They point out that they do not have the authority to identify illegal internet sites or IP addresses for games of chance, nor do they independently decide on blocking such content, but that the Games of Chance Administration does this, and that it submits blocking orders to EKIPU.
"In cases where the Gambling Authority issues a relevant act, or sends a request, the Agency forwards that request to the operators of electronic communications networks and services that provide internet access services, for the technical implementation of blocking. In the previous period, there were cases of acting upon the requests of the Gambling Authority, however, the Agency does not keep records of the number of identified illegal organizers, nor of the frequency of the appearance of new domains and IP addresses, since, pursuant to the Gambling Act, the Gambling Authority is responsible for monitoring and updating the list of domains and IP addresses related to the illegal organization of games of chance via the internet," EKIP stated.
Illegal websites provide instructions, are also advertised by influencers
In the past few days since "Vijesti" has been investigating this topic, they have received more information about foreign and illegal betting sites from Montenegro, such as rainbet.com (registered in the state of Comoros), titanwin.bet (unclear origin), 20bet.com (territory of Curacao), 1xbet.com (Curacao)...
These sites also provide players with instructions in our languages on how to register from Montenegro, how to bypass regulations, how to deposit in cryptocurrencies, and how to withdraw winnings. They also provide contact with an agent for Montenegro.
They also have social networks that are visible from Montenegro. It can also be seen that, for example, titanwin.bet has special paid posts on Instagram that are related to showing to users in Montenegro. Also, the betting company rainbet.com from Komora in Montenegro is advertised by an influencer from Montenegro with the nickname “lobanjica” who has 300 thousand followers.
The Law on Games of Chance, among other things, prohibits participation in foreign games of chance for which stakes are paid on the territory of Montenegro, collection of stakes in Montenegro for participation in games of chance organized abroad, as well as the sale, holding, assignment, issuance, advertising and any other presentation of foreign lottery tickets and tickets (slips) for games of chance on the territory of Montenegro.
Violations of these articles are subject to fines ranging from 1.000 to 20.000 euros.
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