Banks and other payment service providers are no longer allowed to accept cash payments of EUR 10.000 or more related to the proceeds from the sale of real estate, motor vehicles, watercraft... and other movable and immovable property, or related transactions whose total exceeds that amount. This is stipulated by the amendments to the Law on the Prevention of Money Laundering and Financing of Terrorism (SPNFT) of May 12, the Financial Intelligence Unit (FIU) of the Police Directorate told "Vijesti".
The December 2023 law limits cash transactions by legal entities and individuals to an amount of 10.000 euros and above, and has since prevented notaries and lawyers from drafting and certifying sales contracts in which transactions are made in cash above that amount. The then law left several exceptions that have now been deleted from the law through amendments.
"The amendments to the AML/CFT Law, which entered into force on 12 May 2026, further expanded the restriction on the use of cash. Credit institutions and other payment service providers are required to disallow payments of proceeds when they relate to the sale of real estate, unless the price of the real estate is lower than 10.000 euros, as well as payments on individual invoices in the amount of 10.000 euros or more, when they relate to the sale of motor vehicles, watercraft and aircraft, cultural property, precious metals, precious stones, products made of precious metals and precious stones, and watches," the FIU stated.
They clarify that these changes apply a general limit of 9.999 euros on cash transactions from May 12th.
"From December 2023 to May 12, 2026, a restriction on the use of cash was in effect, but not as a general one for everyone, i.e. there were exceptions to its application. The practice that has been established since December 2023 in terms of circumventing this provision has led to a tightening of the conditions for the cash restriction, so that a general restriction now applies, without exceptions," the FIU said.
The application of restrictions on cash transactions, as they explained, is controlled through the actions of taxpayers under the Law on the Prevention of Money Laundering and Financing of Terrorism, and in particular through supervision of the application of the law, monitoring of transactions and reporting suspicious activities.
"Data to date indicate that the implementation of Article 65 of the AML/CFT Law, which limits the use of cash, has yielded concrete results. In real estate transactions, a decrease in the use of cash was recorded by 13,65 percent compared to 2024, or by 46,97 percent compared to 2023. The share of cash in real estate transactions in 2025 was 7,07 percent, while in 2024 it was 10,42 percent," the sector stated.
When asked by "Vijesti" whether any fines have been imposed so far based on the legal solutions from 2023, which relate to violations of the provisions on the restriction of cash transactions, the FIU said that according to the data available to them, two fines were imposed in 2024, in the total amount of 7.000 euros, while five fines were imposed in 2025, in the total amount of 25.500 euros.
They also explained how to determine what are related transactions, the total of which cannot exceed 10.000 euros.
"Article 6, point 68 of the AML/CFT Law stipulates: linked transactions are two or more transactions that can be considered to be interconnected due to the time period in which they were carried out, the recipient or the originator, the manner in which the transaction was carried out, the reason for which the transactions were carried out or other factors on the basis of which the transactions can be considered to be linked. In practice, this means that not only the individual payment is observed, but also the broader context of the transactions. For example, if a single obligation or a single purchase is divided into several smaller cash payments in order to avoid the threshold of 10.000 euros, such transactions are treated as linked. The aim of this provision is to prevent circumvention of the legal restriction through the formal separation of a single transaction into several smaller payments," the FIU stated.
Several notaries told "Vijesti" that despite the ban on notarizing contracts for cash transactions, which has been in effect for a year and a half, they still receive clients seeking such services because they are not informed about the prohibitions and restrictions under the law.
It is possible that the allowed amount will be even lower.
When asked by "Vijesti" whether there will be any new rules or restrictions regarding cash transactions in the continuation of the negotiations between Montenegro and the EU and the accession process, and if so, which ones, the FIU replied that the option of further tightening of certain rules is not ruled out.
"It can be expected that with Montenegro's accession to the EU, the limit on the maximum amount of cash payments will be reduced, as most European countries prescribe a lower limit of 10.000 euros. For example, the limit in the Netherlands is 3.000 euros, in Italy 5.000, in Latvia 7.200, in Lithuania 5.000, in Portugal 3.000, in Slovenia 5.000, and in Spain 1.000 euros," said this sector of the Police Directorate.
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