Montenegro — Country Risk Report

Montenegro (Europe • Southern Europe). Risk report as of the 19 Jun 2026 FATF plenary.

High country risk, with elevated corruption risk. Montenegro's country risk score is 6.0/10, placing it in the high-risk band. The principal driver is weak corruption, alongside rule of law and institutions risk. Montenegro is not currently FATF grey- or black-listed. Montenegro is not subject to comprehensive country-wide sanctions. Firms should apply additional scrutiny where exposure involves state-linked entities, restricted sectors, sensitive technology, dual-use goods or politically exposed counterparties.

Recommended treatment

Enhanced due diligence.

At a glance

  • FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
  • Comprehensive country sanctions: none identified. Targeted sanctions exposure: programmes in place, screen applicable lists
  • Government effectiveness and rule of law: 4.0/10
  • Corruption (CPI 2025): 46/100, rank #65 of 182
  • Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 6.0/10 (High)

Higher score means higher country risk (global average 4.6). Full information available. Strong data coverage. Enforcement activity and CPI are shown for context but do not change the score.

All three parts of the score are available.

How this score was calculated

  • Financial crime controls: 5.4/10 — 50% of this score
  • Government effectiveness and rule of law: 4.0/10 — 30% of this score
  • International sanctions: 5.2/10 — 20% of this score
  • sector-wide international sanctions means the score cannot be lower than 6.0. This minimum set the final score.
Show the exact calculation

aml 5.4 × 50% + governance 4 × 30% + sanctions 5.2 × 20% = 4.9; sanctions-sectoral floor 6 applied; final 6

Principal risk drivers

  • Sectoral sanctions exposure
  • Corruption (WGI) — 5.3/10

Mitigating factors

  • Not currently on the FATF grey or black list.
  • No comprehensive country-wide sanctions programme.
  • Comparatively stronger political stability (2.8/10).
  • Risk is concentrated in specific counterparties, sectors and transactions rather than applying uniformly.

Business impact

  • Customer onboarding (High): Additional ownership and control verification may be required.
  • Payments and transactions (High): Review transaction purpose, counterparties and geographic routing.
  • Trade and export activity (High): Screen goods, end users and potential dual-use exposure.
  • Corporate clients (High): Assess state ownership, government links and political exposure.
  • Ongoing monitoring (High): Apply alerts for ownership changes, sanctions and geopolitical developments.

Recommended controls

  • Verify ultimate beneficial ownership using more than one reliable source.
  • Identify state ownership, government influence and politically exposed persons.
  • Screen entities, directors and beneficial owners against applicable sanctions lists.
  • Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
  • Document transaction purpose and source of funds where cross-border structures are complex.
  • Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

  • State ownership / control
  • PEP involvement
  • Sensitive / restricted sectors
  • Opaque ownership
  • Adverse media
  • Dual-use goods & technology
  • High-risk intermediary routing

FATF status: Not currently listed

Montenegro is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Sanctions: Sectoral

  • EU — sectoral: Prohibiting the satisfying of certain claims in relation to transactions that have been prohibited by the UN Security Council Resolution 757(1992) and related resolutions (source)

Source details

International sanctions by issuing body

  • UN: No
  • EU: Yes (Sectoral)
  • UK: No
  • US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

  • Government Effectiveness: 58/100
  • Regulatory Quality: 57/100
  • Rule of Law: 60/100

Regulators and legal framework

FATF network

FATF network via MONEYVAL.

Last mutual evaluation: 2024 · report

National regulators

Regulator profiles not yet available on RegActions.

FIU: Egmont Group member

Framework signals

  • FATF listing: Not currently listed
  • International sanctions: sectoral exposure
  • Corruption (CPI 2025): 46/100, rank #65 of 182
  • Rule of law (WGI): 4.2/10 risk

Sector exposure

  • Banking & payments (Low): No FATF listing, rule-of-law governance within normal range
  • Trade & export controls (High): Sectoral sanctions: Prohibiting the satisfying of certain claims in relation to transactions that have been prohibited by the UN Security Council Resolution 757(1992) and related resolutions
  • Crypto & virtual assets (Low): No FATF listing, accountability governance within normal range
  • Real estate & luxury assets (Low): Corruption indicators within normal range for high-value assets
  • State-linked & procurement (Low): Political-stability and corruption governance within normal range

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Montenegro: analysis

Montenegro's profile is driven wholly by governance factors, with no FATF or sanctions overlay. The dominant risk domain is corruption (35% weight), followed by rule of law and institutions (40% weight), which together carry three-quarters of the governance weighting. Political stability (moderate) and voice and accountability (moderate) are more moderate risk contributors. Montenegro sits slightly above the global median in governance quality on the World Bank indicators. The CPI reading is consistent with these findings. No enforcement actions are tracked.

Outlook

Montenegro's EU accession process provides a degree of reform pressure, particularly on the judiciary and anti-corruption frameworks. Progress has been slow, however, and structural corruption remains an entrenched challenge. The next FATF plenary in October 2026 represents a monitoring point, albeit with no current listing risk. Firms should expect the governance base to remain broadly stable unless accession-related reforms accelerate.

Key watchpoints

  • Anti-corruption and judicial reform milestones within the EU accession negotiations.
  • Any shift in FATF listing status given the absence of a current listing.
  • Developments in organised crime and illicit financial flows, which are material concerns in the Western Balkans more broadly.
  • CPI trajectory as an independent cross-check on governance improvements or deterioration.

Assessment currency

  • FATF status: Not listed (as of 19 Jun 2026)
  • Sanctions exposure: Targeted programmes in place (as of Jul 2026)
  • Governance (WGI): Latest dataset incorporated (as of 2024)
  • Corruption (CPI): 46/100 (as of 2025)
  • RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

  • FATF network membership: FATF regional network: MONEYVAL (present, as of 2026-07)
  • EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
  • Egmont Group FIU: FIU membership (present, as of 2026-07-17)
  • Beneficial-ownership register: No live register identified in the source (unavailable, as of 2026-07-17)
  • Transparency International CPI: 46/100, rank 65 (present, as of 2025)

Evidence freshness

  • FATF monitored-jurisdiction status: current; data 2026-06-19
  • FATF mutual evaluation and follow-up ratings: current; data 2026-07-31; follow-up 2025-12; base assessment 2024-01
  • World Bank governance indicators: current; data 2024
  • UN, UK, EU and US sanctions regimes: current; data 2026-08-16

Contextual signals are public evidence only and do not change the immutable v2 score.

Download evidence PDF · CSV · JSON

Regional peer scores

FAQ

Is Montenegro on the FATF grey list?

No. Montenegro is not on the FATF grey or black list as of the 19 Jun 2026 plenary. FATF listing is one AML indicator; absence from the list does not by itself make Montenegro low risk. The next FATF plenary review is scheduled for Oct 2026.

Is Montenegro subject to sanctions?

Partly. Montenegro has sectoral sanctions exposure rather than a comprehensive country-wide programme. Firms should screen applicable persons, entities and sectors against the OFAC, UK, EU and UN lists.

What is Montenegro's country risk rating?

RegActions rates Montenegro at 6.0/10 (High risk), where a higher score means higher country risk. The score combines financial crime controls, government effectiveness and rule of law, and international sanctions. Transparency International's 2025 Corruption Perceptions Index scores Montenegro 46/100 (rank #65 of 182).

What due diligence applies to Montenegro?

Enhanced due diligence. This is decision-support based on Montenegro's FATF status, governance and sanctions signals, and is not a substitute for a firm's own risk assessment.

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)