Montenegro — Country Risk Report

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

Moderate country risk, with AML/CFT effectiveness gaps. Montenegro's country risk score is 4.9/10, placing it in the moderate-risk band. The principal score driver is AML/CFT effectiveness, contributing 2.7 of 4.9 points. Separately, the treatment overlays show that Montenegro is not currently FATF grey- or black-listed, and that Montenegro has a sectoral sanctions programme. 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 on every relationship, with senior approval and enhanced ongoing monitoring.

At a glance

• FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
• Sectoral country-level sanctions programme identified; this is a legal treatment overlay and does not change the numeric country-risk score.
• Governance and institutions: 4.0/10
• Corruption (CPI 2025): 46/100, rank #65 of 182
• Enforcement data: not yet assessed (no RegActions coverage)

Country Risk Score: 4.9/10 (Moderate)

Higher score means higher country risk (global average 5.5). Full information available. Composite score. Strong supporting evidence. Enforcement activity and CPI are context only; FATF listing and sanctions are regulatory overlays except the labelled FATF listing status used where no mutual evaluation exists.

All three underlying risk pillars are available. All three underlying risk pillars are available and weighted using the published formula. Weight sensitivity 4.8–5.0/10.

How this score was calculated

• AML/CFT effectiveness: 6.1/10 — 45% of this score
• Technical compliance: 3.7/10 — 20% of this score
• Governance and institutions: 4.0/10 — 35% of this score

Sanctions treatment: Screen transactions and counterparties. FATF treatment: none.

Principal risk drivers

• AML/CFT effectiveness: 6.1/10 × 45% = 2.7 points
• Governance and institutions: 4.0/10 × 35% = 1.4 points
• Technical compliance: 3.7/10 × 20% = 0.7 points

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 (Enhanced): Verify ultimate beneficial ownership and control from more than one source.
• Payments and transactions (Enhanced): Review transaction purpose, counterparties and the full payment routing.
• Trade and export activity (Enhanced): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Elevated): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Elevated): Alert on ownership changes, new designations and status changes.

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.

• Committee of Experts on the Evaluation of Anti-Money Laundering Measures (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 country programme (legal treatment overlay)
• Corruption (CPI 2025): 46/100, rank #65 of 182
• Rule of law (WGI): 4.2/10 risk

Regulatory ecosystem and enforcement visibility

This evidence map is separate from Country Risk v3. It describes official mandates, publication access and RegActions coverage; it does not judge regulatory strength or add points to country risk.

Transparency Index: not scored · Evidence disposition: local-authority-evidence · Mapped official authorities: 4.

Evidence level: Level 1: Identity confirmed. The ladder uses the authority evidenceLevel schema directly and does not infer a level from a URL, site access or RegActions feed count.

1. 1. Identity confirmed — The authority and its mandate are evidenced by official directory provenance.
2. 2. Regulatory activity visible — A qualified authority-owned route has provisional dated activity in the first-page scan.
3. 3. Enforcement visible — A qualified authority-owned enforcement route has provisional dated activity in the first-page scan.
4. 4. Score eligible — Shown only when the authority evidence schema explicitly records score-eligible; no authority currently does.

Enforcement visibility: No authority is classified enforcement-visible or score-eligible in the authority evidence schema. Enforcement visibility remains unknown or limited to identity/activity evidence; this is not evidence of no enforcement.

Authorities and mandate evidence

• Capital Market Authority of Montenegro — Level 1: Identity confirmed · Official site access blocked

  Mandates: Securities · Access status: Official site access blocked · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

• Central Bank of Montenegro — Level 1: Identity confirmed · Official site reachable

  Mandates: Central bank · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  Publication candidates and qualification

  • Unqualified publication candidate: Questions and answers regarding the manner of application of the Decision on interim measures to reduce the adverse effects of the impact of the new coronavirus outbreak on the financial system after the mitigating measures to protect the population against communicable diseases

    Research candidate only; it is not promoted to an official enforcement or regulatory-update route.

    Route type: decision_register · Source scope: authority-owned · Qualification: manual-review-required · Provisional scan signal: no-dated-first-page-signal · Observed months: 0 · Latest observed month: unknown

• Department for the Prevention of Money Laundering and Terrorist Financing (DPMLTF) — Level 1: Identity confirmed · Official site could not be reached

  Mandates: Financial intelligence · Access status: Official site could not be reached · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: unknown · Latest observed month: unknown.

  Source access was limited during this research check, so activity remains unknown. This is not evidence of inactivity.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

  Activity and enforcement visibility remain unknown; this access limitation does not establish that the authority has no enforcement activity.

• Insurance Supervision Agency — Level 1: Identity confirmed · Official site reachable

  Mandates: Insurance · Access status: Official site reachable · Research/publication snapshot checked: 2026-08-20

  Official authority site

  Provisional first-page scan signal

  Signal: unknown · Observed month count: 0 · Latest observed month: unknown.

  No qualified authority-owned dated route supports an activity signal. This is not evidence of inactivity; blocked, external-context, low-frequency and unvalidated sources remain unknown.

  Scan contract and precision

  automated-first-page-date-scan · 2024-01 to 2026-08 · as of 2026-08-20 · month precision · first-page-only-unvalidated. This is not a validated engagement frequency.

  No publication candidate is qualified. Regulatory activity and enforcement visibility remain unknown.

Download regulatory ecosystem PDF · CSV · JSON

Sector exposure

• Banking & payments (Low): No FATF overlay and governance pillar within normal range
• Trade & export controls (High): Sectoral sanctions overlay restricts named trade sectors
• Crypto & virtual assets (Low): No FATF overlay and effectiveness pillar within normal range
• Real estate & luxury assets (High): BO subscore 7.1/10; CPI context 46/100
• State-linked & procurement (Low): Current risk pillars show no elevated procurement signal

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: Sectoral programme 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 2026-08-23)
• 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 2026-08-24; follow-up 2025-12; base assessment 2024-01
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-30

Contextual signals are public evidence only and do not change the current country-risk score.

Download evidence PDF · CSV · JSON

Contextual risk evidence (not scored)

These eight evidence families provide context only. They do not change the v3.1 headline score. Unavailable means no reviewed, country-comparable evidence is currently ingested; it does not mean the risk is absent.

• Organised crime: Not available. No reviewed country-level organised-crime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Fraud and cybercrime: Not available. No reviewed country-level fraud or cybercrime dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Terrorism and proliferation financing: Not available. No reviewed country-comparable terrorism/proliferation threat dataset is currently checked in; FATF listing status remains a separate overlay. Candidate sources are research leads only; they have not been ingested as evidence.
• Trafficking: Not available. No reviewed country-level trafficking dataset is currently checked in; no risk value is inferred. Candidate sources are research leads only; they have not been ingested as evidence.
• Financial secrecy and offshore exposure: Not available. No reviewed, licence-clean financial-secrecy index is currently checked in; jurisdiction type alone is not used as a proxy. Candidate sources are research leads only; they have not been ingested as evidence.
• Tax cooperation: Not listed in EU Annex I. Annex I is a political/legal tax-cooperation list, not a general AML, corruption, or country-risk score. Source
• Political stability and conflict: 72/100 WGI percentile. WGI is an institutional perception indicator, not a conflict event feed or a prediction of future violence. Source
• Beneficial ownership: Not available. The Open Ownership map is a live-register snapshot and absence means no register was identified in that snapshot, not that no register exists. Candidate sources are research leads only; they have not been ingested as evidence.

Regional peer scores

• Bosnia and Herzegovina: 6.0/10 (High)
• Bulgaria: 5.7/10 (High)
• Azerbaijan: 5.3/10 (High)
• Hungary: 5.3/10 (High)
• Ukraine: 5.3/10 (High)
• Albania: 5.2/10 (High)

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)