Financial Crime World

AML/CFT Framework Review: Montenegro’s Missing Pieces

Montenegro’s anti-money laundering (AML) and combating the financing of terrorism (CFT) framework is still incomplete, despite progress made in recent years. The country’s financial intelligence unit (FIU) has been established, but other essential components are lacking.

Post Offices and Precious Metal/Jewellery Dealers at Risk

Montenegro’s AML/CFT regime lacks specific provisions for confiscating the proceeds of crime or property used to finance terrorism. This puts post offices, persons engaged in buying and selling precious metals and jewellery, exchange offices, pawnshops, gambling rooms, betting places, slot machine clubs, lotteries, real estate agents, and traders in arts and antiques at risk.

Money Remitters, Accountants, Auditors, and Lawyers Should be Included

The AML framework also fails to include money remitters, accountants, auditors, and lawyers, who are critical players in the financial system. Their inclusion would help prevent money laundering and terrorist financing.

Criminial Justice Measures and International Cooperation Needed

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Montenegro’s criminal justice measures and international cooperation in AML/CFT are also lacking. The country has not criminalized the financing of terrorism, and there is no provision for confiscating money intended to finance acts of terrorism. This makes it difficult to implement United Nations resolutions on freezing terrorist-related assets.

Recommendations

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To strengthen its AML/CFT framework, Montenegro should:

  • Establish a fully-pledged FIU with adequate resources and powers.
  • Include specific provisions for confiscating the proceeds of crime or property used to finance terrorism in the criminal code.
  • Provide law enforcement and prosecution authorities with sufficient powers and duties to effectively combat money laundering and terrorist financing.
  • Ensure that money remitters, accountants, auditors, and lawyers are included in the AML framework.

By addressing these gaps, Montenegro can improve its ability to prevent and detect money laundering and terrorist financing, and bring its AML/CFT framework in line with international standards.