A method of money laundering in Montenegro: investments in real estate

The Moneyval Committee of the Council of Europe has warned of a high risk of money laundering in the real estate sector in Montenegro. The Moneyval report also highlights the risk of money laundering in the banking sector, casinos, and law firms. Transactions, investments, sales, and brokerage in the real estate sector pose a significant risk of money laundering. The risk is primarily due to the scale of the sector and the large number of suspicious operations involving real estate transactions. Typologies indicate that investing in real estate is the most common method of money laundering in Montenegro.

Some data also indicates that members of organized crime groups already possess certain amounts of cryptocurrency, which are used to purchase real estate and complicate the tracking of financial flows.

Moneyval also warned that the risk of money laundering in Montenegro is increasing due to drug trafficking, rising interest rates, tax evasion, and corruption. It is noted that a new risk of money laundering is the increase in the number and volume of deposits from foreign citizens who have moved to Montenegro after Russia's aggression against Ukraine. These funds are mainly placed in banks or invested in the real estate sector, which affects construction and real estate prices.

Moneyval also emphasizes that Montenegro has an effective level of control over potential terrorist financing, and that the National Security Agency (NSA) and the Special Police Unit monitor financial transactions and money transfers across borders, but do not take action to identify other assets that may be used for financing terrorism.

On December 8, 2023, the media reported on the possible inclusion of Montenegro in the so-called "grey list" of Moneyval due to poor results in implementing measures to prevent money laundering and financing of terrorism. However, Prime Minister Miloš Spajić stated on December 14, 2023, that the Council of Europe Committee for the evaluation of measures against money laundering and financing of terrorism decided not to include Montenegro in the "grey list".