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Montenegro has spent years presenting itself as one of Europe’s most crypto-friendly destinations. Prime minister Milojko Spajić has spoken openly about turning the Adriatic nation into a global blockchain hub, courting digital entrepreneurs and promoting the country as a low-tax base for technology companies looking for a foothold in Europe. Yet, despite its growing profile, Montenegro’s crypto market still operates without a comprehensive legal framework. The sector is governed largely through a patchwork of anti-money laundering (AML) provisions, making Montenegro less attractive to institutional investors while leaving it vulnerable to criminal activity. Montenegro’s crypto regulatory gap “Predictability, a clear licensing regime, a designated supervisory authority and effective legal remedies are the first things institutional players look for,” says Lana Vukmirović Mišić, a senior partner at JPM & Partners, a Montenegrin law firm. She notes that her firm recently advised a prospective client looking to establish a crypto payment service provider in Montenegro, who ultimately abandoned the project due to regulatory gaps and the absence of a complete legal framework. Until early 2025, Montenegro operated without basic rules for digital assets. Lawmakers eventually included cryptocurrencies into amendments to the Law on the Prevention of Money Laundering and Terrorist Financing. The changes introduced basic registration requirements for crypto-asset service providers, mandatory customer identification for larger transactions, and a supervisory role for the Capital Market Authority (CMA). The CMA maintains it has fulfilled its legal mandate. Since the official register became operational at the end of 2025, the authority has registered just one crypto-asset service provider, identified nine operating illegally without registration, and issued two public investor warnings. In a statement, the CMA emphasized that adopting a comprehensive legal framework governing digital assets would “provide greater legal certainty, strengthen investor protection, and support the orderly development of the market in line with international and European standards.” Under current law, registration with the CMA gives the state a mechanism to monitor crypto businesses from a financial crime perspective. However, it fails to create a complete financial architecture capable of supporting institutional investors, regulated stablecoins, or large-scale custody operations. Registration does not constitute a license or authorization as understood under the EU’s Markets in Crypto-Assets (MiCA) framework, nor does it allow a Montenegrin-registered entity to passport its services across the European Union. Billions beyond oversight The absence of heavy regulatory overhead and lower operational costs initially made Montenegro an attractive destination for Web3 projects, blockchain summits, and high-profile founders—including Ethereum co-founder Vitalik Buterin, who was granted Montenegrin citizenship in 2022. But alongside the tech-friendly marketing, Montenegro has also developed a sizable crypto trade operating outside formal oversight. Research by the Balkan Investigative Reporting Network (BIRN) revealed large, unregulated money flows passing through the country's crypto ecosystem. Approximately $2.17 billion in cryptocurrency transactions passed through digital wallets linked to Montenegro between late 2021 and late 2022. Much of the exchange between cash and crypto occurs via unregistered street dealers, online forums and Telegram groups operating entirely outside state oversight. In one case documented by BIRN, a single street-level dealer transacted over $17 million through a single digital account in just one year, illustrating the scale of transactions taking place outside the formal regulatory system. “This is a parallel economic flow about which our state knows nothing,” said BIRN Montenegro executive director Vuk Maras. “Cryptocurrency dealers no longer want to work with small amounts, but with tens of thousands of euros. This black market is huge and needs to be brought into legal channels.” The Montenegrin government’s 2024 Serious and Organized Crime Threat Assessment similarly warned that organized crime groups actively use cryptocurrencies to launder illicit funds. It also identified high-value, unmonitored crypto transactions involving purchases of luxury vehicles and real estate, predominantly by buyers from Russia, Ukraine and Cyprus. Closing the EU gap As part of its EU accession process, Montenegro will need to align its crypto-asset rules with the EU regulatory framework, including MiCA, moving beyond its current AML-based registration system toward licensing and authorization requirements. Full regulation is also essential if Montenegro hopes to fulfill its ambition of becoming a legitimate gateway for digital businesses operating between the Western Balkans and the EU. Some progress has been recognized. In its latest report on anti-money laundering and counter-terrorist financing measures, MONEYVAL, the Council of Europe’s monitoring body, upgraded several of Montenegro’s AML recommendations to “largely compliant”, reflecting progress since the 2025 reforms. The limits of Montenegro’s crypto push For international investors choosing where to incorporate, regulatory certainty often matters as much as low taxes. Montenegro offers low corporate tax rates and uses the euro despite not belonging to the eurozone—advantages that have helped it market itself as a business-friendly base for companies looking toward the European market. Yet the persistent lack of clear rules continues to undermine that appeal. Domestically, public understanding of the sector remains surprisingly low despite years of high-profile publicity. A nationwide survey conducted earlier this year revealed that over 93% of Montenegrins have little to no understanding of cryptocurrencies. Only 4% reported owning digital assets, while nearly three-quarters associated crypto primarily with speculation or criminal activity rather than technological innovation. Despite this skepticism, public demand for state oversight is overwhelming: more than three-quarters of survey respondents stated that Montenegro should immediately adopt comprehensive legislation to regulate digital assets. For now, Montenegro remains caught between its ambition to become a regional Web3 hub and a regulatory system that has yet to catch up. The country has put enough rules in place to bring crypto businesses onto the AML radar, but not enough to offer the licensing, investor protection and legal certainty that larger international players expect. As Vukmirović Mišić puts it, "The question is therefore not whether Montenegro will comprehensively regulate digital assets, but when—and how much investment it loses in the meantime."