AML / CFT · Legal obligation · Montenegro
AML procedures and training — preventing money laundering and terrorist financing
If you are an obliged entity under the Law on the Prevention of Money Laundering and Terrorist Financing, the paperwork is not a formality: a risk analysis, internal procedures, a compliance officer and trained staff are required straight away, and supervisors usually ask for them for the first time just when you do not have them.
Who is an obliged entity under the law
The law lists obliged entities in Article 4. It is not only about banks — the list includes businesses that rarely see themselves as "financial":
credit institutions and branches of foreign credit institutions; factoring and purchase of receivables, financial leasing, safe deposit box rental, issuing guarantees, lending and credit intermediation, currency exchange; payment institutions and electronic money institutions
Pošta Crne Gore (the Montenegrin postal operator); investment and pension fund management companies; investment firms providing capital market services
life insurance companies; insurance brokers and agents, as regards life insurance
gambling operators; pawnshops
exchange between virtual and fiat currencies and custodian wallet providers
forfaiting; audit firms and certified auditors; accounting; tax advisory services and advice on tax matters
services for forming legal entities and companies, business and fiduciary services; asset management for third parties
investment in, trade in and brokerage of real estate; brokerage of lettings where the monthly rent is €10,000 or more; construction of residential and commercial buildings
granting and brokering loans; issuing and managing payment instruments not covered by payment services regulations
trade in motor vehicles; trade in vessels and aircraft and related services; trade in and brokerage (including auctions) of works of art, precious metals, precious stones and other goods — where €10,000 or more is paid or received, in one or several linked transactions
storage and safekeeping of works of art and trade in art when carried out in ports, free zones or warehouses, with the same €10,000 threshold
A lawyer is an obliged entity when assisting a client in planning or carrying out transactions relating to the purchase and sale of real estate or a company, managing money, securities or other assets, opening and managing accounts, raising funds for setting up and running a company, or setting up and managing a company, fund or foundation — and when carrying out a financial or real estate transaction on the client's behalf. A notary is an obliged entity when drawing up notarial deeds and certifying documents relating to those transactions, as well as for loan agreements.
The Government may designate other obliged entities if the nature of the business carries a higher risk, and may exempt operators of certain games of chance (other than casinos) from part of the obligations where an assessment shows lower risk.
What the law requires from obliged entities
This is the minimum supervisors ask for — and the order in which we set it up:
Thresholds and deadlines you need to know
The most common mistakes are not in the documentation but in the deadlines — these are the ones that get checked:
Who supervises and what the penalties are
Supervision is divided by type of obliged entity (Article 131):
For offences under this law, a legal entity is fined €3,000 to €20,000, the responsible person in a legal entity and a natural person €500 to €2,000, and a sole trader €500 to €6,000. A ban on carrying out the activity or duty may be imposed in addition to the fine.
What we do for you
We do not sell a binder of templates — we set up what supervisors require, in a way that fits how you actually work:
An internal document with risk factors for your clients, countries, channels and products — in the form supervisors expect, with an annual update plan.
Policies and procedures, customer due diligence questionnaires, beneficial ownership records and reporting forms — adapted to your business.
Indicators for recognising suspicious clients and transactions that make sense for what you actually do.
Help with selection and appointment, a description of duties and training — including the deputy, who is most often forgotten.
Training for front desk, sales and management, with records and materials that stay with you. The statutory training and exam for the compliance officer are run by a licensed adult education provider — we prepare the candidate.
An internal check before an inspection, a review of records and help preparing the annual report.
Training — what we can do, and what goes through a licensed provider
Staff training is an obligation of the obliged entity: the law requires regular professional training and development of people who work with clients, and supervisors ask for proof that training took place. We deliver that training — for front desk, sales and client intake, for management and for the team around the compliance officer. It covers suspicious transaction indicators using your own examples, what to do when suspicion arises, the ban on tipping off a client that a report has been filed, and record-keeping. We run it in person in Podgorica and Bijelo Polje, and online for the whole of Montenegro.
Training for the compliance officer is a different matter. Under the law it is delivered by a licensed adult education provider, under a programme approved in advance by the financial intelligence unit. After the training the candidate takes a professional exam before a committee set up by the head of the financial intelligence unit, which issues a certificate of passing and then a licence valid for five years. We cannot replace that training and exam — what we do is prepare the candidate for the exam and build the whole system around it: risk analysis, procedures, indicators, records and inspection readiness.
Frequently asked questions
Is an AML system certified?
No. This is a legal obligation, not a standard that gets certified — there is no certification body and no certificate. What exists is supervision, which checks whether you have a risk analysis, procedures, a compliance officer, training and records. If you want a management system framework around it, that is ISO 37301 (compliance) or ISO 37001.
We are a small accounting firm — are we obliged entities?
Yes. The law also treats sole traders and natural persons carrying out a business activity as obliged entities, so accounting and audit services, tax advice, real estate brokerage and a range of other activities are included — regardless of the number of employees.
Who can be a compliance officer?
A person who has completed compliance officer training, passed the professional exam and received a licence from the financial intelligence unit; the licence is valid for five years and can be renewed. In addition, the person must not have been convicted of a criminal offence punishable by more than six months' imprisonment and can be the compliance officer for only one obliged entity. For obliged entities with four or fewer employees, the director may perform these duties under the same conditions, and a deputy is then not mandatory.
What do supervisors ask for first?
The risk analysis and the date of its last update, internal procedures, the decision appointing the compliance officer and deputy, training records, the indicator list and customer due diligence records. The deadline for submitting what is requested is eight days from the request.
What are the penalties?
For a legal entity the fine is €3,000 to €20,000, for the responsible person in a legal entity and a natural person €500 to €2,000, and for a sole trader €500 to €6,000. A ban on carrying out the activity or duty may also be imposed.
How much do compliance work and training cost?
It depends on your business, the number of employees and whether you have any documents at all. Send a short description of your business — you will get the scope of work and a price, with no obligation.
📋 Check the exact price for your organisation →Related pages
What goes well with AML obligations:
Industries where this is most often required:
Some of our references
More than 400 organisations in Montenegro and the region have gone through implementation with us — from banks and public bodies to manufacturing, IT, laboratories and hospitality.
These are only some of our clients. More about us →
Are you an obliged entity — and do you have the paperwork?
Tell us when your deadline is and what it concerns — we will propose a preparation plan that gets there in time. Call us or send an inquiry — we reply within 24 hours.