Montenegro’s financial system processed an estimated $2.17 billion in cryptocurrency transactions linked to addresses associated with the country during a short period when the sector operated without a formal regulatory framework, raising new questions about the state’s ability to monitor digital asset flows and enforce financial oversight.
The estimate comes from an analysis by the Balkan Investigative Reporting Network (BIRN), which found that between November 2021 and 2022 cryptocurrency transactions worth more than $2 billion were connected to blockchain addresses linked to Montenegro, while national institutions had no comprehensive system for tracking such flows.
At the time, Montenegro did not have legislation specifically regulating digital assets. As a result, transactions involving cryptocurrencies could move through the financial ecosystem without systematic state monitoring, reporting requirements or official statistical records.
Officials from the Ministry of Finance acknowledged that the state does not maintain data on cryptocurrency transactions and is not formally required to do so under existing legislation. Other institutions, including the Central Bank and the Tax Administration, have also lacked comprehensive information on the scale of digital-asset trading linked to the country.
The absence of oversight reflects a wider challenge faced by smaller financial systems attempting to adapt to the rapid expansion of digital asset markets. Blockchain-based transactions are decentralized and often cross national borders, making them difficult to track using traditional financial supervision tools. Even law-enforcement agencies equipped with specialized blockchain analytics software say that such tools are designed primarily to investigate suspicious activity rather than measure the total volume of cryptocurrency flows associated with a country.
Despite this lack of formal oversight, cryptocurrency usage in Montenegro has been growing. Data from global exchange platforms suggest that thousands of residents participate in crypto trading. One estimate indicated that around 17,000 users from Montenegro were active on a major exchange platform, equivalent to roughly 3 % of the country’s population, although other estimates place the number of users closer to 7,200.
At the same time, parts of the crypto market in Montenegro operate in what analysts describe as a grey zone. Some exchanges take place through international trading platforms, while other transactions occur through informal networks such as unregistered dealers, online forums and messaging channels, where cryptocurrencies are exchanged for cash outside the traditional financial system.
This environment has drawn increasing attention from policymakers and regulators, particularly following several high-profile crypto-related cases involving individuals operating in Montenegro. The rapid rise of digital asset trading, combined with the absence of a comprehensive regulatory framework, has prompted calls for stronger oversight mechanisms and clearer rules governing virtual asset markets.
Montenegro has begun taking steps in that direction. Amendments to legislation on the prevention of money laundering adopted in March 2025 introduced initial provisions covering digital assets, aligning parts of the legal framework with international standards on financial transparency. However, a comprehensive law governing the broader crypto sector — including licensing of service providers and regulatory supervision — has yet to be adopted.
Experts argue that the next stage of reform will likely involve aligning Montenegro’s regulatory approach with the European Union’s Markets in Crypto-Assets (MiCA) framework, which establishes rules for crypto-asset issuers, trading platforms and service providers across the EU. For a country pursuing EU membership, adopting similar standards could become a key element of financial regulatory alignment.
The findings about billions of dollars in unmonitored crypto flows therefore highlight both the rapid growth of digital finance and the institutional gap that emerged while legislation struggled to keep pace with technological change. For Montenegro’s financial authorities, the challenge now lies in building a regulatory framework capable of overseeing a sector that has already moved billions through the global blockchain network.
