Montenegro currently lacks a fully established financial police unit and effective oversight of cryptocurrency activity, exposing significant institutional gaps in the country’s ability to investigate financial crime and enforce anti–money-laundering standards. Despite repeated announcements and strategic planning, the legal and organisational framework needed to fight complex financial offences — particularly those involving digital assets — has not yet been put in place.
Years of official pledges to create a dedicated financial police modelled on Italy’s Guardia di Finanza have not yet translated into concrete legislative action or operational structures. Although cooperation with the Italian financial police has been discussed at high political levels, Montenegro has no legal basis yet to establish a domestic financial police force with clear investigative mandates and enforcement powers. The idea of such a unit has been included in government policy documents, but there is still no law defining its authority, institutional procedures, or cooperation mechanisms with prosecutors and other agencies.
At the same time, the rapid growth of cryptocurrency use — both legitimate and illicit — has outpaced Montenegro’s capacity to supervise this emerging market. While amendments to the anti–money laundering law in March 2025 brought certain crypto asset activities under basic regulatory standards, there remains no comprehensive national law on virtual assets and no official registry of licensed crypto service providers. This regulatory vacuum means that large segments of crypto trading and exchanges are conducted in grey market conditions, often outside formal supervision or record keeping.
The lack of formal crypto oversight has practical consequences for law enforcement. Authorities trained in blockchain analysis are reportedly unable to seize or manage digital assets because there are no established procedures for accessing national crypto wallets, confiscating digital property, or integrating these assets into criminal investigations. Without these mechanisms, investigators are constrained even when suspicious activity is detected, and major international cases involving cryptocurrencies remain difficult to pursue through the Montenegrin legal system.
International research and law-enforcement assessments have flagged Montenegro as vulnerable to misuse of digital assets for money laundering and illicit transfers, indicating that criminal groups have made use of legal gaps to move funds across borders with little oversight. In particular, decentralised and pseudonymous crypto transactions outside regulated exchanges can facilitate quick, hard-to-trace transfers, complicating efforts to detect and disrupt criminal finance flows.
Authorities have set the creation of new supervisory structures as a priority, with the Capital Market Commission tasked with organising crypto oversight within a legislated timeframe, and the government signalling intentions to finalise comprehensive virtual-asset legislation in 2026. However, until these reforms are enacted and implemented, both financial police capabilities and regulatory supervision over digital currencies will remain limited, leaving law enforcement at a disadvantage in confronting sophisticated financial and cyber-enabled crime.
