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  4. Crypto-Asset Service Provider Registration in Montenegro (Capital Market Commission)

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International Crypto Licensing

Crypto-Asset Service Provider Registration in Montenegro (Capital Market Commission)

What is the essence of Montenegro's regime?

Registration (upis) in the Capital Market Commission's register, under the crypto chapter of the AML law (articles 40a–40r). No dedicated crypto statute exists; no published fee and no capital requirement.

Does a European authorisation work automatically there?

No — Article 40a(2): even a CASP authorised by another Member State must enrol in the same register before serving Montenegro.

How is the application delivered?

Physically, on form Prilog I, with notarised declarations (max 1 month old) and record extracts (max 3 months); prior Beneficial Owners Register enrollment is required. No statutory decision deadline exists.

Who is in the register now?

One company — "Artenx" d.o.o. of Podgorica, since 31 July 2026; the Commission reports continuously receiving inquiries.

6 min·23 Sep 2026

The first and central fact this page must convey: Montenegro has no dedicated crypto-asset statute. International intermediaries market the country's "crypto product" under heavier-sounding labels, yet the only form the law provides is registration (locally, upis): enrollment of a crypto-asset service provider in the register of the Capital Market Commission (Komisija za tržište kapitala), under the crypto chapter of the money-laundering law. This page describes exactly that — nothing more and nothing less.

The practical profile of this registration: no published fee, no capital requirement, and a document file delivered physically, on paper — a combination that makes Montenegro the most budget-friendly official route in the region, covering ten MiCA-mirrored services. The register currently holds exactly one company — a first-mover market.

The Legal Basis: the Crypto Chapter of the AML Law

The operative regulation was created in February 2025 — amendments to the Law on the Prevention of Money Laundering and Financing of Terrorism (ZSPNFT), adopted by parliament on 28 February 2025 and published in the Official Gazette as 024/25 of 12 March 2025. Those amendments added the crypto chapter — articles 40a through 40r — governing the entire registration regime. A dedicated Digital Assets Law, drafted in 2022–2023, was never enacted; a future version may layer additional requirements on top — build that caution into your plan.

The register's keeper and supervisor is the Capital Market Commission (Article 131(1)(3) of the law; the supervised subject sits in Article 4(2), item 12). The register is public as to provider name and services (Article 40a(6)); it went live at the end of 2025 (Article 145c — within 9 months of entry into force). The law also carries over the EU transfer rule (TFR — Regulation (EU) 2023/1113).

Updated: 14 Oct 2026