---
title: "Crypto-Asset Service Provider Registration in Montenegro (Capital Market Commission)"
url: "https://legal.ge/en/service/crypto-blockchain-services-en/crypto-asset-service-provider-registration-in-montenegro-capital-market-commission-en"
field: "Crypto & Blockchain Services"
description: "Crypto-asset service provider registration in Montenegro: Capital Market Commission register, physical filing, one registrant so far. Legal.ge."
updated: "2026-10-15"
publisher: "legal.ge"
---

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

> Source: legal.ge, https://legal.ge/en/service/crypto-blockchain-services-en/crypto-asset-service-provider-registration-in-montenegro-capital-market-commission-en

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).

The full text is available on legal.ge after signing in: https://legal.ge/en/service/crypto-blockchain-services-en/crypto-asset-service-provider-registration-in-montenegro-capital-market-commission-en

### 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.