International Monetary Fund. Monetary and Capital Markets Department
The transparency of the Central Bank of Montenegro (CBCG)’s legal framework, its mandate,
autonomy, and decision-making arrangements have all been strengthened over time, but
further improvements are recommended. The most important room for improvement is for the
CBCG’s website to clearly explain that Montenegro’s unilateral euroization limits the scope for an
independent monetary policy and for the provision of ELA. That should be aligned with an enhanced
policy strategy, which should explain its operational framework and toolkit, helping the public
understand how policies are formulated and what to expect. In addition, it should ensure timely
publication of all its opinions on draft laws concerning the financial sector. The discussion on the
website of the CBCG’s existing functional autonomy could stress that the CBCG can perform its
mandate without prior approval needed from the Government. Finally, the CBCG’s transparency
could be enhanced by clarifying the function of the Governor’s Collegium and by publishing the
general act establishing the remuneration of the Governor, Vice-Governors, and Council members on
its website, along with existing links to their incomes and assets, which is already available in the
Anti-Corruption Agency website.
This Report assesses Observance of Standards and Codes on the Financial Action Task Force (FATF) Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) for Serbia and Montenegro. The assessment reveals that the AML/CFT regime of Serbia still lacks some essential components. On the repressive side, there is not a specific provision on the financing of terrorism. It is possible to confiscate the proceeds of crime, but it is not possible to confiscate money intended to finance an act of terrorism.