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IMF Country Report No. 25/83
MONTENEGRO
CENTRAL BANK TRANSPARENCY CODE REVIEW
April 2025
This paper on Montenegro was prepared by a staff team of the International Monetary Fund. It is based on the information available at the time of the mission and it was completed on March 20, 2025.
Copies of this report are available to the public from
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© 2025 International Monetary Fund
Title page
MONTENEGRO
CENTRAL BANK TRANSPARENCY CODE REVIEW
March 20, 2025
DETAILED REVIEW REPORT
Prepared By
Monetary and Capital Markets, Finance, and Legal Departments
This Detailed Review Report was prepared based on the work of a hybrid IMF mission to Montenegro in June and September 2024. The IMF team for the Central Bank Transparency Code (CBT) Review mission was led by Cecilia Melo Fernandes (Mission Chief, MCM) and comprised Elie Chamoun, Deputy Mission Chief (FIN); Hans Weenink, Luis Jacome, Mohammed Janahi, Sylvain Choquette (IMF External Experts), Kei Moriya (ITD); and jointly overseen by the Monetary and Capital Markets Department and Legal Departments, IMF.1 The production assistance was provided by Julie Vaselopulos.
The team extends its warm appreciation to the Council, senior management, and staff of the CBCG, who provided excellent cooperation, and to outside stakeholders and interested public for their valuable views and insights.
Contents
Glossary
EXECUTIVE SUMMARY
KEY RECOMMENDATIONS
SCOPE AND OBJECTIVE
APPROACH AND METHODOLOGY
BACKGROUND
MAIN FINDINGS
A. Pillar I. Transparency in Governance
B. Pillars II, III, and IV. Transparency in Policies, Operations, and Outcome
C. Pillar V. Transparency in Official Relations
D. Quantitative Insights for Transparency Practices
QUANTITATIVE INSIGHTS FOR TRANSPARENCY PRACTICES
AUTHORITIES’ RESPONSE TO DETAILED REVIEW REPORT
BOXES
1. Central Bank Mandates in Euroized Economies
2. Predicting the Participation of Individuals in CBCG's Public Discussions and Consultations
FIGURES
1. Evolution of CBCG's Press Releases
2. Overall Focus of CBCG's Press Releases
3. Top Popular Topics by Public Interest
4. Information on Key CBCG Publications (Average Over Time)
5. Flesch Readability Ease Score
6. Sentiment Analysis from CBCG Bulletin and Montenegro GDP Growth
7. CBCG Followers on Social Media
8. Key Topics that Attracted the Most Followers
9. QR Code to Household Survey
10. Survey Participants: Age Group Profile
11. Survey Participants by Level of Education
12. What are the Main CBCG's Functions?
13. What are the Main CBCG's Objectives?
14. CBCG's Awareness Index
15. CBCG's Knowledge Gap Index
16. Self-awareness Evaluation (Number of Replies)
17. Predictable Factors of Participation in CBCG's Public Discussions
18. Which CBCG Communication Channel are You Aware Of?
19. What Would be Your Preferred Communication Channel with CBCG?
20. Suggestions from Survey's Participants
TABLE
1. Central Bank Transparency Overview for CBCG
ANNEXES
I. CBCG: Central Bank Transparency Code—Detailed Review
II. List of CBCG Units and External Stakeholders
Glossary
| AML/CFT | Anti-Money Laundering and Combating the Financing of Terrorism |
| AML/CFT Law | Law on Prevention of Money Laundering and Terrorist Financing |
| APC | Agency for Prevention of Corruption |
| AC | Audit Committee |
| AFS | Audited Financial Statements |
| BCM | Business Continuity Management |
| CMAM | Capital Market Authority of Montenegro |
| CBCG | Central Bank of Montenegro |
| CAR | Central Bank of Montenegro Annual Report |
| CBCG Law | Central Bank of Montenegro Law |
| CBCG Public Officials | Governor, Vice-Governor, and members of the Council |
| CBT | Central Bank Transparency Code |
| Council | Council of the Central Bank of Montenegro |
| DM | Deutsche Mark |
| ECB | European Central Bank |
| ELA | Emergency Liquidity Assistance |
| ESCB | European System of Central Banks |
| ESG | Environmental, Sustainability, and Governance |
| EU | European Union |
| FAQ | Frequently Asked Questions |
| FRM | Foreign Reserves Management |
| FSC | Financial Stability Council |
| FSR | Financial Stability Report |
| FX | Foreign Exchange |
| GDP | Gross Domestic Product |
| IC | Investment Committee |
| IFRS | International Financial Reporting Standards |
| IMF | International Monetary Fund |
| IR | Inflation Report |
| ISAM | Insurance Supervision Agency of Montenegro |
| LCC | Law on Consumer Credit |
| LCI | Law on Credit Institutions |
| LFAI | Law on Free Access to Information |
| LLR | Lender of Last Resort |
| LPC | Law on the Prevention of Corruption |
| LPDP | Law on Personal Data Protection |
| ML/TF | Money Laundering and Terrorist Financing |
| MoU | Memorandum of Understanding |
| MOF | Ministry of Finance – Montenegro |
| NBFI | Non-Banking Financial Institutions |
| NPL | Non-Performing Loans |
| NLP | Natural Language Processing |
| SAIM | State Audit Institution of Montenegro |
| SDR | Special Drawing Rights |
The mission was backstopped from HQ by Dmytro Solohub and Mario Tamez (MCM and LEG, respectively).