Montenegro: Central Bank Transparency Code Review
Author:
International Monetary Fund. Monetary and Capital Markets Department
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Publication Date:
04 Apr 2025
eISBN:
9798229005203
Language:
English
Keywords:
CBCG Law; transparency practice; governance arrangement; anti-corruption framework; risk exposure; Anti-money laundering and combating the financing of terrorism (AML/CFT)
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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.

Executive Summary

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.

To boost its governance transparency framework, the CBCG should place more emphasis on risk management, institutional accountability, and human capital. An institutional view of the central bank’s financial and non-financial risk exposures could be outlined in a dedicated chapter on risk management in the annual report and a broader section on the website. Additional transparency on internal and external audits, as well as their oversight arrangements by the Audit Committee of the Council, is also needed. Many of these additional disclosures are quick wins for the CBCG, as the practices are already in place and functioning well. Moreover, the CBCG should consolidate information on its human capital into a single webpage covering careers, human resources management, recruitment, retention, compensation packages (e.g., salary bands by level/category of employee), including details such as gender breakdown by job classification, and staff turnover analysis.

The CBCG’s transparency practices for FX reserve management could be improved with a few changes in the framework. Key governing documents, i.e. the Guidelines for International Reserves Management and the Investment Committee's Terms of Reference, should be published. Increased transparency would benefit from a systematic presentation of (i) all risks; (ii) portfolio performance (both relative and absolute); and a description of the market environment in the annual report. Additionally, greater disclosure on the oversight framework and ex-post analysis of investments, including the rationale behind benchmark selection, would significantly enhance transparency.

The CBCG strategic communication plan should include clear objectives and measurable targets, utilizing quantitative tools to enhance its effectiveness. To effectively assess its progress and impact, specific objectives should be defined, such as increasing public awareness of its policies by a certain percentage along with measurable targets, like the number of successful outreach initiatives or improvements in stakeholder engagement metrics. Data-driven approaches, including survey insights and audience analysis (as outlined in this report), will enable the CBCG to accurately measure and optimize its communication strategy objectives. In addition, the CBCG should consider updating the website for clearer communication with stakeholders and the public, using simplified language, visuals, and dashboards to disseminate core messages, while also providing report schedules, standardizing press conferences, and establishing guidelines for public appearances and social media conduct.

The CBCG should enhance the transparency of macroprudential policy and increase the frequency of the Financial Stability Report, a key publication aligned with its mandate. While the CBCG explains what macroprudential policy is and how the different instruments relate to the macroprudential objectives, it does not place this framework in the context of Montenegro’s economy. In addition, the CBCG should better disseminate its assessments about the soundness of the financial system in its Financial Stability Report. Despite being its flagship publication, it is conducted only once a year, and its main findings are not widely shared.

CBCG’s progress in improving financial integrity transparency is notable, although additional disclosures are needed in relation to AML/CFT supervision and related internal controls. CBCG’s AML/CFT supervisory function is largely transparent, but disclosures are needed in relation to AML/CFT processes and outcomes. The CBCG’s website provides easy access to AML/CFT laws and guidelines, including general guidance on the CBCG’s supervisory approach and different types of supervision. Financial integrity transparency can be further improved with additional disclosures of sanctions and the results of sectoral AML/CFT risk assessments. The CBCG’s internal AML/CFT control framework related to its activities that could give rise to money laundering and terrorism financing (ML/TF) activities is not disclosed.

The CBCG demonstrates adequate transparency in its consumer protection operations, however, further clarity is needed in the anti-corruption framework. Rights of financial consumers are well publicized and reinforced with strong supervisory processes. Outcomes are disclosed in the annual report and the framework could be enhanced by disclosing the names of sanctioned entities and publishing additional guidance for dispute resolutions. While the anticorruption framework is in place, more clarity is needed to better explain its applicability to CBCG Public Officials and staff.

The mission team commends the CBCG’s substantial efforts to address numerous recommendations by the time of this publication. The report captures findings only up to the end of the mission2. The CBCG already started to address several of the recommendations in particular in the areas of governance, autonomy, and anti-corruption, highlighting the CBCG's ongoing commitment to enhancing transparency and aligning with international best practices. Further improvements remain to be addressed in foreign exchange reserves, accountability framework, human capital, communications and in its AML/CFT supervisory processes.

Table 1.

Montenegro: Central Bank Transparency Overview for CBCG

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Key Recommendations3

1. The IMF recommendations encompasses several areas, such as the CBCG's mandate concerning euroization, governance, risk management, and anti-corruption frameworks, along with the consolidation of human capital information and communication strategies, some of which the CBCG has already begun to implement.4 Furthermore, the IMF encourages the CBCG to enhance transparency in the management of foreign exchange reserves and in its AML/CFT supervisory processes. Although the CBCG has made strides in implementing recommendations related to governance, autonomy, and anti-corruption, it remains committed to addressing the subsequent recommendations in the other areas as well. Most "core" practices are concentrated within Pillars II (Policies) and IV (Outcome), while Pillars I (Governance), III (Operations), and V (Official Relations) tend to feature assessments categorized as expanded or comprehensive.

2. Further improve transparency on the CBCG’s mandate as it relates to the unilateral euroization of Montenegro. For example, by: (i) explaining how the euro has been introduced as sole legal tender in Montenegro; and (ii) explaining the limited scope resulting from the euroization for the ability of the CBCG to conduct independent monetary policy and to provide discretionary ELA to banks.

3. Enhance the description of the CBCG’s existing autonomy. For example, by including: (i) a description of the CBCG’s functional autonomy that emphasizes the prohibition of the State to approve CBCG decisions; and (ii) the personal autonomy by including a link to the general act establishing the remuneration of CBCG Public Officials, as well as a link to the information on their assets and incomes that is available on the website of the Agency for Prevention of Corruption (APC).

4. Improve transparency on the CBCG’s governance. For example, by including: (i) information on the CBCG’s website regarding the role of the ‘Collegium of the Governor’; and (ii) an overview of governance arrangements in the Central Bank of Montenegro Annual Report (CAR).

5. Going forward, providing transparency on the need to align the CBCG’s mandate in the Constitution and the CBCG Law as envisaged in the ongoing EU accession negotiations.

6. Enhance transparency on risk management. For example, through disclosures on: (i) a high-level overview of key (financial and non-financial) risks clearly mapped to the CBCG’s mandate and tolerance towards these risks; (ii) the process, governance arrangements, and strategies to manage these risks. These additional disclosures and other emerging developments could be provided through a dedicated section on risk management in the CAR and on the website.

7. Improve transparency on the accountability framework. For example, by including in the CAR: (i) a dedicated section providing an overview of external and internal audit arrangements; (ii) a description of the oversight by the AC and a summary of its activities during the year; and (iii) a full set of AFSs along with the audit opinion by the external auditors.

8. The CBCG’s anti-corruption framework could be made more transparent. For example, by: (i) articulating more clearly the applicability of the Law on Prevention of Corruption (LPC) on CBCG Public Officials and staff; and (ii) provide additional information to clarify the varying requirements between the Code of Ethics and the more demanding LPC.

9. Consolidate information on human capital under one webpage dedicated to careers and human resources management, including aspects related to recruitment and retention, as well as professional and career development. Additional disclosures on CBCG’s employee management practices, including compensation packages (i.e., salary bands by level/category of employee), gender breakdown by job classification, and comparative analysis on staff turnover could also be considered.

10. Include clear objectives and measurable targets on the CBCG’s strategic communications plan, utilizing data-driven approaches to quantify them. The plan should set specific goals, like increasing public awareness of policies, and use measurable targets to assess progress. Data-driven methods could be implemented to refine the communication strategy including surveys and audience analysis. The CBCG should update its website for better communication with traditional stakeholders and the broad public, using simplified language, visuals, and dashboards to clarify objectives, and provide publication schedules for reports. In addition, press conferences should follow a standardized format, and clear guidelines for public appearances as well as communication crisis management should be established.

11. Enhance the FX reserves management framework’s transparency. For example, by: (i) correcting and updating the ‘Decision on International Reserves Management’; (ii) communicating all the non-market sensitive elements of the ‘Guidelines for International Reserves Management’; and (iii) publishing the IC’s terms of reference.

12. Improve transparency related to AML/CFT supervisory outcomes. For example, by increasing the frequency of sanctions disclosures, including, without limitation: (i) the names of sanctioned entities and individuals; (ii) details of identified contraventions and proposed remedial plans; and (iii) progress of remedial plans implementation.

13. Improve transparency related to AML/CFT supervisory processes. For example, by periodically disclosing the results of offsite analysis and supervisory-level AML/CFT sectoral risk assessments.

Scope and Objective

14. In response to a request from the CBCG, the mission conducted a CBT review. The scope of the review covers all the CBT principles, save for those actions that are not performed by the CBCG.

15. This review is intended to allow the CBCG to evaluate its transparency practices, with a focus on identifying both its strengths and its areas for improvement. The review compares the CBCG’s transparency choices to the range of best practices detailed in the CBT, which cover transparency in: (i) governance; (ii) policies; (iii) operations; (iv) outcomes; and (v) official relations. The review aims to help the CBCG in further strengthening its dialogue with stakeholders and in finding the proper balance between independence and accountability. While it is important to note that the CBT review is not an assessment of central bank policies, it is likely to benefit the CBCG’s efforts to advance policy effectiveness. The CBT’s range of practices is not intended to be a tool for ranking the transparency of central banks, as noted in the IMF Policy Paper Central Bank Transparency Code.

Approach and Methodology

16. The mission’s approach consisted of a desk review as well as in-depth discussions with the CBCG and its key stakeholders. The mission team conducted a preliminary desk review based on both publicly available information and the Self-Review Questionnaire responses provided by the CBCG prior to the mission.5 The desk review formed the basis for discussions with the CBCG’s management and staff—and for meetings with the key stakeholders (from the public and private sector, including academia, and journalists).6 The meetings enabled the mission to collect views on, and to better understand, experiences with the CBCG’s transparency practices. The mission conducted 52 meetings (in both hybrid and virtual format) over two weeks. The meetings with key stakeholders were planned in coordination with the CBCG, though the CBCG’s staff did not attend those meetings. The team greatly appreciated the very high quality of cooperation, including the provision of responses to the Self-Review Questionnaire, documentation, and technical support, as well as the CBCG’s facilitation of the mission meeting schedule. It extends its warm thanks to the staff of the CBCG.

17. The review was conducted principle-by-principle, taking into consideration the relevant dimensions of transparency. The review maps the CBCG’s transparency practices across a range of best practices and was conducted in the context of the CBCG’s legal mandate and policy context, as well as the prevailing general legal framework. The review considered several important dimensions of transparency, including: (i) timeliness; (ii) periodicity; and (iii) quality of disclosure. The latter covers both accessibility and ease of understanding, especially by the general public. The review also considered the views expressed by CBCG stakeholders.

18. In addition, the mission employed quantitative methods to the greatest extent feasible to assess qualitative factors such as clarity, accessibility of information and sentiment analysis in the CBCG’s disclosures. Transparency in central banks’ publications goes beyond simply providing information; it requires the information to be clear and accessible. To assess that dimension of transparency, the following methods were applied: (i) Flesch Score index to assess the level of readability of the key CBCG reports; (ii) analysis of document structure to assess the accessibility of CBCG’s publications, checking for multilingual support; (iii) Natural Language Processing (NLP) to extract insights and gauge the overall tone and sentiment of the reports, which can be directly related to economic cycles; and (iv) analysis of tracking visits and "clicks" on key links to gain insights into public engagement with press releases and social media.

19. Finally, a household survey was conducted for the first time in Montenegro, and econometric models were used to extract key insights which are useful to improve CBCG’s communication strategy. The survey was conducted online, with the IMF setting up the infrastructure and the CBCG assisting in disseminating the link. The survey was entirely in Montenegrin and remained accessible for one week, and users could easily access it through a QR code. Based on the responses, two indexes were developed to assess the participants' level of knowledge regarding the central bank. In addition, methodologies such as multinominal logit regressions were performed on the collected data to better understand public behavior and support the CBCG in refining its communication strategy.

Background

20. The COVID-19 pandemic and Russia’s invasion of Ukraine have had significant repercussions for the Montenegrin economy. As a small open economy with high dependence on tourism revenues, the country was hit hard by COVID-19 with GDP plunging by 15 percent in 2020. The authorities responded to the shock by introducing various crisis support measures and securing emergency financial assistance of SDR 60.5 million from the IMF under the Rapid Financing Instrument. The strong recovery of tourism, followed by the influx of relatively affluent Ukrainians and Russians amid Russia’s invasion of Ukraine, stimulated growth rebound in 2021–22, resulting in record-high inflation since the country’s independence. In 2023, Montenegro's economy experienced strong growth at a rate of 6.3 percent, buoyed by solid consumption and tourism earnings surpassing levels seen before the pandemic. Unemployment rate dropped to its lowest ever. A significant reduction in inflation was facilitated by declining global food prices. Economic growth is anticipated to slow to 3.7 percent in 2024–25 and further decelerate to approximately 3 percent over the medium-term. The longer-term economic outlook heavily depends on the EU accession schedule, authorities’ efforts to engineer structural reforms and certainty around political developments.

21. The financial sector appears to have withstood the consecutive shocks well. The banking sector has effectively navigated recent challenges. Despite the end of COVID-19 support, the NPL ratio is decreasing, capital adequacy far exceeds the required minimum, and a surge in deposits has ensured ample liquidity. Meanwhile, banks are experiencing record profitability, thanks to expanding net interest margins. The regulatory and supervisory framework has been significantly strengthened in recent years in line with the recommendations of the Financial Sector Assessment Program conducted in 2015–16. The undercapitalized banks were resolved, the financial safety net strengthened, and a new risk-based AML/CFT framework was introduced. Given ambitious EU accession plans, the authorities strive to bring financial regulations and supervision practices fully in line with current EU frameworks and other international standards.

22. Fostering and maintaining financial system stability is the primary objective of the CBCG. The CBCG also has an objective of contributing to achieving and maintaining domestic price stability and, without prejudice to these objectives, supporting the government’s economic policy goals. The CBCG performs a relatively broad set of functions, including banking supervision and resolution, payment systems’ oversight, FX reserve management, protection of rights of financial services’ consumers, etc. With the goal of preventing or mitigating systemic risks in the financial system, the CBCG also acts through the FSC, established in 2010, and comprised of representatives of the CBCG, the MOF, CMAM, and ISAM.

23. In June 2012 negotiations commenced between the EU and Montenegro on the latter’s candidacy for membership of the EU. These negotiations are currently ongoing and according to public statements by the European Commission, 33 Chapters of the negotiation framework have been opened, of which three Chapters have now been provisionally closed. The CBCG informed the mission that the negotiations are expected to be concluded in 2026. The CBCG is actively involved in these negotiations and has been nominated to lead the talks regarding three negotiation chapters on which the negotiations are continuing: Chapter 4 on free movement of capital, Chapter 9 on financial services and Chapter 17 on Economic and Monetary Union. Prior to EU membership the Government of Montenegro unilaterally decided in 2002 to introduce the Euro as the sole legal tender in Montenegro. This unilateral euroization has an impact on Montenegro’s economy and financial system. Hence, Box 1 discusses the implications of this euroization on the CBCG’s mandate, operations, and governance.

24. While the legal framework of the CBCG has been strengthened with technical assistance from the IMF Legal Department, certain issues related to governance remain unaddressed. The first-time IMF safeguards assessment of the CBCG in 2021 found strong operational controls at the CBCG but identified weaknesses in, inter alia, independent oversight that is undermined by the structure of the CBCG’s Council, the appointment procedures for Council members, and the CBCG’s decision-making structures. The assessment recommended to introduce amendments to the legal framework to address these findings and to improve the autonomy. The legal amendments, a number of which are aligned with IMF Legal Department’s technical assistance, resulted in an amended CBCG Law that was published and entered into force on December 31, 2023; however, certain recommended legal amendments to strengthen the governance remain outstanding.

25. The domestic political fragmentation weighs on the CBCG’s governance arrangements and policies. After the collapse of two governments in 2022 due to no-confidence votes, lawmakers struggled to form a new government or initiate snap elections. Following presidential and parliamentary elections in 2023, a new parliamentary majority and government formation took place. The parliamentarians recently endorsed the proposal to eliminate double veto procedure for Governor’s nomination by excluding the President from the process.5 The CBCG management has also come under repeated attacks from politicians and media, blaming it for poor supervisory policies and lack of integrity. In December 2023, a new governor has been appointed to the CBCG through a parliamentary vote of 58–13, succeeding a failed effort by the country's former president to retain the prior governor in the position. Also, currently, the CBCG has only two Vice-Governors instead of the three prescribed by the CBCG Law: one Vice-Governor continues to act in his role despite the term having expired, while the other Vice-Governor is currently on leave. Proposals for the appointment of two Vice-Governors have been submitted to Parliament on August 27, 2024, with the expectation that the appointment by Parliament might be finalized by the end of the year. In addition, the CBCG currently only has two non-executive Council members, whose mandate expired in July, as opposed to the four prescribed by the CBCG Law.

26. The CBCG is committed to open and transparent communications. The CBCG’s website is the key communication tool with stakeholders, complemented by the CBCG CAR, monthly Governor’s Report and a handful of policy and analytical publications (IR, FSR MR, Price Stability Report, and Bulletin). Once a year the CBCG publishes its work program for the next 12 months, outlining its policy priorities. During the COVID-19 pandemic the CBCG regularly engaged with the public via various communication channels to increase awareness and understanding of the CBCG policies and actions. As part of its program of improving financial literacy and economic knowledge in the society, the CBCG conducts a number of financial education activities through its Money Museum, participates in the Global Money Week and the World Savings Day, and publishes CBCG’s Financial Entertainer, which is an educational and entertainment magazine for children.

Main Findings

A. Pillar I. Transparency in Governance

Legal Structure, Mandate, and Decision-making

27. The legal structure of the CBCG, including its legal framework, autonomy and decisionmaking structures are all well disclosed on its website, but further improvements are needed. The CBCG’s transparency could be enhanced by including on its website links to applicable legislation such as the Constitution of Montenegro. An explanation of the limited scope of audits by the State Audit Institution of Montenegro (SAIM) could also be included on the CBCG’s website. The function of the Governor’s Collegium, which is provided for in the Statute of the CBCG, could be better explained on the CBCG’s website. As regards the translated version of the CBCG Law (the mission could not verify the original version), the numbering of the articles in its two Chapters that are applicable to the CBCG: (i) after Montenegro accession to the EU; and (ii) subsequently after the CBCG becomes a member of the Eurosystem, is confusing. The discussion on the website of the CBCG’s existing functional autonomy could usefully stress that the CBCG can perform its mandate without prior approval from the Government. Finally, the general act establishing the remuneration of CBCG Public Officials could be published on the CBCG’s website. In addition, while the incomes and assets of the Council members are published on the website of the Agency for Prevention of Corruption (APC), their remuneration is only disclosed in aggregate form in the CBCG’s financial statements. The CVs of the non-executive Council members could be provided on the CBCG’s website, in addition to the CVs of the Governor and Vice-Governors that are already provided. Links to the aforementioned publications on the website of the APC could be made available on the website of the CBCG. In addition to these points on the website of the CBCG’s, the CAR also does not contain a developed section on governance, as is common in other central banks. Finally, as part of the CBCG’s strategic communication plan, which is under development as part of ongoing efforts to establish an overall strategic plan for the CBCG, the timeliness of the publication of CBCG opinions on draft laws concerning the financial sector could be stressed.

28. The CBCG’s website clearly discloses the CBCG’s mandate, but the discussion of the CBCG’s objectives and the limitations resulting from Montenegro’s unilateral euroization for the CBCG’s mandate could benefit from further explanation on the CBCG’s website. As noted, the legal framework is published on the CBCG’s website and both the hierarchy of the CBCG’s objectives and its core functions are discussed in a clear and easily accessible manner on the website. However, while the CBCG Law contains the hierarchy of the CBCG’s objectives, the Constitution is silent on such a hierarchy. Therefore, the CBCG’s website could usefully explain that one of the benchmarks included in the ongoing accession negotiations with the EU foresees the amendment of Montenegro’s Constitution to provide for a hierarchy of the CBCG’s objectives at a future date. Montenegro has unilaterally adopted the Euro as Montenegro’s sole legal tender. While a technical CBCG Working Paper on dollarized/euroized economies on the CBCG’s website explains that this policy choice implies a limited possibility for the CBCG to conduct an independent monetary policy and that this policy choice also limits the use of LLR, the subsequent presentation of the CBCG’s monetary policy instruments and ELA on the CBCG’s website does not explain how these limitations impact and limit said instruments.

Risk Management and Accountability Framework

29. Increased disclosures about risk exposures and governance would enhance transparency and accountability. The CBCG’s risk exposure is mainly focused on financial risks and disclosed as an integral part of foreign reserves management (FRM). In contrast, disclosures about overall risk governance and management of operational risk are limited. Specifically, the CBCG’s publications lack an institutional view on the CBCG’s risk management framework and respective governance arrangements, and they are not reflective of latest developments to strengthen risk management practices. To further improve transparency, the CBCG could consider disclosing information on: (i) all financial and non-financial risks as they relate to its mandate and the bank’s tolerance for these risks; (ii) the process, governance arrangements, main developments, and strategies to manage these risks. These additional disclosures could be provided through a separate chapter on risk management in the CAR, as well as a broader section on the website.

30. The CBCG discloses reasonably sufficient information on its financial activities and position in the AFSs and the CAR. The CBCG publishes a complete set of independently AFSs on its website. The financial statements are prepared in accordance with IFRS and accompanied by the external auditor’s report, which includes an external audit opinion referring to International Standards on Auditing. While financial reporting practices are comprehensive and the external audit mechanism is well-established, the CAR does not include, as a separate chapter, the full set of AFSs.

31. Additional disclosures on audit mechanisms and oversight arrangements are needed. The audit (internal and external) mechanisms and oversight of the latter by the AC are well established in the CBCG Law and explicitly disclosed on the CBCG’s website. However, disclosures about the same are lacking in the CAR. In addition, the limited scope of the audits conducted by the SAIM over the CBCG (i.e., excluding activities related to its mandate and functions) merits further clarification on the website and needs to be disclosed in the CAR. Transparency could be enhanced by including in the CAR: (i) a dedicated section providing an overview of external and internal audit arrangements; (ii) a description of the oversight by the AC and a summary of its activities during the year; and (iii) a full set of AFSs along with the audit opinion by the external auditors.

32. Consideration should be given to increase transparency on governance and the management of human capital. The CBCG discloses (on the website and in the CAR) an array of references to legislation and internal regulations on the management of its human resources, including job classifications, staff composition, competencies, and professional development. That said, other important aspects such as diversity and inclusion or leadership and succession planning are lacking, and the disclosures on the website are dispersed across different sections and not consolidated under a specific section.

33. Transparency would be enhanced by consolidating information on human capital under one webpage dedicated to careers and human resources management, including aspects related to recruitment and retention, as well as professional and career development. In particular, the CBCG could use this as a platform to promote its intended strategy of being an “employer of choice” and provide details about: (i) current openings; (ii) partnerships and concrete programs to support diversity and inclusion; and (iii) recruitment programs, including scholarships/internships. In addition, disclosures could be enhanced across a number of dimensions on CBCG’s employee management practices, including compensation packages (i.e., salary bands by level/category of employee), gender breakdown by job classification, and comparative analysis on staff turnover and evolution of the workforce. Going forward, as the human resources function is expected to support the CBCG in implementing its forthcoming strategic plan, disclosures in this area should also evolve to provide additional quantitative measures that tie back to the said plan.

34. CBCG is generally transparent about its anti-corruption efforts, although disclosures on the applicability of anti-corruption legislation and the overall coverage of the CBCG’s Code of Ethics could be improved. The LPC is published on the CBCG website, a Montenegrin language version only, and applies to CBCG Public Officials only, excluding all other employees. This distinction in applicability is not immediately disclosed and transparency could be enhanced by explicitly setting out any immunities and/or exclusions. While the CBCG’s Code of Ethics, published on the CBCG website, largely emulates the provisions of the LPC, important key measures are lacking, including on pre- and post-public employment (i.e., cooling off periods), periodic asset declarations, and periodic declarations of compliance with the Code of Ethics. As such, transparency regarding the anticorruption framework could be improved if this variation was articulated more clearly. Furthermore, the internal process for handling whistleblowing reports is not disclosed and could be made more transparent.

Communications

35. For the first time, the CBCG Communication Department is developing a strategic communication plan. The document will address institutional affairs, public relations, and mass media strategies, focusing on tailored communication initiatives to enhance public engagement. Further details on its implementation were not yet available during the mission. The CBCG provides information on its communications function and while it follows clear legal guidelines for reporting and data accessibility, it does not disclose detailed internal principles, guidelines, or processes for external communication. The new CBCG communications strategy should have clear objectives and where possible, measurable targets. It should document its communication processes and integrate them into core activities like supervision, financial stability, and issuing opinions.

36. The CBCG has clearly identified with its target audiences and utilizes a wide range of tools to engage with them effectively, but key improvements could be included in its new strategy. For example, key website sections should be updated to better reflect the actual level of communication efforts of the CBCG towards media engagement. Although access to information requests are managed transparently, the publication schedule of the reports could be improved by offering clear publication dates, and press conferences should adhere to a pre-defined format with a structured Q&A session for transparency. Finally, the CBCG should set guidelines for public appearances by policymakers, including the Governor, Vice Governors and staff, with clear social media conduct rules. In addition, regular updates on key topics and crisis protocols for handling misinformation are crucial to protect its reputation.

37. Tailored and well disseminated communication to the targeted audiences, including simplified explanations or videos on the CBCG’s objectives would enhance the public understanding and accessibility of information. Transparency in reports goes beyond simply providing information; it requires the information to be clear and accessible. To achieve that, the CBCG could prepare messages based on its key contents and publications with a simpler language with the help of illustrations to access a broader audience. In addition, the CBCG could conduct regular surveys to continue assessing public literacy on CBCG topics, which could further inform communication improvements. Ongoing initiatives with children, youth, and academics should continue to foster education. Finally, the key reports—such as the FSR—should also be more advertised to the targeted audience via several channels, highlighting its key findings. Given its relevance and alignment with the CBCG’s objective and mandate, the CBCG should consider publish it more frequently than once a year.

Confidentiality

38. The CBCG has a confidentiality framework, stemming from the Constitution and further established by law. A dedicated section on the CBCG’s website provides an overview of the institutional arrangements on access to information and possible exceptions as a result of the confidentiality of, for instance, the privacy of personal data and commercial secrets, as well as monetary and economic policy, are anchored in the Constitution of Montenegro (Article 51) and the national LFAI. The application of this law is ensured through the CBCG’s “Rulebook on Secrecy”—akin to a policy on confidentiality—and a guide on classification of information and a step-by-step procedure to obtain access. The framework also regulates matters related to collection and protection of personal data. That said, free access to information is not absolute and remains subject to limitations that are also regulated. Transparency around the rejection of access is suboptimal and the CBCG could consider publishing a statement with the reasons for rejecting a request for free access when deciding not to allow access to certain information, and in cases for which it estimates that there is a high level of public interest. In addition, high-level information about requests for access to information, including topics and statistics about the responses of the CBCG could be provided through a summary in the CAR.

B. Pillars II, III, and IV. Transparency in Policies, Operations, and Outcome

Monetary Policy

39. The CBCG should articulate and disseminate a broad institutional policy strategy. This implies reiterating its mandate focused on preserving financial stability and stressing that, in practice, it has no capacity to formulate monetary policy owing to the official euroization of the economy. The policy strategy should also explain its policy and operational framework as well as the toolkit it has at its disposal, which is not used for monetary policy purposes and, instead, helps to preserve financial stability. CBCG’s communication should build on this institutional strategy, stressing the limits imposed by euroization for having a meaningful monetary policy. This is particularly important for accountability purposes as the CBCG is not responsible for inflation developments, which fundamentally come from abroad.

Montenegro: Central Bank Mandates in Euroized Economies

The government of Montenegro has unilaterally decided to Euroize the economy. Following hyperinflation in the 1980’s and 1990’s, Montenegro pegged the Dinar to the DM in December 1998. This was followed by the unofficial parallel circulation of these currencies until November 1999, when the DM was designated as legal tender in Montenegro alongside the Dinar. This lasted until January 2001 when the government of Montenegro first decided to introduce the DM as sole legal tender and then the Euro as sole legal tender in 2002.

The following reflections explain in general terms how Euroization limits the scope of a central bank’s mandate, including in Montenegro. Because such a central bank does not issue its own currency, it cannot set interest rates to manage inflation or stimulate economic growth. Thus, an independent monetary policy is not possible and there is also only a limited possibility for the central bank to act as a LLR. This dependence on a foreign currency makes the economy vulnerable to external shocks and to policy decisions made by the issuing country. Against this backdrop, such a central bank law should assign the primary objective to the central bank to foster and maintain a stable financial system. The central bank’s mandate to contribute to achieving and maintaining price stability should be understood as protecting the functioning of the payments system, strengthening banking supervision, and providing, to the extent possible, LLR assistance to credit institutions. Of course, the issuance of new domestic banknotes and coins is no longer possible within this context.

The governance arrangements of a central bank should reflect its mandate. For instance, the central bank decision-makers should have the relevant expertise to adequately implement the main objective of financial stability, and the decision-making bodies’ structure, functions, and operational arrangements should be designed accordingly. Also, because seigniorage does not exist, and as monetary policy operations cannot generate income either, the central bank is limited in its income generation and an alternative to ensure its financial soundness is needed.

Finally, as euroization is a monetary arrangement with specific characteristics, transparency is served by external stakeholders having a proper understanding of the limitations resulting from euroization for the central bank’s mandate and governance. In addition, to a clear explanation on the website, incorporating the principles elaborated here in the central bank’s legal framework will maintain the credibility of the central bank and help to clarify the scope of the central bank’s accountability.

Source: Economic Policy in Dollarized Economies with a Special Review of Montenegro, CBCG, Working Paper No. 1, 2004; Implementing Official Dollarization, L. Jácome and A. Lönnberg, IMF Working Paper No. 10/106, 2010 and Official Dollarization/Euroization: Motives, Features and Policy Implications of Current Cases, ECB Occasional Papers Series, No. 11/February 2004.

Cross-Border Financial Flows and Foreign Exchange Administration

40. The CBCG should clarify its framework for potential exchange controls. The Law on Foreign Current and Capital Operations stipulates that all current and capital transactions may be carried out freely by both residents and non-residents. The same law provides for the implementation of FX controls if capital movements seriously jeopardize or threaten to jeopardize Montenegro’s monetary policy or financial stability. However, exchange controls are in principle not foreseen subsequent to an euroization and, a country that has chosen to unilaterally adopt a freely tradable foreign currency as legal tender will face significant policy and operational challenges if it tries to implement them.7 The CBCG should be transparent about these challenges to prevent misunderstandings regarding the availability of exchange controls as a remedial measure.

Foreign Exchange Reserve Management

41. The CBCG’s transparency practices for FX reserve management are reasonably well communicated but could benefit from further enhancements. The CBCG Law defines the CBCG’s objectives and eligible asset classes for its reserve management. The ‘Decision on International Reserves Arrangements’ (adopted by the Council) lists and defines the unidimensional risks to manage. However, key documents essential for ensuring an appropriate level of transparency regarding the framework are not published, inter alia, the investment guidelines and the Investment Committee (IC)’s Terms of Reference. The CAR discloses some information on some risks considered and some performance data. However, this document would gain from a more systematic presentation of: (i) all the risks; (ii) all the portfolios’ performances (relative and absolute); and (iii) a relevant description of the prevailing market environment. Finally, the financial statements provide other information on the performance and unidimensional risks. Greater disclosure regarding the oversight framework and ex-post analysis of the investments and their risks, particularly the rationale behind the benchmark selection, could significantly enhance transparency.

Financial Stability and Macroprudential Policies

42. The macroprudential policy framework published by the CBCG falls short of providing a comprehensive policy strategy that aims at preserving systemic financial stability in Montenegro. While it explains what macroprudential policy is and how the different instruments relate to the macroprudential objectives, it does not place this framework in the context of Montenegro’s economy. For instance, some of the CBCG’s analysis associates macroprudential policy with inflation, like the 2022 CAR, where the analysis addresses the causes of inflation and contends that “the instruments of monetary and macroprudential policy in Montenegro would not produce sufficiently effective results in reducing retail prices.” The need of providing a comprehensive macroprudential policy strategy is more important in a euroized economy, like Montenegro, because interest rates set by the ECB may at times place financial stability risks, which should be tackled through macroprudential policy measures.

43. The CBCG should enhance the explanation to the public about the soundness of the financial system. After the Governor of the CBCG attends Parliament following the submission of the FSR, this document is posted on the CBCG’s website. However, because it is its flagship publication, the CBCG should disseminate more widely its main findings, in particular the risks to financial stability, as well as the outlook and possible policy corrective actions if needed.

44. The CBCG could usefully conduct ex-post evaluations of macroprudential policies and disclose the results, hinting possible adjustments if necessary. Macroprudential policy, like other economic policies, is not exempt from potential costs, especially because decisions are often taken when the economy is growing and in situations which credit would be increasing at a rapid pace. In this environment, macroprudential policy may hamper the development of the financial system and the provision of services to the rest of the economy, thus hindering economic growth. Assessing the impact of policy decisions is thus warranted to minimize unintended costs. There is a burgeoning literature on macroprudential policy evaluation conducted by the BIS, ECB, IMF, and several central banks that the CBCG could use as a reference.8 Building on this analysis, the CBCG could disseminate the main takeaways.

Emergency Liquidity Assistance

45. The CBCG’s ELA framework is well communicated. The CBCG Law does not allow marketwide liquidity provision. On the other hand, Article 16 of the same law authorizes bank-specific lending. The different instruments available to provide credit to banks are detailed in a policy document as well as some of the ELA’s operational specificities. The CBCG is preparing a manual for publication on its website to cover all operational aspects of the ELA. The framework omits to consider and communicate the CBCG’s limited capacity to extend ELA due to the fact that it is euroized; this ELA capacity would be influenced by the CBCG’s financial soundness. This blind spot could accentuate a crisis if stakeholders were not initially aware that even legitimate requests for discretionary ELA could not be entertained in specific cases.

Financial Integrity

46. The CBCG discloses information relating to its policies and powers supporting its AML/CFT supervisory function, but additional transparency is needed with respect to the processes and outcomes of its supervisory efforts. The CBCG supervises the implementation of AML/CFT measures across banks and NBFIs. The CBCG exercises its supervisory powers through the AML/CFT Directorate and details on its general activities are available on the CBCG website. However, updated information on resource allocation is not publicly accessible, limiting insight into how CBCG allocates human and technical resources to AML/CFT supervision. The CBCG publishes information on supervisory sanctions within the CAR cumulatively by type of measure imposed, as well as remedial actions and implementation progress by providing information on follow-up inspections, it does not publish information on the names of sanctioned entities, details of the contraventions, and implementation progress. In mitigation, the new AML/CFT law which came into effect in 2024 widens the scope of sanctions disclosures and provides for case-by-case exceptions particularly where publication jeopardizes the stability of financial markets or an on-going investigation.

47. Although the CBCG publishes general guidance on its AML/CFT policies and provides guidance on implementing risk analysis, there is a notable lack of disclosure regarding the effectiveness of preventive measures applied by the private sector as the results of the supervisory-level AML/CFT sectoral risk assessment are not published. The number of completed onsite inspections is disclosed in the CAR without articulating the actual completion rate based on the number of planned inspections, notwithstanding a 100 percent completion rate factually during recent years. Information regarding the outcomes of offsite assessments, and related analysis, is not disclosed. While names of supervised entities are disclosed on the CBCG website, information regarding cross border activity is not available.

48. The CBCG’s internal AML/CFT control framework related to its activities that could give rise to ML/TF activities is not disclosed. The CBCG is exposed to such risks in respect to multiple functions, including its payment services and reserve management activities, and the Financial and Banking Operations Department applies measures to mitigate ML/TF risks. However, these measures are not disclosed. While the CBCG Law does not provision for this level of internal oversight, the CBCG should consider disclosing its internal AML/CFT control activities, their oversight and accountability within the organizational structure, and the human and technical resources allocated to perform the functions. Following the establishment of such a function, the CBCG would be able to improve transparency of its AML/CFT oversight by publishing information of the AML/CFT internal framework and periodically reporting on the results of the control activities.

Consumer Protection

49. Transparency related to CBCG’s framework for consumer protection is adequate and minor improvements should be considered. Consumer protection policies and processes are largely disclosed on the CBCG’s website, which includes a dedicated page for financial consumers’ rights and obligations. In addition to applicable legislation, the page includes relevant information for consumers before concluding agreements, guidance on submitting complaints, and an annually updated list of effective interest rates offered by credit institutions. Outcomes of the CBCG’s consumer protection operations are reported annually in the CAR, including details and statistics on inspection outcomes, sanctions, and complaints handling. CBCG could enhance the consumer protection transparency by: (i) disclosing the names of sanctioned entities; (ii) publishing additional guidance on methods of out-of-court dispute resolution before relevant arbitration bodies; and (iii) explaining the CBCG's role in the Central Consumer Protection Information System.

C. Pillar V. Transparency in Official Relations

50. While the CBCG discloses its relationship with domestic and foreign financial institutions, as well as with semi-public entities, there is still room for improvement, in particular with respect to the government. For instance, the confidential character of the Agreement between the CBCG and the MOF, by which the CBCG performs the duties of banker, depository, and fiscal agent, as well as the tariff that is calculated for the services rendered, should be reviewed to make public this information, thus enhancing the transparency of the relationship between the CBCG and the government.

D. Quantitative Insights for Transparency Practices

51. The CBCG should enhance its communication channels by tailoring messages to different target audiences and prioritizing more press releases that highlight key publications and main findings. This would underscore the CBCG's efforts to fulfill its mandate and provide timely updates on the economy’s status. The CBCG utilizes a diverse range of communication channels to engage with the public, ensuring broad outreach. Recently, the CBCG has also increased its presence on social media, an initiative that is encouraged to expand further in order to attract more followers and foster greater engagement across all platforms, thereby strengthening its connection with the public. Additional initiatives are encouraged to attract more followers and engagement in all platforms. They include for example, engaging in communication for the broad public regarding its core messages, objectives and functions using simplified language, visuals, explainers and dashboards to enhance accessibility.

52. For the first time, the IMF, in collaboration with the CBCG, conducted a survey targeting households in Montenegro, which provided insights about the public understanding about the central bank and helped to predict their behavior regarding CBCG’s public and educational initiatives. Based on the data from the survey, indexes to evaluate the audience’s awareness and knowledge gaps were created, which are useful to evaluate the effectiveness of the CBCG’s engagement in enhancing the literacy of the audience once it is repeatedly conducted over time. In addition, econometric method allowed the prediction of public behavior regarding central bank initiatives. While there is a reasonable understanding of the CBCG's core functions, misconceptions about its objectives remain, with nearly 50 percent of respondents exhibiting low or very low awareness. A key challenge for the CBCG is to engage those who are less informed, less aware, and have lower levels of education in consultations and discussions. In contrast, individuals with higher education levels, greater confidence in their knowledge, and more awareness are more likely to participate in CBCG-organized consultations and discussions.

Quantitative Insights for Transparency Practices

53. Data driven analyses are crucial for enhancing transparency practices within the CBCG's communications strategy, which is currently under development. By leveraging data-driven analysis, the CBCG can better understand audience interests, identify the most popular topics, and tailor its messages accordingly. In addition, other insights allow for the assessment of the readability of reports, ensuring that they are accessible and comprehensible to a wider audience. Furthermore, analyzing the focus of press releases through quantitative metrics ensures that key economic and policy updates are prioritized and can resonate with stakeholders. Finally, surveys with the population further enrich this strategy, providing direct feedback on public perceptions, and insights to predict the audience’s behavior for example towards the central bank’s key initiatives, enabling the CBCG to fine-tune its communication methods and reinforce its commitment to transparency.

Data Extraction and Analysis of Existing CBCG’s Tools

54. The CBCG employs a diverse set of communication channels to engage with the public. The CBCG website has been the primary tool for communications, as it is the official portal for announcements, press releases, reports, data, and articles. The website is predominantly accessed by users in Montenegro, accounting for 69 percent of visits, followed by 17 percent from Serbia, 2 percent from Bosnia and Herzegovina, and 1 percent from Croatia, with the remainder spread mainly across other European countries. Most visitors access the site via mobile devices (57 percent), while 42 percent use desktop computers, and the remaining users access the site through tablets. Most visitors are primarily seeking information related to exchange rates.9 In addition to its website, the CBCG also engages with the media through interviews and by responding to inquiries. It is also involved in several projects aimed at promoting financial literacy with students of different age groups. Recently, the CBCG has increased its activity on social media, utilizing a variety of platforms to reach a wider audience.

55. The CBCG would benefit from prioritizing more press releases broadcasting its key publications as well as its main findings, highlighting its effort to achieve its mandate and the providing up-to-date status of the economy. Press releases and reports are vital communication tools for central banks, serving as official channels to disseminate timely and accurate information to the wide public, including media and stakeholders. Since 2010,10 the volume of communications increased significantly, reaching 94 press releases in 2023 and 95 by September 2024 (see Figure 1). Over time, the primary areas of focus11 of the CBCG press releases have been mainly focusing on international cooperation (33 percent) and public relations (24 percent)12 and internal meetings (14 percent), mainly informing the public about Council meetings. The remaining topics are concentrated on the CBCG’s decisions and key initiatives. Those are: announcements of measures to support the economy and financial sector (7 percent), decisions and ESG initiatives (6.5 percent), and clarifications and reiterating facts that are treated in a misleading way by the media (4.5 percent). In addition, the CBCG also promotes education and financial literacy through recognition and awards (3.4 percent) and engages in social campaigns, including donations (3.3 percent). Enhancing the dissemination of these topics rather than focusing mainly on public appearances on its press releases could enhance transparency and build public trust, allowing stakeholders to better understand its initiatives and their impact. Furthermore, it could help to promote financial literacy and engagement.

Figure 1.
Figure 1.

Montenegro: Evolution of CBCG’s Press Releases

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF staff calculations.
Figure 2.
Figure 2.

Montenegro: Overall Focus of CBCG’s Press Releases

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF staff calculations.

56. The highest level of public engagement in press releases is centered around household financial relief, consumer-oriented policies, and financial initiatives, as they directly impact the broader public. Figure 3 shows the rank of top 5 topics with the highest level of interest of all times by the public, measured by the number of access (“clicks”). Topics like measures to lower household loan interest rates, improving payment systems, and limiting interchange fees for card payments were the most accessed by the public, as they have a significant effect on the financial wellbeing of individuals and businesses alike. Maintaining transparency and providing regular updates on these topics not only keeps the public informed but also reinforces the CBCG’s role in safeguarding financial stability and consumer protection, fostering a stronger relationship with the general public.

Figure 3.
Figure 3.

Montenegro: Top Popular Topics by Public Interest

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF.

57. The CBCG has several publications of different frequencies with updates on the economic and financial situation, and the Financial Stability Report deserves greater emphasis given the CBCG’s mandate. Figure 4 shows some of the key publications (for a complete list, see item 1.7 of the detailed review). The CBCG Bulletin is historically the most extensive report, averaging over 80 pages and exceeding 10,000 words, published monthly. Since its reformulation in 2016, it was reduced from more than 120 to 58 pages, but considering it is a bilingual publication, it essentially has 29 pages.13 The Macroeconomic Report (MR, quarterly) and the Financial Stability Report (FSR, annual) have similar page counts, around 60. The Inflation Report is shorter with moderate length, while the monthly Governor Report - which gives a brief overview of the CBCG’s key activities and provides economic/financial data—is the briefest in both pages and word count. While the CBCG publishes relevant information regularly, the FSR, which is a key source of information aligned with the CBCG's goal of preserving financial stability, is published only once a year. In addition, its access remains low (172 in 2022, dropping to eight in 2023). Despite its importance, some stakeholders reported that they were unaware of its existence. To address this, the report should be published more frequently (at least twice a year) and actively disseminated with key messages in an accessible language to raise awareness and interest among stakeholders and the public, informing them by the main risks and CBCG’s measures.

Figure 4.
Figure 4.

Montenegro: Information on Key CBCG Publications (Average Over Time)

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF staff calculations

58. Transparency in reports goes beyond simply providing information; it requires the information to be clear and accessible. Complex or overly detailed reports may obscure important points, making it harder for readers to understand. Therefore, clear communication is essential for ensuring that transparency serves its purpose. To access the level of complexity, the Flesch Readability Ease Score14 is applied in key publications. As shown in Figure 5, all reports fall in the “Difficult” category.15 The overall result is not surprising, as the content of the reports is mainly focused on economic and financial topics, which demand a certain level of expertise to comprehend. The CBCG could enhance accessibility to other segments of its audience by translating key messages into simpler language in separate versions for broadcasting, considering using illustrations and dashboards to better engage a broader audience.

Figure 5.
Figure 5.

Montenegro: Flesch Readability Ease

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF staff calculations.
Figure 6.
Figure 6.

Montenegro: Sentiment Analysis from CBCG Bulletin and Montenegro GDP Growth

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF staff calculations.

59. Central Bank reports are a useful source for conducting sentiment analysis on economic language, however, they are most effective when forward looking, which is not the case for most of CBCG’s publications. Through the application of Natural Language Processing (NLP) tools, it is possible to extract insights and gauge the overall tone and sentiment of the reports. Figure 6 shows the application of a methodology developed by the Federal Reserve’s Sentiment Analysis16 on the CBCG Bulletin and its comparison with the quarterly GDP growth. This report was chosen because its higher word count and more frequent publication provide a larger dataset compared to the others. The chart demonstrates that the sentiment index provides a backward-looking analysis, where sentiment scores consistently reflect the conditions of previous months. This reporting delay accounts for the observed lag between sentiment and real GDP growth, especially during volatile periods like the COVID-19 pandemic. For example, while the sharp GDP contraction in early 2020 captures the immediate economic impact, sentiment reacts more slowly due to the reporting delay. This indicates that the index accurately captures sentiment, although with a noticeable lag. Although the concept of the Bulletin is to report on conjectural recent past economic events, the CBCG publications in general would benefit from more forwardlooking insights regarding the economy. That is helpful to manage market sentiment and expectations, fostering greater confidence among investors, businesses, and consumers. In addition, it can be useful to identify and address potential risks before they materialize, promoting financial stability and enhancing the effectiveness of their policy measures.

60. Recently, the CBCG started to engage actively in social media, and additional initiatives are encouraged to attract more followers and engagement in all platforms. The CBCG first established an account in Facebook in August 2021 and in X, Instagram and LinkedIn since December 2023. The CBCG has the highest followers on Linkedin (close to 3000), and they consist mostly of professionals in the banking industry (25 percent), financial services (8 percent), government administration (7 percent), IT services and consulting (4 percent), followed by small numbers segregated in other related indutries. The CBCG also regularly launches videos on YouTube and engages in TV campaigns. Figure 7 shows the cumulative growth of followers across three platforms—Facebook, Instagram, and X (given data availability)—over time. Facebook consistently maintains the highest number of followers, reaching close to 1,600 by September 2024. Despite X being a widely used medium for sharing official updates and news, its follower count has only 300 followers, lagging behind Instagram (800 followers), which is typically associated with more casual or visual content. The relatively low number of followers across all platforms highlights the restricted reach of these social media channels.

Figure 7.
Figure 7.

Montenegro: CBCG Followers on Social Media

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF staff calculations.

61. The CBCG can enhance its social media presence by creating engaging, audience-tailored content, such as infographics and videos, while fostering direct interaction through live sessions and monitoring trends to maintain transparent communication. Figure 8 shows that Facebook posts on practical measures and social initiatives attract the most followers, while Instagram sees more interaction with educational and environmental content. X remains the least engaged platform in this dataset. To enhance its presence on social media, the CBCG could create informative and engaging content tailored to the interests of diverse audiences, such as infographics or videos that explain its mandate, objective and economic indicators in simple terms. In particular, these tools could be paired with regular publications to increase acccessibility and readability in the CBCG website, summarizing the key insights of each report in an accessible way. Additionally, hosting live Q&A sessions or webinars can foster direct interaction with the public, allowing citizens to ask questions and gain insights in real-time. Collaborating with financial educators can also help broaden the bank's reach, making its messages more relatable and accessible. Lastly, actively monitoring social media trends and public sentiment will enable the central bank to respond promptly to concerns and maintain a transparent dialogue with the community.

Figure 8.
Figure 8.

Montenegro: Key Topics that Attracted the Most Followers

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: CBCG and IMF staff calculations.

Household Survey for Montenegrin Citizens

62. Conducting a household survey about the CBCG's role and policies provides valuable insights into public awareness and perception regarding its key functions while also helping to predict audience behavior toward key CBCG initiatives. By surveying not only financial, business, and academic communities but also households, the CBCG can gain a more complete understanding of its effectiveness, fostering greater public trust and encouraging stronger engagement between the central bank and the wider population. This feedback helps the CBCG to refine their transparency, communication strategies, and ensures policies resonate with broader societal concerns, fostering a stronger relationship between the institution and the public. Importantly, highlighting the gaps in knowledge that can be addressed through improved communication can increase the trust and ultimately the credibility of the central bank. This is crucial as central bank policies are more effective when trusted. The data can also help to gauge insights on the public’s behavior, when treated with appropriate econometric tools.

63. For the first time, the IMF, in collaboration with the CBCG, conducted a survey targeting households in Montenegro featuring specific questions related to its central bank. The primary goal of the survey is to gain a deeper understanding of the public's perception and knowledge of the CBCG. By collecting insights from the population, the CBCG can understand and address the knowledge gaps about its role, objectives, and its impact on Montenegro's citizens. Those are valuable insights for an effective communication strategy implementation. The survey was set up by the IMF and conducted online17 through a link, which was widely promoted by media channels and the CBCG, including the use of a QR code for easy access (Figure 9). The survey was available for 7 days, during which 492 responses were collected. Of these, 298 were from females (62.5 percent), 178 from males (37.3 percent), 1 from a non-binary individual and 13 preferred not to reveal their gender. It was completely anonymous, and all responses were handled with the utmost confidentiality. Figure 10 displays age and gender, with the majority aged 35-44 and 45-54, and females generally more represented across all age groups given its higher participation. Figure 11 highlights the education levels of the participants, with most respondents holding a bachelor’s or master’s degree, while smaller numbers had a high school education, a doctorate, or other qualifications. It is important to mention that the short duration of the survey and the potential for limited outreach may have introduced some limitations, as a broader campaign across diverse social environments could be crucial in obtaining a more representative sample that better reflects the general population.

Figure 9.
Figure 9.

Montenegro: QR Code to Household Survey

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff.
Figure 10.
Figure 10.

Montenegro: Survey Participants: Age Group Profile

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.
Figure 11.
Figure 11.

Montenegro: Survey Participants by Level of Education

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.

64. While there is a reasonable understanding of the CBCG`s core functions, there is a need for further clarification to address misconceptions about its objectives. The survey included two multiple choice questions asking what the participant believes to be the main CBCG`s functions and objectives, shown respectively in Figures 12 and 13. Each bar represents the percentage of people who selected a particular answer as the correct function of the central bank. The red bars indicate incorrect answers, and the blue bars reflect correct responses. Figure 12 shows that a significant portion of the respondents correctly identified key functions such as overseeing the overall stability of the financial system (28 percent), regulating commercial banks (24.5 percent), and helping banks recover from problems (17.7 percent). However, there are notable misconceptions as well, with 4.4 percent of people mistakenly believing that printing Montenegro's money is a key responsibility, and 0.7 percent thinking the central bank opens deposit accounts for individuals—both shown in red. Figure 13 shows that many respondents accurately pointed out that supporting and maintaining a sound financial system (32.7 percent) and contributing to economic stability (30.5 percent) are central roles of the institution. On the other hand, 19 percent incorrectly thought that ensuring Montenegro's economic growth is a primary task of the central bank, and 2.4 percent believed that the CBCG is responsible for deciding how much the government can spend.

Figure 12.
Figure 12.

Montenegro: What are the Main CBCG’s Functions?

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.Note: Red bars indicate wrong answers (or unknown, as it is the case of the first option in Figure 13).
Figure 13.
Figure 13.

Montenegro: What are the Main CBCG’s Objectives?

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.Note: Red bars indicate wrong answers (or unknown, as it is the case of the first option in Figure 13).

65. Nearly 50 percent of the respondents exhibit low or very low awareness of the CBCG (Figure 14). Based on the 14 answers for the two questions regarding the main CBCG`s functions and objectives discussed above, an index measuring the awareness about the CBCG was developed. The index indicates that 31 percent of the participants have high or full awareness regarding the main functions and objectives of CBCG, while 21.7 percent have partial awareness and the remaining have low or very low awareness. This index is determined by the count of correct, incorrect, and omitted responses that participants were prompted to choose from, according to weights assigned to each option. It imposes a greater penalty for incorrect answers compared to omitted responses. The result is categorized as follows: a score of 85-100 percent indicates full, 60-84 percent indicates high, 40-59 percent indicates partial, 20-39 percent indicates low, and below 20 percent indicates very low awareness. Respondents' answers were evaluated based on the following formula:

A001lev1sec10
Figure 14.
Figure 14.

Montenegro: CBCG’s Awareness Index

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.

  • Correct Selections: Number of correct options chosen by the respondent.

  • Omissions: Number of correct options the respondent failed to select.

  • Incorrect Selections: Number of false options incorrectly selected by the respondent.

  • Omission Penalty (OP): A penalty of 0.1 points for each correct option omitted.

  • Incorrect Penalty (IP): A penalty of 1 point for each false option incorrectly selected.

66. Nearly half of the participants show a significant discrepancy between their selfassessed knowledge and their actual level of awareness of the CBCG’s functions and objectives. A Knowledge Gap Index was built to provide insights into how well individuals perceive their own understanding compared to their true level of knowledge (see Figure 15). The index is based on the absolute difference between a participant’s self-assessed knowledge score based on a multiple-choice question “How would you rate your understanding of the role of the Central Bank of Montenegro?” (Figure 16) and their actual awareness score, based on the awareness index presented above. It is calculated based on the following formula:

Knowledge Gap Level =1 Self assessed Score — Awareness Index Score I

When the self-assessment aligns with the accuracy of the answers reflected in the awareness index, the discrepancy is low. However, when the self-assessment does not match, it indicates an under or overestimation of the participant’s knowledge. The results show that 40 percent of participants have a significant gap between their perceived level of awareness and their actual level, with 66 percent of them overestimating their knowledge. This is relevant for the CBCG because a significant discrepancy between public perception and actual awareness can hinder effective communication. Addressing these gaps is crucial for ensuring that the public has accurate knowledge, which is essential for informed decision-making and fostering confidence in the central bank's actions. Most importantly, both indexes are valuable for evaluating how the population's knowledge evolves over time, especially if the survey is conducted multiple times in the future. This provides a great opportunity to assess the effectiveness of the communication strategy.

Figure 15.
Figure 15.

Montenegro: CBCG’s Knowledge Gap Index

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.
Figure 16.
Figure 16.

Montenegro: Self-awareness Evaluation (Number of Replies)

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.

Predicting Audience’s Behavior Based on Survey’s Data

67. A major challenge for the CBCG is to capture the attention and encourage the engagement in consultations and discussions of those who are less informed, less aware, and have lower levels of education. Based econometric tools such as multinominal logistic regressions, the data from the survey allows to derive insights about the behavior of different segments of the population regarding CBCG’s initiatives. This information is valuable for tailoring and strengthening the CBCG’s strategy to effectively achieve its objectives in these initiatives. Overall, individuals who are more informed, confident in their knowledge, and have higher levels of education are more likely to participate in consultations and public discussions organized by the CBCG (see Figure 17). Education is a strong predictor of participation, with individuals holding a PhD having the highest likelihood of engagement (66.7 percent), followed by those with a master’s degree (39.3 percent), while high school diploma holders have the lowest (24.5 percent). Similarly, self-assessment of knowledge impacts participation, with those rating their knowledge as "Very Good" showing a 50.4 percent probability to participate in CBCG’s events, compared to 23.7 percent for those who rated themselves as "Poor." Awareness levels also correlate with participation, as individuals with "High" awareness (44.5 percent) are much more likely to engage than those with "Very Low" awareness (28.5 percent). Finally, younger individuals are more likely to engage. The 25-34 age group has the highest likelihood participation rate at 45.5 percent, while those above 55 have the lowest at 19.3 percent, suggesting that older individuals are less engaged. The CBCG could benefit from enhanced engagement by implementing targeted programs designed to clarify its roles and objectives, specifically for individuals who are less aware of the central bank's existence, along with other key factors identified as predictors of lower engagement. Furthermore, these findings could guide and inform the best strategies to engage in each social media platform according to each audience profile.

Figure 17.
Figure 17.
Figure 17.

Montenegro: Predictable Factors of Participation in CBCG’s Public Discussions

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.

Montenegro: Predicting the Participation of Individuals in CBCG’s Public Discussions and Consultations

Deriving probabilities for individuals’ participation in CBCG’s public discussions and consultations is useful because it offers insights to shape the CBCG’s communication strategy. While several approaches can be implemented for this purpose using survey’s data, the multinomial logistic regression framework allows for a more flexible understanding of outcomes with more than two categories, which is particularly relevant when studying complex decisions like participation in public discussions. Including multiple predictor variables and comparing them to a reference category allows for more accurate predictions of participation tendencies. This approach helps in understanding how different groups—such as those with varying awareness levels or self-assessed knowledge—are more or less likely to participate.

In the model applied in this report, the probability of falling into each participation outcomes are based on predictor variables, such as age, awareness, self-assessed knowledge level, and gender. For this analysis, the dependent variable is multinomial encompassing the responses about the public’s willingness to participate in CBCG’s consultations and public discussions: “yes”, “unsure” and “no” (used as the base outcome). Each category's probability Pikis compared to the base outcome Pi(k+1), allowing to assess how changes in predictors shift the odds of being in a particular category relative to the baseline. X/is vector of covariates (such as intercept, age, awareness, self-assessed knowledge, education, gender, etc.). The objective is to estimate the vector of unknown regression parameters f>k, which further enables the estimation of the probabilities.

Box 2.
Source: Methods and Applications of Longitudinal Data Analysis by Xian Liu (1st Edition, 2015, Elsevier), ISBN: 9780128013427 (Hardback), ISBN: 9780128014820 (eBook).

Further Insights on Social Media and Suggestions from the Audience

68. Although social media would be the preferred communication channel of the participants, it remains unfamiliar to them. Figure 18 shows that the CBCG website is the most widely recognized communication channel, with 69.5 percent of respondents aware of it. This is followed by press releases (51.8 percent) and television (43.5 percent), which also enjoy relatively high levels of awareness. On the other hand, radio, with only 9.6 percent, and newspapers (22.4 percent) seem to be the least recognized channels, suggesting a shift in public engagement from traditional media to more modern communication platforms. Figure 19 provides an overview of respondents' preferred communication channels with the CBCG. Interestingly, media news is the most preferred channel, with 51.6 percent of respondents selecting it. Social media posts and email newsletters also show significant preference rates at 48.4 percent and 33.9 percent, respectively. This indicates a growing trend toward digital communication methods. Meanwhile, channels such as SMS (13.4 percent) and public events (29.7 percent) are less favored, showing that respondents lean more toward indirect sources rather than direct or event-based communication. This highlights the importance of continuing to strengthen CBCG’s digital and media presence to meet public preferences.

Figure 18.
Figure 18.

Montenegro: Which CBCG Communication Channels are You Aware Of?

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.
Figure 19.
Figure 19.

Montenegro: What Would be Your Preferred Communication Channel with CBCG?

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.

69. Suggestions to improve the CBCG’S transparency reflect the public’s desire for consistent and timely communication (Figure 20). The most prominent recommendation, with 30 percent of respondents, is to provide more frequent updates. Additionally, 27 percent of respondents believe that holding more public discussions could enhance transparency, fostering greater engagement with the community. Improving access to information (21 percent) and simplifying the language used (18 percent) are also seen as important steps to make the content more understandable and accessible to a broader audience.

Figure 20.
Figure 20.

Montenegro: Suggestions from Survey’s Participants

Citation: IMF Staff Country Reports 2025, 083; 10.5089/9798229005203.002.A001

Source: IMF staff calculations.

Authorities’ Response to Detailed Review Report

The Central Bank of Montenegro (CBCG) expresses its sincere appreciation to the International Monetary Fund (IMF) for conducting the Central Bank Transparency Code Review (CBTR). We would also like to extend our gratitude to the authors of the Detailed Review Report for their thorough and systematic assessment of the CBCG’s transparency practices.

The CBCG initiated this review with the goal of strengthening its transparency, enhancing accountability towards key stakeholders, and improving the efficiency and visibility of its policies.

As part of our ongoing commitment to enhancing transparency, the review of CBCG practices outlined in the CBTC further bolstered our efforts toward achieving this strategic objective. In addition to our regular internal assessments, we highly value feedback from external stakeholders and remain attentive to broader trends within the central banking community. This commitment made our participation in the CBTC review especially valuable, as it provided an opportunity for a diverse group of CBCG stakeholders to offer an objective evaluation of our transparency initiatives.

The CBCG requested a comprehensive review of its transparency in governance, policies, operations, outcomes, and official relations with government and other agencies to independently assess these areas. In the Detailed Review Report, the Mission stated that the CBCG is committed to open and transparent communications, and its website serves as the key communication tool with stakeholders, complemented by a variety of policy and analytical publications. It also noted that the CBCG discloses extensive economic information and analysis explaining current economic developments and projections as well as the stability of the financial sector. The assessment further observed the CBCG's dedication to transparency through clear communication practices, comprehensive financial disclosures, and the use of established audit mechanisms, as well as its commitment to openness and transparency across different aspects of its work.

The Detailed Review report also provides twelve Key Recommendations across the five mentioned pillars of the CBTC. The CBCG will carefully consider all recommendations to proceed with their implementation to further enhance the effectiveness of its transparency policies in the near term. Therefore, the Action Plan for implementing the recommendations is an integral part of the Report and outlines the responses and timelines for their execution.

CBCG welcomes the publication of the Detailed Review Report by the IMF Mission Team and acknowledges the valuable insights, findings, and recommendations provided. The insights from the IMF Review will play a pivotal role in guiding our continued improvements, ensuring our transparency policies align with international best practices.

The CBCG emphasizes that transparency is the foundation of trust between the central bank, its citizens, and stakeholders. We remain committed to continuously improving our practices to enhance accountability, efficiency, and openness, with a strong belief that the IMF’s findings affirm the institution’s dedication and progress. The IMF’s recommendations will serve as a valuable guide in the CBCG’s ongoing development as a modern, responsible institution.

Finally, we would like to extend our gratitude to the members of the IMF Mission Team, who held productive meetings from September 11 to September 24, 2024, with the CBCG Council members, management, staff, and key stakeholders, including financial sector regulators, government agencies, the banking community, business associations, financial analysts, academia and the media. Their expertise, commitment, and professionalism in engaging with us have significantly contributed to the success of the Mission and to the depth and relevance of the findings in this Detailed Review Report.

CBCG: Proposed Action Plan

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Annex I. CBCG: Central Bank Transparency Code—Detailed Review

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Annex II. List of CBCG Units and External Stakeholders

CBCG Senior Management and Staff

  • Governor

  • Vice-Governor

  • External Member of the Council (Mr. Milorad Jovovic)

  • Advisers to the Governor

  • Secretary to the Council/Audit Committee

  • Governor’s Office

  • Directorate for Legal Affairs

  • Department for Financial Stability, Research and Statistics

  • Directorate for Resolution of Credit Institutions

  • Supervision Department

  • Internal Audit

  • Directorate for Finances, Accounting and Controlling

  • Directorate for Operational Risk Management, Information Security and Business Continuity

  • Directorate for Supervision of AML/CFT Compliance and the Financial and Credit Institutions Consumer Protection

  • Financial and Banking Operations

  • Human Resources Directorate

  • Directorate for International cooperation and European Integration

  • Payment System Department

  • Directorate for Communication

  • Information Technology Department

External Stakeholders in Montenegro

Government/Government Agencies/Regulators

  • Ministry of Finance

  • Ministry of Economic Development

  • Tax Administration of Montenegro

  • Police Administration - Department for Financial Intelligence Affairs

  • Members of Parliament (Skupština Crne Gore) - Committee on Economy, Finance and Budget

  • Committee on Economy, Finance, and Budget

  • Insurance Supervision Agency

  • Capital Market Authority

Financial Sector Entities

  • Erste Bank

  • Hipotekarna Bank

  • NLB Banka

  • Crnogorska Komercijalna Banka

  • Addiko Bank

  • Prva Banka Crne Gore

  • Ziraat Bank

  • Investment Development Fund

  • VIP Broker

  • Montenegro Stock Exchange

Business Associations/Consulting and Audit Firms

  • Chamber of Economy

  • Employers Federation of Montenegro

  • BDO

  • PwC

  • Deloitte

  • Ernst Young (EY)

  • KPMG

  • CEED Consulting

Media

  • Dan Daily

  • RTCG

  • Vijesti

  • Pobjeda

Academia

  • University of Montenegro Faculty of Economics

  • UDG

  • Mediterranean University
2

According to the Central Bank Transparency Code Review Guidance Note, the last day of the mission is set as a cutoff date for review’s findings, hence initiatives implemented after this date are not considered. The cut-off date of the mission is September 25, 2024. See Guidance Note in the following link.

3

Please refer to the Detailed Review Table in Annex I for a complete overview of principle wise transparency recommendations.

4

Please refer to the Authorities’ response to detailed review report for details on the recommendations that have been already implemented before this report’s publication.

5

The mission took place from September 11–25, 2024. Initiatives implemented after the mission conclusion date have not been considered.

6

See Annex II for a list of the CBCG units and external stakeholders that were met as part of the mission.

7

Even though, under the EU legal framework, member countries can impose temporary restrictions on cross-border transactions in certain circumstances, e.g., in balance of payment crisis”

8

See Jácome, L. I., & Mitra, S. (2015). LTV and DTI Limits - Going Granular. IMF Working Paper No. 15/154, International Monetary Fund. This paper, published in July 2015 highlights practical methodologies for evaluating macroprudential measures and contributes to the broader literature on policy evaluation.

9

The information regarding the accesses on the CBCG’s websites are based on data collected and provided by the CBCG from May 2023 to August 2024.

10

The analysis starts in 2010 due to data availability, however, the CBCG started publishing press releases on January 18, 2007.

11

The topics were classified according to the title of the releases and not through an extensive revision of the content of the text. It is consistent with the assumption that the title of the press releases reflects what the CBCG wants to emphasize as the primary messaging. Therefore, it is important to mention that some press releases may cover multiple topics—for example, a press release on internal meetings also may contain information on economic support measures.

12

These topics include respectively about: (i) meetings with external counterparts and joint collaboration between the CBCG and multilateral organizations and other central banks/governments: and (ii) engagements with regional counterparts and public initiatives such as conference announcements.

13

Additionally, it should be noted that out of the 58 pages, 28 are methodological explanations with links to statistical tables.

14

Flesch, Rudolf. "A New Readability Yardstick." Journal of Applied Psychology, vol. 32, no. 3, 1948, pp. 221-233. Note that this score captures only lexical features of the language and not semantical meaning.

15

The Bulletin was reformulated and shortened in 2016, and the index indicates that the report became more difficult to read after this change. This result was likely obtained because the annex, which includes the methodology intended for researchers and specialists in this field, was also taken into account by software assessment.

16

See Shapiro, Adam Hale, and Daniel J. Wilson. "Taking the Fed at its Word: Direct Estimation of Central Bank Objectives Using Text Analytics." Federal Reserve Bank of San Francisco Working Paper Series, 2019-02. Note that the index was converted to quarterly frequency and was smoothed through moving average.

17

Typically, surveys aimed at this type of audience are also conducted by phone to ensure broader population coverage, enhancing randomization. However, due to constraints, this approach was not feasible to implement.

1

The CBCG is considering a revision of the Decision on International Reserves Management to increase transparency. This change is not included in the transparency review. However, it is expected that the new Decision would, inter alia, disclose the distribution of responsibilities and the institutional framework, as well as some additional explanation on risk exposure and constraints. To avoid inducing internal and external confusion with its planned new Decision, particular attention should be given to avoid overlap in governing documents. The contemplated new broader Decision should remain at the policy level while the implementation framework and specific constraints stay in the existing Guidelines for International Reserves Management and the IC’s Terms of reference.

Citation Info

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Cover IMF Staff Country Reports
Montenegro: Central Bank Transparency Code Review
Author:
International Monetary Fund. Monetary and Capital Markets Department
Volume/Issue:
Volume 2025: Issue 083
Publisher:
International Monetary Fund
ISBN:
9798229005203
ISSN:
1934-7685
Pages:
113
DOI:
https://doi.org/10.5089/9798229005203.002
Figure 1.

Montenegro: Evolution of CBCG’s Press Releases
Figure 2.

Montenegro: Overall Focus of CBCG’s Press Releases
Figure 3.

Montenegro: Top Popular Topics by Public Interest
Figure 4.

Montenegro: Information on Key CBCG Publications (Average Over Time)
Figure 5.

Montenegro: Flesch Readability Ease
Figure 6.

Montenegro: Sentiment Analysis from CBCG Bulletin and Montenegro GDP Growth
Figure 7.

Montenegro: CBCG Followers on Social Media
Figure 8.

Montenegro: Key Topics that Attracted the Most Followers
Figure 9.

Montenegro: QR Code to Household Survey
Figure 10.

Montenegro: Survey Participants: Age Group Profile
Figure 11.

Montenegro: Survey Participants by Level of Education
Figure 12.

Montenegro: What are the Main CBCG’s Functions?
Figure 13.

Montenegro: What are the Main CBCG’s Objectives?
Figure 14.

Montenegro: CBCG’s Awareness Index
Figure 15.

Montenegro: CBCG’s Knowledge Gap Index
Figure 16.

Montenegro: Self-awareness Evaluation (Number of Replies)
Figure 17.

Montenegro: Predictable Factors of Participation in CBCG’s Public Discussions
Figure 17.

Montenegro: Predictable Factors of Participation in CBCG’s Public Discussions
Figure 18.

Montenegro: Which CBCG Communication Channels are You Aware Of?
Figure 19.

Montenegro: What Would be Your Preferred Communication Channel with CBCG?
Figure 20.

Montenegro: Suggestions from Survey’s Participants