The Montenegrin Ministry of Internal Affairs recently implemented a Rulebook on Ultimate Beneficial Owner (“UBO”) Registration, effective from 27 July 2024. It introduces significant changes in how legal entities in Montenegro must manage their UBO information as part of the country’s effort to strengthen its fight against money laundering.
For legal entities established before the new Anti-Money Laundering (“AML”) law, which came into effect on 20 December 2023, there is a crucial compliance deadline. These legal entities must register or update their UBO information in the UBO Registry by 26 August 2024.
To comply with the new Rulebook, legal entities must use the online application and a qualified e-signature from an employee, authorized representative, or attorney with permanent residence in Montenegro. Required information includes details on paid capital, bank accounts, authorized representative, and UBOs, supported by relevant documents. Legal entities with complex ownership structures (owned by at least one legal entity) must also provide an ownership structure scheme and registry extracts for each legal entity within the ownership chain.
In addition, the Rulebook introduces automated supervision of the UBO Registry, aiming to ensure continuous compliance and up-to-date information. The most relevant aspect of this system is expected to be the automatic flagging of legal entities that fail to perform an annual update by 31 March each year.
Non-compliance can result in significant penalties, including fines up to EUR 20,000 for the legal entity and up to EUR 2,000 for the authorized representative.
The information in this document does not constitute legal advice on any matter and is provided for general informational purposes only.
By Sandra Perisic, Senior Associate, and Filip Vukovic, Associate, Karanovic & Partners
