Montenegro defines crypto ATMs in its AML law and runs a registration route, with one provider entered since 31 July 2026
Montenegro has no standalone crypto law. Its AML law defines a crypto ATM and requires providers to register with the Capital Market Commission before they start. The Commission adopted its rulebook on 20 November 2025. On 8 October 2026 the register lists one provider, and no registered ATM operator was found.
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Provider in the register, entered 31 July 2026
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EUR 1,000
Customer due diligence applies to occasional crypto transfers from this value
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Registered crypto ATM operators found in public sources
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Montenegro has no standalone crypto law. Its AML law defines a crypto ATM and requires providers to register with the Capital Market Commission before they start.1,2 The Commission adopted its rulebook on 20 November 2025.2 On 8 October 2026 the register lists one provider, and no registered ATM operator was found.3,4
Last updated: October 2026
Regulatory Framework
Crypto-asset rules sit inside the Law on the Prevention of Money Laundering and Terrorist Financing. The chapter on crypto-assets was added by amendments published in the Official Gazette on 12 March 2025 (24/25).1 A law firm briefing gives 20 March 2025 as the date they entered into force.7 The text has since been amended again, with the latest consolidated version in this review running to Official Gazette 59/26 of 4 May 2026.1 Montenegro has no separate digital assets law.10
Article 6, point 89 defines a crypto ATM ("kriptomat") as a physical or online electronic terminal that allows a crypto-asset service provider, in particular, to provide crypto-asset transfer services on behalf of clients. Point 80 says that this transfer service includes the use of a crypto ATM.1 Point 70 lists the crypto-asset services covered by the law. They include the exchange of crypto-assets for fiat currency and for other crypto-assets, order execution, custody and trading platform operation.1 Crypto-asset service providers are obliged entities under the AML rules (Article 4).1
The regime is a registration, not a licence. A law firm briefing describes it as a registration obligation without any permit or licensing.8 The Capital Market Commission keeps the register and supervises the providers (Article 40a, paragraph 4).2,4
Getting Registered
| Date | What happened |
|---|---|
| 2023 | Inspectors find a crypto ATM in a private club at Porto Montenegro in Tivat; the then government calls it an illegal device (as reported)11 |
| 12 Mar 2025 | Amendments with the crypto-asset chapter published in the Official Gazette (24/25)1 |
| 20 Mar 2025 | Amendments in force (as reported by a law firm)7 |
| 20 Nov 2025 | Capital Market Commission adopts the Rulebook on the register of crypto-asset service providers and reputation assessment2 |
| 27 Apr 2026 | Parliament adopts further AML amendments, promulgated on 30 April 20265 |
| 31 Jul 2026 | Commission enters the first provider, Artenx d.o.o. Podgorica, at its 195th session4 |
| 31 Jul 2026 | Ministry of Finance rulebook on reporting users of crypto-asset services to the tax authority is dated this day6 |
A provider must be in the register before it starts providing services. The rulebook asks for an application on the Commission form with identity data, a notarised statement, proof of the appointed AML officer and deputy, an extract from the beneficial owners register, a business plan describing the services and how they will be marketed, and data on the directors.2 Directors and associates also go through a reputation assessment. It needs a notarised questionnaire and statement, a criminal and misdemeanour record extract no older than three months, and proof of no final conviction for offences carrying an unconditional prison sentence of one year or more.2
Applications are delivered in person. The rulebook states no processing deadline, no fee and no capital requirement.2 It does not require a separate local office. The applicant declares that the activity is carried out from its registered seat, which for a company is the seat entered in the Central Register of Business Entities.2 A provider authorised or registered in another EU member state files its home-state approval or register extract with the application.2 The Commission can delete a provider from the register, or suspend it. A suspended provider may not carry out crypto-asset activities.2
AML and KYC
Customer due diligence applies to each occasional transaction that is a crypto-asset transfer worth EUR 1,000 or more, whether it is a single transaction or several linked ones (Article 18, paragraph 1).1 The April 2026 amendments extend the ban on anonymous accounts to anonymous crypto-asset accounts, add monitoring rules for transactions with self-hosted addresses and require records to include the deposit addresses of sender and recipient.5
A Ministry of Finance rulebook dated 31 July 2026 requires providers to report user data to the tax authority every year. It covers identity, residence, tax identification numbers and transaction data. It takes effect eight days after publication in the Official Gazette, and the issue number was not shown on the copy reviewed.6
What the Register Shows
On 8 October 2026 the Commission register lists one provider, Artenx d.o.o. Podgorica. The page gives no registration date, services or status.3 The Commission announced the entry on 31 July 2026 and described it as the first business entity in the register.4 The register was still empty when BIRN published its analysis in February 2026.10
The Commission told Forbes that it has identified nine businesses operating without registration and has issued two public investor warnings.9 No public source reviewed names a registered crypto ATM operator, and the Commission pages do not mention crypto ATMs.3,4 The one known machine case predates the 2025 amendments. In 2023 inspectors found a crypto ATM in Tivat, and the owner said his lawyer told him the area was unregulated, so no proceedings followed.11
What Is Changing
Forbes reports that Montenegro will need to align its crypto rules with MiCA as part of EU accession, with no timeline given. It also notes that registration in Montenegro is not a MiCA licence and does not allow passporting services across the EU.9 The Commission has said a full digital asset framework would give more legal certainty.9 No draft digital assets law was found as of 8 October 2026.
What Is Not Known
The amount of penalties for providing crypto-asset services without registration could not be confirmed from the text reviewed. The rulebook does not mention fees, capital or crypto ATMs, and the Commission does not state how long it takes to decide. The copy of the rulebook reviewed does not show its Official Gazette publication date. The sources do not say whether a machine operator needs anything beyond standard registration, whether a local permit is needed to site a machine, or how customer due diligence applies to ATM transactions below EUR 1,000. They also do not address bank accounts for operators or the position of a hardware or software supplier that does not provide the service. These are questions for Montenegrin counsel.
Sources and references
1. Law on the Prevention of Money Laundering and Terrorist Financing, unofficial consolidated text to Official Gazette 59/26 (PRIMARY, accessed 8 October 2026) | cbcg.me
2. Capital Market Commission, Rulebook on the register of crypto-asset service providers and reputation assessment, No. 01/9-1358/1-25, 20 November 2025 (PRIMARY, accessed 8 October 2026) | scmn.me
3. Capital Market Commission, Register of crypto-asset service providers (PRIMARY, accessed 8 October 2026) | scmn.me
4. Capital Market Commission, first crypto-asset service provider entered in the register, 31 July 2026 (PRIMARY, accessed 8 October 2026) | scmn.me
5. President of Montenegro, Decree promulgating the Law amending the AML/CFT Law, 30 April 2026 (PRIMARY, accessed 8 October 2026) | sluzbenilist.me
6. Ministry of Finance, Rulebook on the detailed manner of reporting on users of crypto-asset-related services, 31 July 2026 (PRIMARY, accessed 8 October 2026) | sluzbenilist.me
7. CEE Legal Matters, Montenegro: regulation of business operations related to crypto assets through amendments to the AML law (SECONDARY, accessed 8 October 2026) | ceelegalmatters.com
8. Karanovic & Partners, Montenegro's first-ever crypto regulation, March 2025 (SECONDARY, accessed 8 October 2026) | karanovicpartners.com
9. Forbes, Montenegro wants to be Europe's next crypto hub, 14 August 2026 (SECONDARY, accessed 8 October 2026) | forbes.com
10. BIRN Montenegro, Crypto-assets and money laundering analysis, February 2026 (SECONDARY, accessed 8 October 2026) | birn.eu.com
11. Radio Slobodna Evropa, report on the crypto ATM found in Tivat, 19 January 2024 (SECONDARY, accessed 8 October 2026) | slobodnaevropa.org
Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Rules may change; always consult specialised local legal counsel and confirm the current position with the Capital Market Commission of Montenegro before considering market entry.