Reaction to the Draft Strategy for Combating Corruption 2024 - 2028


Regarding the draft Strategy for Combating Corruption 2024 - 2028, published on 9 April 2024 on the Government of Montenegro website, which, among other things, states that: “The Central Bank of Montenegro has a central register of resident accounts, but still does not have a register of non-resident accounts, which is a key tool for investigations involving non-residents”, we issue the following


Pursuant to Article 65 of the Payment System Law, the Central Bank of Montenegro maintains the Central Registry of Transaction Accounts, which also includes data on non-residents. The decision on the content of this register, which is harmonised with the relevant legal acts, clearly stipulates the obligation of banks to submit data on transaction accounts of non-residents.

The Central Bank defines the content of the Central Register of Transaction Accounts, the data to be submitted to that register, the data submission method, and the method of accessing the data from the register.

Accordingly, the Central Register of Transaction Accounts also contains data on non-residents because, starting from 4 August 2021, banks have to submit data on non-residents’ transaction accounts under the Decision Amending the Decision on Central Registry of Transaction Accounts (“Official Gazette of Montenegro”, No. 53/21 of 27 May 2021).

During a public hearing, the CBCG will submit suggestions for deleting that part from the subject strategy to the relevant authority.

Andrija Jovović

Head of Payment System Department, CBCG