Canada    FinTech Guide    Chapter 15    Serbia

15. Initial Coin Offerings (ICOs)
Serbia  Serbia

There is not much talk about ICOs in social and political spheres in Serbia, as the public is generally not familiar nor interested in cryptocurrency topics.

Legal Affairs

Currently, there is no explicit regulation on ICOs and the issuance of token/coins in Serbia.

Restrictions: Currently, there are no explicit restrictions on ICOs or the issuance, distribution and/or transfer of token/coins.

Token classification: As currently there is no explicit regulation of the tokens/coins, the legal treatment and classification of tokens/coins would depend on the type and structure of the respective token/coin. Regardless of the type and structure of tokens/coins, they cannot be recognized as a currency, unless current by-laws rendered by the National Bank of Serbia are amended.

Prospectus: Due to the lack of regulation on tokens/coins, there is no explicitly prescribed duty to publish a prospectus before offering tokens/coins to investors. However, depending on the type and structure of the token/coin, if a respective token/coin may be classified as a security under the Law on Capital Markets, it may trigger the application to publish a prospectus before offering tokens/coins.

AML/KYC: The new Law on Prevention of Money Laundering and Financing of Terrorism („Official Gazette of the Republic of Serbia“ no. 113/2017) (“AML Law”) introduces for the first time entities engaged in the provision of services of sale, purchase and transfer of virtual currencies (and the mediation thereof) as obligors obliged to perform the standard AML procedures. Seemingly, the new AML law targets only entities dealing with the transfer of virtual currencies such as the virtual currency exchange platforms and it is disputable whether the ICO issuers could fall within this definition.

Economic Conditions

There is no reliable market data available for Serbia. As cryptocurrencies are not a legal tender in the Republic of Serbia, no regulated ICOs have taken place, although there is some unregulated activity. According to our knowledge, there is only 1 Serbian company conducting an ICO at the moment this text was written (Crypto Angel).

Contributing Authors

Karanovic & Nikolic

Marko Ketler
Belgrade, Serbia

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Chapter Index:

1. Payment Services / Mobile Payment

2. Asset and Portfolio Management

3. Consulting and Broking Services / Robo-advisory / Auto-trading

4. Trading Platforms / Social Trading Platforms / Signal Following

5. Crowdfunding / Crowdinvesting / Crowdlending

6. Virtual Currency - Bitcoin

7. Loan Services / Factoring / Loan Broking / Finetrading

8. Online Banking Services

9. Analytics and Research / Data Management / Risk Management

10. Accounting

11. Identification

12. Online-pawning

13. InsurTech

14. RegTech

15. Initial Coin Offerings (ICOs)

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.

Publication Date: 1 May 2018