DLT and cryptocurrencies
FinTechs belonging to this category offer financial services using crypto currencies. This category also includes FinTechs utilising blockchain and distributed ledger technologies (DLT) upon which Bitcoin and Ethereum are based, among others. FinTechs develop and do research in this field in order to create new services – e.g. crypto currency exchange markets, wallet providers, NFTs-related services, new payment services, "smart contracts" or new clearing and settling services.
Attitude of the country towards financial services using crypto currencies
There were some reservations towards using cryptocurrencies in Montenegro, and these assets have not been yet recognised as official means of payment. However, in July 2021, Ministry of Finance and Social Welfare established a Directorate for Blockchain and Crypto Currencies with the aim of establishing a legal framework for blockchain and cryptocurrencies’ matters. Accordingly, in October 2021, the CBM stated in a press release that Montenegrin authorities were preparing the draft of a law which would govern the respective matters.
Obligations and requirements to provide financial services using crypto currencies described above
There is no specific prescribed obligations, requirements, or licensing system for performance of cryptocurrency related business services, as there is no legal framework governing this matter. Still, as it is not explicitly prohibited, performance of such activities is not in a direct noncompliance with the law. Therefore, a subject performing cryptocurrency related activities would have reporting obligations in accordance with the Anti Money Laundering Law and other obligations which typically arise out of the local establishment of the legal entity.
Additional comments regarding the legal situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area
It is expected that Law on Crypto Currencies (whose draft is still being prepared) is to regulate the obligations, requirements, and licensing system for crypto currency related business services.
Market size for financial services using crypto currencies and biggest companies in this business area
There is no available information about the revenues, transactions, or other market factors.
However, it should be noted that there are certain investing companies in Montenegro (such as Limited Prime Securities and Finveo) offering crypto currency related business services.
Additional comments regarding the economic situation for financial services using crypto currencies or what FinTech’s must be aware of in this business area