PostsCompliance Update: Ultimate Beneficial Owner (UBO) Registration in Montenegro

October 14, 2024

On July 19, 2024, the Ministry of Internal Affairs introduced a new Rulebook for the registration, updating, verification, and access to information in the UBO Register. Starting July 27, 2024, entities established before the new Anti-Money Laundering and Countering the Financing of Terrorism
(AML/CFT) Law (effective December 12, 2023) must comply by registering or updating their UBO details by August 26, 2024—a 30-day deadline.

Here’s what you need to know to comply:
– Utilize the online application: https://lnkd.in/dRKGQmq7
– Ensure you have a qualified electronic signature
– Submit detailed data including paid-in capital, bank accounts, management, UBOs, and for entities with complex ownership structures, ownership diagrams and registry excerpts for each entity in the ownership structure.

The Rulebook also introduces an automated monitoring system for the UBO Registry to maintain continuous compliance and up-to-date information. Entities failing to complete their annual update by March 31 will be automatically flagged.

Non-compliance can lead to significant fines—up to EUR 20,000 for the entity and up to EUR 2,000 for the authorized representative.