Montenegro Payment System License

Several years ago, Montenegro took large-scale steps to introduce electronic money circulation in the legal field. The country adopted a law aimed at implementing European Directives 98/26, 2007/64, 2009/44 and 2009/110 on e-money, e-money-based settlements and e-money-based commercial services.

The national norm has radically changed the existing rules on the use of electronic money in Montenegro and affected all entrepreneurs engaged in e-money-based operations. The law established provisions, firstly, allowing EU suppliers from the EU to operate in the country (after its entry into the Eurozone), and secondly, authorising payment structures and adding them to the circle of "legal" market players. It also consolidated the concept of e-money — defined in legal terms as "deposited value" that is issued upon receipt of money and is used for transactions by special services.

Until recently, payment transactions within the state could only be performed by the National Bank – the main financial regulator. The European directives have allowed commercial suppliers registered as legal entities and having passed the licensing procedure to also implement payment transactions. The initial minimum capital required to begin issuing electronic funds is EUR 350,000. Commercial organisations with authorised capital of between EUR 20,000 and EUR 125,000 can now accept and manage e-money in Montenegro depending on the list of activities. Payment services may:

• deposit electronic funds into accounts and manage them;
• maintain payment accounts and withdraw cash from them;
• transfer funds to service provider or third party accounts;
• issue payment instruments, carry out transactions;
• provide related services — exchange currencies, store and process data, etc.

What requirements must be met by licensed companies

Licenses are issued by the National Bank. The National Bank also ensures that the operator complies with all requirements, and conducts internal audit of documents submitted with the application. In Montenegro, only fully registered commercial organisations having official physical addresses in the country and providing proof of payment of the authorised capital are entitled to operate e-money.

To operate in Montenegro not only on the national market but also "with an eye" on the EU, one must take measures in advance to ensure that the payment system complies with the current directives, AML/KYC and GDPR legislation. Therefore, when applying to the licensing department of the National Bank, one must prepare:

• document package of the legal entity— extracts from national registers, memorandum and articles of association, etc.;
• description of the scope of activities, business structure, professional training of owners and directors – as per EU rules and norms, the management should be competent in the e-money field;
• descriptions of policies providing the business model, security of client tools and data, anti-money laundering;
• if you wish to operate on the EU market and use the data on its residents — proof of compliance with GDPR regulations personal data protection;
• description of internal audit procedures, etc.

Prifinance Expert Assistance

If you are interested in operating in Montenegro, electronic money is a promising business for you, and you want to easily go through all the bureaucratic formalities, contact Prifinance now. Our experts will help you register and license your payment system and fulfill all the requirements for it. We will create the legal entity, open a bank account for it, arrange and formalise the status of an e-money issuer or operator, etc. Prifinance will help you launch a fully-legitimate business quickly and hassle-free.