According to the text of the law (new article 65a), the execution of a payment under a real estate purchase and sale agreement is considered legal only if at least one party transfers money from an account in Montenegro or receives it to such an account. This means that transactions in which both the buyer and the seller use bank accounts outside the country are now prohibited.
In practice, two legal scenarios are possible for foreigners. If the buyer is a foreigner without an account in Montenegro, he can pay for the property from abroad, but the seller must receive the money exclusively to a local account. If the seller is a foreigner who wants to withdraw funds abroad, the buyer must pay from an account in a Montenegrin bank. The option where both participants use foreign banks is illegal.The legislator assigned a special role to notaries in monitoring compliance with the new rules. The notary is obliged to refuse to certify the transaction if the parties try to circumvent the national payment system of Montenegro. Moreover, the notary must require real proof of payment using a local account. A simple oral statement from the participant stating that the calculations have been made is no longer accepted.
The law comes into force on the eighth day after its official publication in the Official List of Montenegro, that is, on May 8, 2026. Experts warn that the new rules may significantly complicate the purchase of housing for foreigners who do not have an open account in a Montenegrin bank. It is recommended to open such an account in advance or include a local intermediary with a local account in the transaction in order to comply with the requirements of the law, although the latter option is unsafe and difficult to implement.
The law provides for heavy fines for real estate agencies.A source: Montenegro's Service Sheet,Law on the Prevention of Money Laundering and Terrorist Financing, Article 41 and Article 42, Article 65a
