Edinburgh Napier University

  This Technical Paper provides guidance to the national supervisory authorities to apply a risk-based AML/CFT supervisory approach to the supervision of the Designated Non-Financial Businesses and Professions (DNFBPs) in Montenegro. The objective of this paper is to strengthen the procedures for AML/CFT supervision of DNFBPs in Montenegro by providing guidelines to supervisors on how to perform an overall ML/TF risk assessment with respect to their supervisory processes and which factors should be taken into account.

The paper is based on a desk-based review of the relevant literature relating to the AML/CFT supervision of the DNFBPs (in Montenegro and internationally), as well as the information gathered during the interviews conducted with relevant stakeholders in Montenegro about their current supervisory practices and challenges in the oversight of DNFBPs. The stakeholders interviewed for this paper includes the representatives of the Administration for the Prevention of Money Laundering and Terrorist Financing (APMLTF), the Directorate of Inspection, the Bar Association of Montenegro and the Notary Association. The relevant literature referred to for the purposes of this paper includes, but is not limited to, the laws and bylaws related to the AML/CFT supervision of DNFBPs in Montenegro, 2015 National Risk Assessment Report of Montenegro, 2015 MONEYVAL Fourth Mutual Evaluation Report of Montenegro, risk-based approach guidelines issued by relevant authorities to DNFBPs in Montenegro and internationally, sector-specific ML/TF typology reports published by international organisations such as the FATF (the global standard- setter for AML/CTF) and any other relevant literature that relates to the effective AML/CFT supervision of DNFBPs.

The paper has identified some shortcomings and challenges in the current supervisory practices and/or approaches to the AML/CFT supervision of DNFBPs in Montenegro and provides recommendations to strengthen the supervisory processes and practices.