In early 2024, Montenegro amended Article 68(f) of its Gambling Act to prohibit gambling operators from accepting mobile and online banking deposits through mechanisms such as PayPal and Apple Pay.
The Montengro Government has confirmed it will re-assess the mandate following public and industry criticism over the ban. In anticipation of the ban, Montengro Bet, the country’s leading trade association in this sector, initiated a petition to stop the amendment which received over 25,000 signatures. Montenegro Bet considers the amendment to be “unconstitutional” and contrary to EU standards. While Montengro is not a member of the EU, it has been negotiating to join since 2012.
In 2021, the European Commission urged Montengro to enhance its efforts against money laundering. However, the e-payments ban encourages the use of cash payments in the gambling industry, which the EU considers to be higher-risk. EU initiatives such as the European Digital Identity Scheme seek to enable cross-border, mutual recognition of national electronic identification, as well as introduce the EU Digital Identity Wallet. Critics suggest the amendment could hinder Montenegro’s efforts in joining the EU in light of the EU’s pro-digital stance.
The outcome of the Government’s revision of the e-payments ban is yet to be published publicly. Given the strong outcry against the ban, as well as at least one gambling operator preparing an ICSID claim against the Government, we are interested to observe the Government’s response.
