Country Manual Independent Portfolio Manager/Advisor (EAM)
Montenegro Update 2024
BRP has updated its Country Manual Independent Portfolio Manager/Advisor (EAM) for Montenegro out of company’s country of establishment (Def, RS & BT).
| SOURCE OF CHANGES | ANSWERS |
| Law/Regulation | Yes |
| New Position of the Authorities | No |
| Evolution of Expert’s interpretation | Yes |
Regulatory Summary and Behaviour Template
Material changes
While it was considered in the past that activities on Montenegrin territory, even upon a prospect’s or client’s request, would not be tolerated by the authorities, following a thorough analysis of the current situation with local experts, it seems appropriate to adopt a slightly more flexible approach. Activities related to the introduction of a third-party foreign custodian bank, as well as investment services related activities on Montenegrin territory on a prospect’s/client’s request are therefore qualified as a grey zone. However, there is no guidance or established practice concerning the admissibility of such activities. If performed at all, a cautious approach should be taken and presence on Montenegrin territory should be limited as much as possible
Non Material changes
Some comments/conditions have been reworded and further non-material changes have been made throughout the documents.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the EAM Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM EAM BT SHORT COMP” and “MONTENEGRO” in the Target Country Field.
The BT Short Comparison should be read as follows:
The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.
For more information, please contact us: info@brpsa.com
Best regards,
Geneva, October 29th, 2024