Country Manual Private Banking
Montenegro – Update 2024
BRP has updated its Country Manual Private Banking for Montenegro out of Bank’s Country of Establishment (DEF, RS, BT & RT)
| Source of changes | Answers |
|---|---|
| Law / Regulation | Yes |
| New Position of the Authorities | No |
| Evolution of Expert’s Interpretation | Yes |
Regulatory Template, Regulatory Summary and Behaviour Template
Material changes
According to local counsel, the authorities may apply a strict territorial approach, and therefore activities related to banking and investment services on Montenegrin territory on a prospect’s/client’s request remain a grey zone. 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. An exception in this respect seems to apply to generic marketing activities on the Bank, which are only targeted at a limited number of prospects, but a careful approach is recommended in the absence of formal rules.
The foreign bank is allowed to actively offer online access to an existing account via remote means of communication, provided that no additional services are offered.
Non-material changes
Some comments/conditions have been reworded and further non-material changes have been made throughout the documents.
Implications for business relations with third parties
With respect to the provision of documentation to the EAM (such as documentation on the Bank’s banking and investment services, investment research and financial analysis or recommendation lists), our Country Manual now distinguishes between the provision to the EAM for remittance to the end client on one hand and the provision to the EAM for the EAM’s own professional purposes on the other hand. The answers have been amended accordingly.
Regulatory Summary
This document has now a more user-friendly layout and reflects the changes contained in the RT.
BT Short Comparison
BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB 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 PB 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
Geneva, September 19th, 2024