Montenegro: documents and checks for expat buyers

Montenegro is one of the most open markets for foreign buyers in the region, and many of them are expats: people with a passport from one country who live in another and buy at a distance. In May 2026 the anti-money-laundering rules for real estate tightened. This briefing sets out what an agency should collect and verify, and what changed for the people who sit across the table from you.

What changed on 12 May 2026

A law-firm note reports that amendments to the Act on Prevention of Money-Laundering and Financing of Terrorism entered into force on 12 May 2026. Three points matter to an agency.

• Real estate agencies must carry out due diligence on all parties to a transaction when the payment, or a series of related payments, is EUR 10,000 or more.
• A real estate transaction involving EUR 10,000 or more may be carried out only if at least one party has an account with a Montenegrin bank, and the payment is made by wire transfer to an account at a Montenegrin credit institution. Cash above that amount is excluded.
• If the buyer paid before the notarisation, the notary must obtain documentary proof of payment. A party's own statement is not accepted, and notaries may not certify documents designed to bypass the national payment system.

We have read the note, not the statute. Ask a Montenegrin lawyer to confirm how these points apply to your own agency and its files.

What to collect from a cross-border buyer

• A valid passport. Documents in another language usually need a translator.
• A residence document for the country where the buyer lives, if relevant.
• A statement of how the purchase will be paid and from which bank and country.
• A source-of-funds explanation and one supporting document, collected before the deposit.
• The name of any representative and a power of attorney if the buyer will not attend.
• Contact details and the language in which the buyer wants to receive documents.

Due diligence you owe under the new rules

For payments of EUR 10,000 or more, do and record the checks yourself rather than leave them to the notary.

• Identify the buyer and the seller, and where a company is involved identify the beneficial owner. The amendments reportedly treat the people in managerial positions as the owners where the true owner cannot be identified.
• Record the source of funds and keep the supporting document.
• Screen the parties against the sanctions lists that apply to your agency and your bank.
• Keep the file in a form that you can show to a supervisor.

If a buyer cannot or will not explain the funds, stop. Never advise anyone on how to avoid a check.

What can be bought, and what needs more scrutiny

Foreigners can buy apartments, houses and commercial premises in most cases. Sources point to restrictions or extra scrutiny for agricultural land and forests, natural resources, plots in protected or planning-restricted areas, larger parcels and border-zone property. Check the land registry entry, the seller's basis of ownership, any encumbrances and the planning parameters before you present a property as available to a foreigner.

The notary

A sales contract is not valid unless it is signed before a licensed notary, who certifies it. Plan the buyer's attendance, or the power of attorney, around that appointment. The tax and registration steps follow the notarisation.

Status questions for non-EU buyers

Buying property does not by itself give a right to live or work in Montenegro. The Foreigners Act amendments reported as in force from 17 January 2026 set a value threshold for residence based on property for third-country nationals; the other guide in this series covers it. Tell buyers to check their own residence position with a lawyer and not to rely on a sales conversation.

Banks and sanctions

Banks apply their own risk and sanctions policies. Buyers from some countries should expect more questions and slower account opening. Say so early and set the expectation; do not suggest ways around it.

Language and signing

Many cross-border buyers read neither Montenegrin nor English comfortably. Offer the contract and the key documents in a language the buyer reads, and have a translator at the notary appointment. Sources describe a qualified translator as required where the parties do not share the language of the proceedings. If the buyer will sign through a representative, agree early with the notary what form the power of attorney must take and who may use it.

An intake checklist

• Passport and residence documents filed.
• Source-of-funds statement with a supporting document.
• Payment route agreed: which Montenegrin account will receive the money.
• Land registry check done and noted.
• Translator and notary appointment arranged.
• Power of attorney in order, if needed.

Working with D.H. Realting

D.H. Realting is a trilingual (Russian, English, Polish) overseas-property platform. We introduce buyers, including expats and cross-border buyers, to property in other countries and support the process. Agencies that handle the deal locally and want to be introduced to such buyers can contact us through our partners page. We do not publish commission terms or promise any volume of enquiries here; those are discussed one to one.

Sources we relied on: a law-firm note on the May 2026 AML amendments.

This briefing is informational only. It is not legal, tax or investment advice, rules change often, and the sources named above are summaries rather than the legal texts. Confirm every point with a local lawyer and the competent authority before you rely on it.