The Economic Citizenship program in Montenegro, which ran from 2019 to the end of 2022, generated a total of 1,113 applications for Montenegrin passports, with 663 of those applications approved to date.

This information is derived from recently released government data regarding the status of a special investment initiative of significant economic importance to Montenegro as of April 30, 2024 (financial overview).

Started in 2019, the program was designed and managed by the Democratic Party of Socialists (DPS) administration, which was ousted in the August 2020 elections. The initial Montenegrin passport was issued in February 2020. The intention was to provide investors with citizenship in exchange for investments in development projects in tourism, agriculture, and the processing sector.

The criteria for obtaining a Montenegrin passport initially required a minimum investment of 450,000 euros in development projects in Podgorica and coastal areas, or 250,000 euros in northern or central regions, along with donations to less developed municipalities. However, in 2022, the government tightened these requirements. By the end of 2022, when the program was discontinued, investors were mandated to submit a government guarantee of 50 percent of their investment within a month. Additionally, applicants were required to contribute 100,000 euros to the Fund for Underdeveloped Municipalities and an extra 100,000 euros to an innovation fund.

The program was initially set to sell 2,000 passports within three years (starting January 2019), but Zdravko Krivokapić decided to terminate it at the end of 2021 due to low interest. Nonetheless, in December 2021, he opted to extend the program until the end of 2022, citing that investors needed more time to complete their projects due to the crisis.

The European Commission (EC) has repeatedly warned Montenegro, as an EU candidate country, that the “Gold Passport” scheme should align with EU visa policies. The EC stated it was closely monitoring this program in Montenegro, following prior measures taken against Malta and Cyprus due to scandals involving citizenship grants. These countries have raised billions of euros by selling thousands of passports, which sometimes allowed citizenship to individuals blacklisted by their home countries.

The program was concluded in late 2022, but processing of applications continued until that time.

While Montenegro’s government pushed for the economic citizenship initiative, it ultimately heeded the EU’s request, halting the program in 2016.

228 applications rejected, 100 under review

Based on data from the Investment Agency of Montenegro, there are currently 100 applications in the decision-making phase at the Ministry of the Interior. The Ministry has approved 663 applications for Montenegrin citizenship, and the subsequent passport issuance is currently being audited by an independent entity.

“To date, a total of 228 applications have been rejected due to negative assessments from international eligibility agents and non-compliance with specified criteria,” as indicated in the government report.

According to previous reports from the Center for Investigative Journalism (CIN-CG), most Montenegrin passports issued through the Economic Citizenship program were granted to Russian nationals, with the Ministry of Interior asserting that none of these individuals appeared on Montenegro’s sanction list related to the Russian invasion of Ukraine.

Donations for Southern Montenegro’s development total 33.3 million euros

The government’s report also mentions that, according to Montenegro’s budget law, funds allocated for less developed local governments were transferred to the Central State Treasury account, totaling 32,999,849 euros as of January 13, 2023.

For the development of less developed municipalities, the Montenegrin Investment Agency reported a total of 33,300,000 euros deposited in January 2023, per the registry with CKB Bank.

As of April 30, 2024, the balance in the CKB Bank account designated for less developed municipalities stands at 10,999,997 euros.

According to the Investment Agency’s records, 19,400,000 euros are currently in Escrow accounts, representing funds set aside by applicants whose submissions are still being evaluated by the relevant authorities.

From the program’s inception to April 30, 2024, total investments in tourism development projects amount to 198,924,752 euros, with 58,288,003 euros currently in Escrow accounts, reflecting funds from applicants awaiting evaluation.

In terms of agriculture and processing industry investments, the total raised by investors from the program’s start until April 30, 2024, reached 250,000 euros.

“Additionally, as per the Agency’s records, an amount of 250,000 euros is in Escrow, again reflecting funds from applicants whose submissions are still under review,” states the government report.

According to the Central State Treasury, administrative fees collected since the program’s launch until April 30, 2024, totaled 43,575,344 euros.

With respect to the Innovation Fund aimed at fostering innovation policy, a total of 20,800,000 euros has been allocated since the program began, while 11,300,000 euros remains in accounts, sourced from applicants’ deposits under evaluation.

The development projects included in the Economic Citizenship program comprise 15 focused on tourism and one on agriculture.

List of tourism development projects

List of agricultural development projects

In March 2022, the government removed six tourism-related projects from the development project list.

These included the construction of a four-star hotel “Bobotov Hotel and Resort” in Žabljak, also under the Kondo business model, as well as the Elite Hotel & Residence in Kolašin, following the same model.

Other projects included the construction of the four-star Hotel with Villas “Kolašin Resort & Spa,” the five-star “Queen’s Beach” hotel in Milocer, via mixed business model, and the Black Pine Hotel project in Mojkovac, according to the Kondo business model.

The government determined that three projects did not satisfy investment commitments, while bank guarantees were not submitted for three others.