For many years, Montenegro faced significant financial outflows through transactions to foreign gambling websites—funds that fell entirely outside state control, resulting in considerable losses to the national budget. Specifically, domestic payment cards issued in Montenegro were frequently utilized to transfer large sums to foreign operators of gaming, with a correspondent merchant category code (MCC) tied to gambling and betting.

In 2022 alone, 4,911 payment cards facilitated such transactions, resulting in 132,109 transactions totaling €6,315,019.61. This trend persisted in 2023, where 5,118 cards were used for 133,445 transactions, amounting to €6,183,943.93.

This situation obstructed the state from exercising any form of oversight over the organization of such games, as well as from collecting revenues, and made it impossible to manage or mitigate gambling addiction and associated social harms. These circumstances prompted necessary legislative action in 2023, culminating in a legal prohibition of:

1. Participation in foreign gambling activities where stakes are paid from Montenegro;
2. The collection of stakes within Montenegro for participation in gambling organized abroad.

The trend of outflow continued into the first quarter of 2024, when 1,998 cards were used to perform 30,367 transactions, totaling €1,296,541.45. This situation necessitated a decisive intervention by the Coordinating Body for the protection and advancement of public interest regarding games of chance, in collaboration with the Administration for Games of Chance and the Central Bank.

The Coordinating Body conducted a thorough analysis, issued guidelines and recommendations, and the Administration for Games of Chance responded efficiently by distributing a directive to all banks. The Central Bank ensured effective enforcement, with both entities represented within the Coordinating Body.

All banks complied with the legal standards by blocking transactions flagged as payments to foreign entities with a merchant category code related to gambling and betting. Seven banks implemented the block in May 2024, one bank in June, and three additional banks followed suit in July 2024 after making necessary technical adjustments and coordinating with the Central Bank and the Administration for Games of Chance.

As a result of this extensive intervention, during the fourth quarter of 2024 and the first quarter of 2025, no payment cards were used for these transactions, and not a single transaction was conducted toward such websites. Consequently, no euros were transferred abroad for these activities during that period.

This outcome highlights the successful execution of the legal framework and the effective collaboration of competent institutions, ultimately serving to protect the national interest. This was also reaffirmed during the latest session of the Coordinating Body.