Podgorica, March 27th, 2025 – There is an exceptionally high risk that the Agreement with the Government of the United Arab Emirates, which Montenegrin Prime Minister Milojko Spajić plans to sign by the end of this week, could be misused for money laundering, as information about the actual owners of companies registered in that country is not available to the public.
A clear example that illustrates this problem is the case of Blažo Đukanović, son of the former President of Montenegro, Milo Đukanović. Specifically, MANS, based on the Pandora Papers, discovered that the younger Đukanović founded Victoria Bridge Corporation in the British Virgin Islands. On December 9, 2016, the law firm Alcogal sent documentation to establish a subsidiary of Đukanović’s company to the address of Prudenter Group Dubai, which provides company registration services in the Emirates. However, due to the unavailability of company registers in the UAE, it is impossible to determine whether this company is indeed registered, nor who its real owners are.
The UAE has as many as 39 different company registers, many of which are not available to the public at all. Moreover, even publicly accessible registers often do not contain information about the actual owners, only about the formal directors of the companies, whose role is to conceal the identity of the real owners. Therefore, it is practically impossible to verify who is really behind the capital coming from the Emirates.
Given this example, it is clear how dangerous the Agreement that Prime Minister Spajić plans to sign with the Government of the Emirates is. In that case, the Government of Montenegro would not have even basic mechanisms to check who the real owners of the companies that would receive privileged status in Montenegro are and could buy state land without tenders.
Indeed, the Agreement stipulates that the Government of the Emirates designate companies whose projects will have privileged status in Montenegro, and that the Government of Montenegro give its consent to this. However, the Agreement does not define on what criteria Montenegro will give its consent, nor what information the Emirates will provide about the investors they propose.
The Agreement further provides the possibility for third parties to also fund the projects, but it is not specified whether the Government of Montenegro consents to these investors as well, nor are there defined criteria and mechanisms for checking the origin of such capital, which further increases the risk of introducing illegally obtained money into the country.
Additionally worrying is that the Agreement frees the UAE Government of any responsibility if the investors it proposes fail to meet their obligations or are involved in illegal activities. This means that the Government of Montenegro would be completely unprotected in case companies misuse their privileged status for financial or other criminal activities.
It is especially important to note that international reports indicate minimal cooperation from the Emirates with other countries in cases related to discovering the real owners of companies and confiscating illegally obtained capital.
All of the above points to a high risk that this Agreement, adopted without broad public discussion and in a record short time, could be misused as a channel for money laundering.
MANS
