Real Estate Tokenization
in Montenegro

Montenegro is building first-layer crypto compliance (VASPs under AML law), refreshed capital-markets and fund regimes, and a newly regulated real-estate intermediation sector. While title remains strictly off-chain, these updates create workable wrappers for tokenized property financing and distribution

  • VASP registration/AML obligations in force (Mar 2025)

  • Updated Capital Markets Act (Jul 2025) for securities-style tokens

  • New AIF/OIF fund laws (Mar 2025) for real-estate pooling

  • Live case: Dukley × Binaryx tokenized financing completed

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  • VASP registration/AML obligations in force (Mar 2025)

  • Updated Capital Markets Act (Jul 2025) for securities-style tokens

  • New AIF/OIF fund laws (Mar 2025) for real-estate pooling

  • Live case: Dukley × Binaryx tokenized financing completed

About

Why Montenegro is Attractive for Tokenization

Montenegro is one of the first jurisdictions where real-estate tokenization has moved from theory to practice. Several factors make it especially attractive

Tokenization Routes

Possible Routes for Tokenizing Property
in Montenegro

  • Montenegrin VASP license

    The Capital Market Commission of Montenegro together with the Central Bank of Montenegro (CBCG) form a regulatory ecosystem authorizing, enforcing and supervising entities providing crypto-related services, including token issuance and virtual asset service providers (VASPs).

  • Montenegrin SPV + private placement (token-mirrored)

    Best for: Professional/qualified investors, controlled distribution.
    How: Issue shares/notes under the Capital Markets Act via private placement; keep the official register off-chain and mirror positions on-chain for transfers/cap table with embedded eligibility/KYC rules.

  • Offshore issuer + local asset exposure

    Best for: Cross-border retail access with an offshore vehicle.
    How: Keep the asset in a local developer/SPV; issue tokens offshore (e.g., DAO LLC membership interests). Avoid “public offers” in Montenegro; if any in-country activity occurs, meet AML registration/advertising rules.
    Note: Title remains with the Montenegrin SPV; investors hold claims against the offshore vehicle.

  • Real-estate AIF (token-mirrored units)

    Best for: Multi-asset pipelines or income portfolios.
    How: Establish an AIF per the 2025 law; appoint depositary; issue units to professional investors. Tokens mirror the unit register; apply transfer restrictions and AML.

  • EU/foreign regulated token issuance + Montenegrin SPV

    Best for: Distribution under EU regimes (MiFID/AIFMD/MiCA jurisdictions).
    How: Hold the asset locally; issue from an EU venue; any marketing into Montenegro must respect prospectus/advertising and AML rules.

Real cases

Implemented Market Examples

  • Dukley × Binaryx

    Tokenized financing of a 73 m² Duplex Loft in Dukley Gardens. Raised $385k from 283 investors (Dec 2024). Tokens minted on Polygon, with a Wyoming DAO LLC holding structure, while on-register property title remains with the local SPV/developer.

  • Crypto-denominated sales (practice)

    Growing practice of using crypto in real estate purchases (e.g., in Budva). While not full tokenization, it shows regulatory openness — sales still require notarisation and land registry updates, but settlements in crypto are accepted.

Considering tokenization in Montenegro?
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Solution

The Solution with Tokenizer.Estate

Use cases

Solutions Designed for Your Success

We support everyone from Real estate owner to Sovereign Funds

FAQ

Frequently asked questions

  • Is tokenization legal in Montenegro?

    Yes—via existing capital-markets and fund laws. Tokens that are securities require compliance with the Capital Markets Act; VASPs must meet AML registration and conduct rules.

  • What’s the simplest compliant path today?

    For professional investors: SPV private placement with on-chain mirroring. For broader retail: offshore issuance with no public offer into Montenegro.

  • Can tokens transfer land title?

    No. Title transfers require notarised deeds and cadastre registration; tokens typically represent SPV/fund rights or off-register claims.

  • Do you provide legal services?

    No. We provide the platform and connect you with licensed Montenegrin counsel and regulated intermediaries.

See our full FAQ page for more details

Adopted for

Global Jurisdictional Coverage

Every market has its own rules. We’ve already built the structures to make tokenization work — from Europe to Asia to the Middle East. Launch with confidence, wherever your investors are

Last updated: 2025-10-01

The information on this page is for general informational purposes only and does not constitute legal, financial, investment, or tax advice.
Tokenizer.Estate provides a platform for real estate tokenization and connects you with licensed local partners, but we do not provide legal or regulatory guidance.
Please consult qualified professionals in your jurisdiction before making any investment or tokenization decisions.

Sources & References

  1. Službeni list (Official Gazette): https://www.sluzbenilist.me/
  2. Government of Montenegro (gov.me): https://www.gov.me/
  3. Central Bank of Montenegro (CBCG): https://www.cbcg.me/
  4. Capital Market Authority (SCMN): https://www.scmn.me/
  5. BDK Advokati (Capital Markets updates 2025): https://bdkadvokati.com/
  6. Investitor / Vijesti (local coverage): https://investitor.me/ | https://www.vijesti.me/
  7. Dukley Gardens (project case): https://dukleygardens.com/