Serbia Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Swedish International Development Cooperation Agency and the Council of Europe, Securities Commission of the Republic of Serbia, Bank of Serbia, Committee of Experts, Administration for the Prevention of Money Laundering, Tax Administration of the Republic of Serbia
Primary Legislation: This law defines digital assets, regulates their issuance and trading, and expli, Law on the Prevention of Money Laundering and Terrorist Financing (Zakon o spreč, This is the overarching AML/CFT law in Serbia, applying to all obliged entities,, Overview of Digital Assets Law and NBS role: https://www.petosevic.com/resources, This law, and its subsequent amendments, apply to VASPs as obliged entities., Serbia has not enacted a comprehensive, dedicated cryptocurrency or digital asset law as of 2025, Serbia has not adopted any law specifically governing cryptocurrency, virtual as, The primary general business regulation includes the Law on Investments, which e, The Law on Foreign Exchange Operations regulates capital movements and restricts, The Law on Prevention of Money Laundering and Terrorist Financing requires compa, Serbia's Law on Prevention of Money Laundering and Terrorist Financing requires, The AML law has caused some foreign companies to face difficulties opening bank
Travel Rule: Adopted — Threshold: Implemented
Tax Reporting: Defines "virtual currency" (kriptovaluta) as a digital record of value that is not issued or guaranteed by a central bank or public authority, nor necessarily linked to a fiat currency, but is accepted by natural or legal persons as a medium of exchange and can be transferred, stored, and traded electronically.. Defines "digital token" as a digital record of value or rights that can be electronically transferred and stored.. Regulates issuance, trading, and services related to digital assets.. Provides a legal basis for the application of existing tax laws to these assets.. Law on Digital Assets (Zakon o digitalnoj imovini): While a direct link to the consolidated text on a government portal can be elusive, the Serbian National Bank often provides information related to its scope. You can usually find the law's text on legal information portals or the Official Gazette website (e.g., Pravno-informacioni sistem Republike Srbije - PIS RS), but these require subscription or specific searches.

Key Facts

aml The main preventive law in the AML/CFT area is the Law on the Prevention of Money Laundering and the Financing of Terrorism, published in the Official Gazette of RS, Nos. 113/17 and 91/19 (the "AML/CFT Law"). Laws and regulations - Аdministration for the Prevention of Money Laundering The AML/CFT Law establishes the Administration for the Prevention of Money Laundering (APML) as the financial intelligence unit (FIU) of the Republic of Serbia. Laws and regulations - Аdministration for the Prevention of Money Laundering The AML/CFT Law identifies AML/CFT supervisory authorities which examine compliance with this law by obliged entities and stipulates sanctions for non-compliance. Laws and regulations - Аdministration for the Prevention of Money Laundering Under Article 84 of the AML/CFT Law, the APML is responsible for monitoring the implementation of the AML/CFT Law and using its powers to remove observed irregularities. Laws and regulations - Аdministration for the Prevention of Money Laundering The APML takes part in the preparation of concept papers aiming to improve the AML/CFT legislative framework and drafts and provides opinions concerning the uniform application of legislation. Laws and regulations - Аdministration for the Prevention of Money Laundering Serbia is evaluated by MONEYVAL, the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism, which is part of the FATF global network. Serbia A MONEYVAL Mutual Evaluation Report of Serbia was published in 2025, assessing the effectiveness of Serbia's measures against money laundering, terrorist financing, and proliferation financing, based on an on-site visit conducted in May 2025. Serbia As of March 2024, Serbia had 5 Recommendations rated Compliant and 35 Recommendations rated Largely Compliant in FATF evaluations. Serbia
custody Licensing Authority: The Law on Digital Assets designates two main regulators, depending on the nature of the digital asset: The National Bank of Serbia (NBS) supervises banks and financial institutions, but the regulation of virtual assets as means of payment is governed by the Law on Digital Assets, which establishes a separate regulatory framework from the NBS’s traditional supervision of payment systems. The Securities Commission (SC) supervises digital assets that qualify as financial instruments (e.g., security tokens, certain stablecoins). A legal entity providing services related to digital assets must obtain a license from the relevant authority. If a VASP intends to provide services for both types of digital assets, it might require licenses from both regulators or a combined license if stipulated. Eligible Entities: Only legal entities registered in Serbia can apply for a VASP license. Foreign entities cannot directly provide services without establishing a Serbian legal entity. Licensable Activities (including custody): The law defines "virtual asset services" that require a license, including: Receipt, transfer, and execution of orders related to digital assets. Exchange of digital assets for other digital assets.
enforcement Entity Targeted: Various domestic entities and individuals operating crypto asset exchange or custody services without the required licenses. While specific names are not always publicly disclosed with detailed penalties, the NBS has consistently emphasized its licensing requirements and taken steps against non-compliant entities. Violation Type: Operating a virtual asset service provider (VASP) without obtaining the necessary operating license from the NBS, as mandated by the Digital Assets Law. This includes facilitating the exchange of virtual assets for fiat currency or other virtual assets, or providing custody services. Penalty Amount: Administrative fines, cessation of operations. The Digital Assets Law (Article 109, Paragraph 1, Point 1 and 2) prescribes fines ranging from RSD 100,000 to RSD 5,000,000 for legal entities and RSD 10,000 to RSD 500,000 for responsible persons within the legal entity, along with potential protective measures like a ban on conducting business. Outcome: Several entities have either ceased operations, come into compliance, or faced administrative proceedings. The NBS continues to monitor the market for unlicensed activity. Entity Targeted: Individuals and organized criminal groups involved in large-scale crypto Ponzi schemes, investment fraud, and money laundering using virtual assets. Examples include actions related to the "Infinity Economics" scheme and connections to other global crypto scams like "Finiko.". Violation Type: Fraud, money laundering, unauthorized organization of games of chance (depending on the nature of the scheme), cybercrime. These often fall under general criminal statutes rather than specific "crypto violations.". Penalty Amount: Arrests, pre-trial detention, asset freezes (including virtual assets), criminal charges leading to potential prison sentences if convicted. Specific final conviction penalties (amounts/sentences) are rarely publicly detailed for each individual case by Serbian authorities, especially if investigations are ongoing or multi-jurisdictional. Outcome: Numerous arrests have been made, leading to ongoing investigations, indictments, and trials. Assets, including cryptocurrencies, have been seized. These cases are often complex and lengthy. Entity Targeted: Individuals and legal entities earning income from digital assets (e.g., capital gains from crypto trading, income from mining, staking, or providing crypto services). Violation Type: Tax evasion related to income or capital gains derived from digital assets. Penalty Amount: Varies significantly based on the amount of unpaid tax, plus interest and potential fines as per tax laws. Outcome: Increased tax compliance, with individuals and entities reporting and paying taxes on their crypto gains. Audits and enforcement actions against non-compliant taxpayers are conducted, though details are private unless criminal charges are filed. Outcome: Several entities have either ceased operations, come into compliance, or faced administrative proceedings. The NBS continues to monitor the market for unlicensed activity. Outcome: Numerous arrests have been made, leading to ongoing investigations, indictments, and trials. Assets, including cryptocurrencies, have been seized. These cases are often complex and lengthy. Outcome: Increased tax compliance, with individuals and entities reporting and paying taxes on their crypto gains. Audits and enforcement actions against non-compliant taxpayers are conducted, though details are private unless criminal charges are filed.
general €50,000 for virtual currency exchange services. €20,000 for digital token services (if not regulated by KHOV). €125,000 for safekeeping and administration of virtual currencies or digital tokens on behalf of third parties (custody). For services related to digital tokens that qualify as financial instruments (KHOV regulated): Capital requirements are generally higher and align with traditional investment firm requirements, which can range from €125,000 to €730,000, depending on the specific services (e.g., portfolio management, dealing on own account). VASPs are designated as obliged entities under the Serbian Law on Prevention of Money Laundering and Terrorist Financing. They must implement robust AML/CTF policies, procedures, and controls, including: Customer due diligence (CDD): Identifying and verifying the identity of clients, including beneficial owners. Ongoing monitoring: Regularly reviewing transactions and client relationships.
licensing This law defines digital assets, regulates their issuance and trading, and explicitly designates Virtual Asset Service Providers (VASPs) as obliged entities under the general AML/CFT law. It also sets out the licensing requirements for VASPs. Law on the Prevention of Money Laundering and Terrorist Financing (Zakon o sprečavanju pranja novca i finansiranja terorizma) Official Name: Закон о спречавању прања новца и финансирања тероризма Published: "Official Gazette of RS", No. 113/2017, 91/2019, 153/2020 (last amended) This is the overarching AML/CFT law in Serbia, applying to all obliged entities, including VASPs. It sets out the general rules for customer due diligence, suspicious transaction reporting, record-keeping, and internal controls. Exchange between virtual assets and fiat currencies. Exchange between one or more forms of virtual assets. Transfer of virtual assets.
securities Serbia has a functional legal framework for digital assets, with the Law on Digital Assets establishing a bifurcated regulatory regime: the Securities Commission of the Republic of Serbia regulates digital tokens, while the National Bank of Serbia regulates virtual currencies. Securities Commission of the Republic of Serbia issued two licences to service providers related to digital tokens Licensing is mandatory for service providers dealing with digital tokens, and the Securities Commission has actually granted licenses—two companies received licenses in March 2023 for services including order execution, exchange, custody, and portfolio management of digital tokens. Securities Commission of the Republic of Serbia issued two licences to service providers related to digital tokens The capital market legal framework is anchored in the Capital Market Law (Official Gazette of the Republic of Serbia, Nos. 129/2021 and 109/2025), with the Securities Commission as the primary regulator. Securities Commission adopts the Rulebook on tied agents The practical reality is that digital token regulation is operational but still developing, with the Securities Commission actively issuing investor guidance, adopting implementing rulebooks, and participating in international cooperation through IOSCO and Moneyval. Securities Commission of the Republic of Serbia For entities that issue digital tokens with securities characteristics, or provide services around them, obtaining a license from the Securities Commission is a real, viable path rather than theoretical—two licenses have already been granted as of March 2023. Securities Commission of the Republic of Serbia issued two licences to service providers related to digital tokens The Securities Commission of the Republic of Serbia (Commission/Komisija za hartije od vrednosti) is the independent and autonomous regulatory authority responsible for the Republic of Serbia capital market, headquartered in Belgrade at 1 Omladinskih brigada Street. About Us The Commission is a legal entity that operates as an independent and autonomous organization of the Republic of Serbia, accountable to the Assembly (National Assembly) of the Republic of Serbia. About Us The Commission is comprised of a Chairman and three Commissioners, all appointed by the National Assembly of the Republic of Serbia as full-time employees; the current X term of office took duties on 24 November 2021, led by Chairman Marko Janković. About Us
status Serbia has not enacted a comprehensive, dedicated cryptocurrency or digital asset law as of 2025–2026, and no specific crypto-asset legislation or licensing regime exists. Serbia - United States Department of State No regulatory body in Serbia has explicit statutory authority over virtual assets, and no licensing or registration obligations for crypto businesses exist. Serbia - Standards for Trade No entities have been licensed to conduct cryptocurrency exchange, custody, or wallet services under any Serbian framework. Serbia - United States Department of State Serbia's broader financial and investment regulatory framework is in place, but it does not specifically address digital assets; crypto activity exists in a legal gray area rather than under a defined authorization system. Serbia - State.gov The practical reality for a crypto business in Serbia is that it must operate within general company, tax, and AML laws, but without a specialized license or dedicated digital asset regulator. Serbia - EUR-Lex - Europa.eu The National Bank of Serbia is the central monetary authority in Serbia, but it has no virtual asset regulatory functions. Serbia - United States Department of State The Securities Commission (Komisija za hartije od vrednosti) oversees capital markets, but it has no digital asset authority. Serbia - United States Department of State The Ministry of Finance is designated as the competent authority to resolve appeals in expropriation matters, but it has no defined role in crypto regulation. Serbia - State.gov
tax Defines "virtual currency" (kriptovaluta) as a digital record of value that is not issued or guaranteed by a central bank or public authority, nor necessarily linked to a fiat currency, but is accepted by natural or legal persons as a medium of exchange and can be transferred, stored, and traded electronically. Defines "digital token" as a digital record of value or rights that can be electronically transferred and stored. Regulates issuance, trading, and services related to digital assets. Provides a legal basis for the application of existing tax laws to these assets. Law on Digital Assets (Zakon o digitalnoj imovini): While a direct link to the consolidated text on a government portal can be elusive, the Serbian National Bank often provides information related to its scope. You can usually find the law's text on legal information portals or the Official Gazette website (e.g., Pravno-informacioni sistem Republike Srbije - PIS RS), but these require subscription or specific searches. Applicability: Applies to the disposal of virtual currency, including: Sale of crypto for fiat currency (RSD, EUR, USD, etc.). Exchange of one virtual currency for another virtual currency.
travel rule Whether Adopted: Yes, adopted. Serbia incorporated the FATF Travel Rule principles into its national legislation, primarily through the Law on Digital Assets (Zakon o digitalnoj imovini). This law specifically designates the National Bank of Serbia (NBS) as the supervisory authority for virtual asset service providers (VASPs) concerning AML/CFT compliance. Effective Date: The Law on Digital Assets (Zakon o digitalnoj imovini) entered into force on June 29, 2021. The provisions related to AML/CFT, including those implementing the Travel Rule, became effective from this date. Threshold Amounts: Serbia generally follows the FATF Recommendation 16 for the Travel Rule. This means: For cross-border transfers of digital assets: The Travel Rule applies to transactions with a value of EUR 1,000 or more. For domestic transfers of digital assets: The Travel Rule also applies to transactions with a value of EUR 1,000 or more. The thresholds are typically calculated based on the value of the digital assets at the time of the transaction. Which VASPs are Covered: The Law on Digital Assets defines and covers a broad range of "providers of services related to digital assets" (VASPs) that are subject to AML/CFT obligations, including the Travel Rule. These typically include, but are not limited to: Digital asset exchanges (fiat-to-crypto, crypto-to-crypto).

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile