Montenegro’s amendments to its anti-money-laundering and terrorist-financing legislation have prompted a regional comparison on cash handling. Under the Montenegro changes, banks and other payment-service providers cannot receive cash deposits of €10,000 or more when the deposits relate to proceeds from the sale of property, vehicles, vessels and other movable or immovable assets. That development raised the question of whether Serbia has a comparable restriction and whether Serbian banks could face tighter cash-deposit limits.
- Serbia’s €10,000 cash-receipt restriction for goods, real estate and services
- How the rule applies to private loans and real-estate purchases
- Bank deposits versus direct cash receipt
- Reporting threshold for cash transactions at €15,000 and suspicious activity
- Customer due diligence and possible refusal by banks
- Operational implications for businesses handling payments above €10,000
- Foreign-currency cash restrictions and exchange-office due diligence
- NBS position on potential changes to Serbia’s thresholds
Serbia’s €10,000 cash-receipt restriction for goods, real estate and services
In Serbia, the National Bank of Serbia describes a different framework for restricting high-value cash acceptance. Under the Serbian Law on the Prevention of Money Laundering and Terrorist Financing, a person selling goods or real estate, or providing services in Serbia, may not receive cash from a customer or third party amounting to €10,000 or more in dinar equivalent. The rule applies regardless of whether the payment is made through one transaction or several mutually connected cash transactions.
The Serbian limit also covers situations where payments relate to one or several contracts within a period of one year. Instead of cash receipt at that threshold, the amount must be paid into a bank account. The practical effect is that buyers cannot hand over €10,000 or more in cash directly to sellers or service providers for covered transactions.
How the rule applies to private loans and real-estate purchases
The same restriction extends to private individuals receiving cash under a loan agreement or a real-estate purchase agreement. For example, a private person selling an apartment or receiving money under a loan agreement cannot legally treat €10,000 or more as a hand-to-hand cash payment if the threshold is crossed. In those cases, the transaction has to pass through a bank account.
The rules do not remove cash from everyday commerce. Serbia continues to use cash widely in retail, small services, hospitality, local trade and household transactions. The legal line is drawn between routine cash use and high-value payments that can conceal undeclared income, tax evasion, corruption proceeds or criminal assets.
Bank deposits versus direct cash receipt
A separate clarification concerns how bank deposits are treated compared with direct cash receipt by an individual. A cash deposit of €10,000 or more into the bank account of the seller or recipient is not handled in the same way as direct handover of cash to that person. This places the banking channel as the controlled route through which high-value cash must pass.
Banks can record transactions, identify customers, apply internal risk rules, ask questions, request documents and either report activity where required or refuse to execute it. As a result, compliance obligations fall heavily on banks and other obliged entities rather than only on counterparties exchanging cash.
Reporting threshold for cash transactions at €15,000 and suspicious activity
The law requires reporting of cash transactions of €15,000 or more in dinar equivalent to the Administration for the Prevention of Money Laundering. This reporting threshold operates separately from the €10,000 limit on receiving cash for goods, services, real estate and certain private contracts. Together, they restrict how high-value cash can be accepted while ensuring larger amounts entering the financial system are visible to authorities.
Banks also must report suspicious transactions regardless of amount. A transaction below €15,000 can still trigger scrutiny if risk analysis indicates possible money laundering, terrorist financing or financing of weapons proliferation. Compliance is therefore not limited to mechanical thresholds; banks are expected to understand customers, transaction purpose and source of funds.
Customer due diligence and possible refusal by banks
Banks may request evidence explaining where funds originate when customers deposit significant amounts. Examples listed include sale contracts, inheritance decisions, loan agreements, salary records, tax documentation and dividend documentation. Other documentation may include business-income evidence and proof that funds were withdrawn from another bank.
If banks cannot complete required customer due-diligence measures—including assessing whether source-of-funds information is credible—they must refuse the transaction or refuse to establish a business relationship. The level of scrutiny can differ between customers with similar amounts because risk profiles may vary across long-standing clients with documented activity and new clients with unclear income or complex ownership links.
Operational implications for businesses handling payments above €10,000
For businesses selling expensive goods, real estate, professional services, vehicles and equipment—or undertaking construction works—cash cannot be treated as a neutral payment method above €10,000. Companies need documented bank payments supported by clear contracts, invoices and payment references that create accounting trails. The sectors highlighted as having traditionally higher exposure to cash include construction, property brokerage, vehicle sales, luxury retail and private healthcare.
The rule also affects hospitality, transport services and professional advisory services where large-value transactions may occur. Large cash payments are described as difficult to reconcile with VAT records and corporate-income reporting as well as personal-income reporting and beneficial-ownership checks. When payments move through bank accounts instead of remaining solely in cash form, it becomes easier for tax authorities, auditors and financial-intelligence bodies to connect payments with contracts and declared sources.
Foreign-currency cash restrictions and exchange-office due diligence
The National Bank of Serbia notes that payment in effective foreign cash in Serbia is allowed only exceptionally under secondary legislation based on the foreign-exchange law. The exceptions include certain sales at international airports; fuel and lubricant sales to foreign aircraft and vessels; international passenger transport services; and motorway tolls for vehicles with foreign registration. Outside those defined cases, payment for domestic services or real estate in Serbia cannot be made in foreign cash regardless of amount.
The rules also extend to currency exchange operations. For exchange transactions of €5,000 or more in dinar equivalent, obliged exchange operators must apply customer due-diligence measures including identity verification and assessment of purpose and source aligned with risk. The lower threshold reflects that currency exchange can be used to convert cash before or after another transaction within money-laundering schemes.
NBS position on potential changes to Serbia’s thresholds
The regulatory direction described by Serbia’s central bank indicates no move toward loosening current limits. The National Bank of Serbia said it is not aware of initiatives aiming to reduce the current €10,000 cash-acceptance limit or change the €15,000 mandatory reporting threshold. It also indicates that existing frameworks already give banks room to scrutinise transactions more closely through risk-based controls.
The comparison with Montenegro remains limited because Montenegro’s change created a visible new rule focused on deposits linked to property and asset-sale proceeds. Serbia already operates an anti-money-laundering architecture covering merchants and service providers as well as real-estate transactions and private loans alongside bank deposits at obliged entities including exchange offices and reporting obligations tied to suspicious activity.
