Serbia AML 2025: What changed
Serbia’s 2025 AML/CFT reform (including amendments to the Law on the Prevention of Money Laundering and Terrorist Financing) has materially raised the bar for bank onboarding in Serbia. Enhanced customer due diligence (CDD), stricter beneficial ownership (UBO) transparency and a more rigorous risk-based approach now directly shape bank decision-making.
The overlooked trigger: APR non-compliance
A separate—and often overlooked—trigger arises from beneficial ownership compliance in Serbia. The Serbian Business Registers Agency (APR) maintains the central register of beneficial owners and publishes a non-compliance list of entities that have not met the applicable UBO disclosure requirements. In practice, inclusion on this list is treated by banks as an elevated AML risk indicator.
Where such issues are present, banks will typically require enhanced CDD, including, where relevant, retrospective (“look-back”) checks on ownership and control. This applies even where the client is already banked, as prior onboarding may not have captured the full UBO profile in line with current AML standards.
Transaction impact and execution risk
In a transaction context, this may affect multiple stages—buyer due diligence, pre-signing compliance, conditions precedent (CP) to closing or post-closing undertakings. If not addressed early, it may delay deal execution, restrict account operability or, in certain cases, prevent the bank from proceeding.
The issue is not the legal permissibility of the structure, but whether it can be reconciled with the bank’s internal AML risk framework, documentary expectations and correspondent banking constraints. That is where otherwise viable transactions tend to fail.
Managing the risk
In practice, these risks are managed through early alignment with the bank, supported by a structured KYC approach, and, where necessary, targeted pre-closing steps and post-closing undertakings to complete outstanding CDD and UBO compliance requirements.
Author: Stefan Jovičić, Partner, banking & finance / corporate and M&A
