Mobing u Crnoj Gori investigations into the CBM’s management of Atlas Bank, which included suspicions 11 that it had been complicit in the laundering of EUR 500 million in funds through the bank. 12 ZUGIC was among the suspects investigated. However, the State Prosecution later informed parliament that the case had been closed, with no charges being filed. His reasoning and lack of 131415 action has been questioned. • Atlas Bank was also associated with the now disgraced Meinl Bank in Austria that lost its banking licence in November 2019. Meinl owns several properties in Montenegro.16 2.5 Nova Banka – violation of banking law • In January 2020, ZUGIC authorized the purchase of Nova Banka by a Delaware-based 17 offshore company with anonymous owners. He refused to reveal the identity of the owners, despite their company – Adriatic Capital LLC – sharing an address with 13 other companies and possessing only USD 88,000 in capital, despite the value of the purchase being EUR 7.1 18 19 million. The decision violated Montenegro’s banking law and was also contrary to the IMF’s 20 request that bank owners and managers be subjected to a fit and proper test. 2.6 Failure to implement IMF and World Bank recommendations on Asset Quality Review (‘AQR’) 21 22 • Since 2015, the IMF and World Bank have repeatedly called for the CBM to conduct an AQR of banks in order to diagnose health of banks, consolidate the oversaturated banking sector, as well as the strengthening of banking supervision and anti-money laundering measures. However, in practice this has not transpired, with Montenegro remaining the only European country that has consistently evaded its commitment to implementing AQR, since 2015 FSAP Mission recommendations. New AQR Deadline set in latest IMF Article IV report is now the end of 2020 with significant ongoing delays by the CBM. If AQR is completed correctly, by international independent assessors, by the end of 2020 then according to one analyst the President’s brother, Aco Djukanovic would need to inject €50million to recapitalise 23 Prva Bank. 2.7 Proliferation of banks during CBM tenure • Since ZUGIC became CBM governor in 2010, the number of banks in Montenegro has multiplied threefold, despite IMF warnings. Many of those banks have been linked to illicit 11 https://www.slobodnaevropa.org/a/atlas-banka-malverzacije/29641342.html https://borba.me/potvrdjeno-pisanje-borbe-preko-atlas-banke-oprano-500-miliona-evra/ 12 https://borba.me/borba-saznaje-u-sdt-u-istrazitelji-provjeravaju-i-radoja-zugica-zbog-atlas-banke/ 13 https://www.occrp.org/en/investigations/prosecutors-drop-investigation-into-millions-missing-from- montenegro-bank 14 https://borba.me/medjunarodna-istraga-prvu-banku-provjeravaju-zbog-pranja-prljavog-novca/ 15 https://www.vijesti.me/vijesti/ekonomija/tuzilastvo-cuti-o-svom-predmetu-u-vezi-depozita-atlas-banke 16 https://www.vijesti.me/vijesti/ekonomija/pala-meinl-banka-sporni-poslovi-i-u-crnoj-gori 17 https://www.vijesti.me/vijesti/ekonomija/novu-banku-kupili-preko-majamija-i-delavera 18 https://www.dan.co.me/?nivo=3&rubrika=Ekonomija&clanak=730291&datum=2020-01-22 19 https://www.vijesti.me/kolumne/rapid-resolution 20 https://www.imf.org/en/Publications/CR/Issues/2019/09/09/Montenegro-2019-Article-IV-Consultation- Press-Release-Staff-Report-and-Statement-by-the-48667 21 https://www.imf.org/external/pubs/ft/scr/2016/cr1688.pdf 22 http://documents.worldbank.org/curated/en/652681467988911202/Montenegro-Financial-Sector- Assessment-Program-FSAP-deposit-insurance-system-technical-note 23 https://www.dan.co.me/?nivo=3&rubrika=Ekonomija&clanak=727940&datum=2020-01-03 194