Mobing u Crnoj Gori activities, including processing criminal proceeds from gambling and large-scale trafficking of narcotics. Examples include: • In October 2015, the Finance Ministry’s Administration for the Prevention of Money Laundering and Terrorist Financing (‘APMLTF’) launched investigations into six unnamed Montenegrin 24 banks suspected of money laundering. • In November 2018, investigative media cited suspicions by the EU anti-laundering authorities that the 14K Triad group engaged in illegal gambling, extortion, prostitution, credit card fraud and drug trafficking at Universal Capital Bank (‘UCB’). The FBI suspects that its head is the 25 Malaysian businessman Paul PHUA, who is politically connected in Montenegro. • A stated in section 2.3, Prva Banka is suspected of having engaged in money-laundering, among other activities. • As stated in section 2.4, Atlas Bank is suspected of having engaged in money laundering worth EUR 500 million. • As stated in section 2.5, Nova Banka is suspected of having been purchased via an offshore money-laundering scheme. • Contrary to the IMF’s Article IV report stating repeatedly that Montenegro has too many 26 27 banks, the procedure of licensing of another bank is underway. 2.8 Nepotism in CBM recruitments • ZUGIC’s term at CBM has been characterised by large-scale nepotism that has resulted in family members and associates being recruited to senior positions. Examples include: • His nephew, IVAN BOSKOVIC, is a CBM director and member of the CBM tender/public 28 procurement committees. BOSKOVIC’s spouse and ZUGIC’s daughter-in-law, ANA BOSKOVIC, works in CBM HR. Ana’s aunt, Nadja MAROVIC, is ZUGIC’s chief legal advisor. Their best man, Aleksandar TERZIC, is a former porter who works as the CBM’s 29 director of security, investments and public procurement. • His uncle, MLADJAN SLJIVANCANIN, serves as his advisor.30 • His niece, Dara PRELEVIC, works in CBM Banking Operations & Secretary General of the Reserve Management Committee. • His daughter, JOVANA ZUGIC, started working at OTP CKB bank in July 2018 as a precondition for the approval of its merger with Societe Generale. • His daughter, MILICA ZUGIC, has changed between increasingly senior positions at Nova, UCB and Zapad banks since ZUGIC reassumed the CBM governorship in October 2016. • His nephew, NIKOLA BOSKOVIC, is head of risks at Addiko bank. • His nephew, IGOR SLJIVANCANIN is contracted by the CBM as a photographer. • His son-in-law, NIKOLA TOMOVIC, serves as Head of CBM Transport and Security department and ZUGIC’s personal driver. • His cousin, BOJANA STANISIC SUPELJAK, is in charge of Media & Protocol and serves 31 concurrently as Director of the CBM Museum. 24 https://www.intellinews.com/six-montenegrin-banks-suspected-of-failing-to-comply-with-money- laundering-law-82457/ 25 https://theblacksea.eu/stories/football-leaks-2018/paul-phua-gambler-montenegro/ https://www.vijesti.me/vijesti/drustvo/kako-je-clan-kineske-trijade-kupio-crnogorsku-obalu 26 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 27 https://www.mina.news/minabusiness/u-toku-postupak-osnivanja-nove-banke/ 28 http://www.vijesti.me/ekonomija/zaposljavanje-u-cbcg-kcerke-snahe-sestrici-sinovi-113625 29 https://www.vijesti.me/vijesti/ekonomija/terzic-nisam-znao-da-je-radoje-zugic-ujak-mom-kumu 30 https://www.vijesti.me/vijesti/ekonomija/smijenjeni-guverner-albanije-i-zugicev-ujak-savjetuju-cbcg 31 https://www.vijesti.me/vijesti/ekonomija/doktorirali-kod-knezevica-pa-ga-zaobilazili-za-kontrolu 195