On 6 December 2024, the Law on Amendments to the Law on Prevention of Money Laundering and Financing of Terrorism and the Law on Amendments to the Law on Public Notaries entered into force. These two laws were adopted by the National Assembly of the Republic of Serbia and published in the Official Gazette of the Republic of Serbia on 28 November 2024.
Starting tomorrow, the solemnization of loan agreements between natural persons in the amount of EUR 10,000 and higher, calculated in accordance with the middle exchange rate of the National Bank of Serbia (NBS) on the date of the solemnization, will be mandatory. In addition, public notaries will be obliged to submit such agreements to the Administration for the Prevention of Money Laundering.
A month ago, our partner Jelena Stanković Lukić provided a detailed analysis of the proposed amendments to the Law on Public Notaries. For more details, please visit the following link: [https://www.jpm.law/proposal-for-the-amendment-of-the-law-on-public-notaries/].
The Law on Amendments to the Law on the Prevention of Money Laundering and Financing of Terrorism stipulates that anyone engaged in the sale of goods, real estate, or the provision of services in the Republic of Serbia is prohibited from accepting cash payments of EUR 10,000 or higher (in RSD equivalent) for goods or services. This applies whether the payment is made in a single transaction in multiple related cash transactions, or in the case of one or more agreements within one year. Such payments must be deposited into a bank account. This restriction also applies to natural persons receiving cash under loan agreements or agreements for the sale of real estate.
The reason behind these amendments to the law on preventing money laundering and financing of terrorism is the recommendations resulting from the work of the Expert Team of the Coordination Body for Preventing Money Laundering and Financing of Terrorism, regarding the risk assessment in the real estate sector. These amendments aim to mitigate risks in this sector by limiting transactions involving the purchase and payment in cash for natural persons. Additionally, these amendments address the risks related to usury crimes, prohibiting the receipt of cash in amounts of EUR 10,000 or higher, based on loan agreements.
By Katarina Rosic, Senior Associate, JPM Partners
