---
title: "Serbia Crypto Regulation Monitor | cryptoassets.gi"
canonical: https://cryptoassets.gi/jurisdictions/serbia/
source_html: /jurisdictions/serbia/index.html
description: "Serbia crypto asset regulation: 8 categories, 59 sourced findings, updated 2026-10-25. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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# Serbia Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed regulated overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/serbia/), [World Payments](https://payments.gi/jurisdictions/serbia/)

Last updated 2026-10-25 · 8 categories · 59 sourced
findings · 26 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-10-25 · Position last changed: 2026-10-25 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

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Framework posture Regulated 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority National Bank of Serbia Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) None scheduled No dated future statutory milestone on record

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

8 Categories

0 Moved this cycle 0 Key judgments 4 Open gaps 59 Findings

15 Tier-1 sources

Confidence mix 8 unpopulated
(sums to 8 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 25 October 2026

#### Lead Signal

Serbia's virtual-asset cross-border compliance posture has improved materially, per direct confirmation from MONEYVAL. Serbia has taken measures since November 2021 to ensure implementation of the FATF travel rule by virtual-asset service providers and to exchange prudential and AML/CFT information on virtual-asset matters, a development that upgraded FATF Recommendation 15 from Partially Compliant to Largely Compliant. This is a concrete, Tier 1-sourced improvement in Serbia's cross-border virtual-asset compliance architecture, distinct from and additive to the country's already-established licensing regime for virtual-currency service providers under the 2021 Law on Digital Assets.

#### Other Developments

No other crypto-module developments are authorised for composition; the remaining seven modules (Crypto Licensing, Token Classification, On-Chain Activity Regime, Stablecoin Regime, Consumer Protection, Tax Treatment, AML/CFT Regime) are stable and their previously published narratives stand as-is.

#### Cross-Monitor Connections

The Cross-Border Transfer finding shares its underlying evidentiary basis with the financial integrity monitor's D5 (Crypto, Digital Assets, and Financial Innovation) finding for Serbia, both drawing on the identical MONEYVAL confirmation of Serbia's travel-rule implementation and R.15 upgrade. Readers tracking Serbia's digital-asset compliance trajectory across both monitors should read these two findings as mutually reinforcing rather than independent observations, since they derive from the same underlying MONEYVAL assessment.

#### Outlook

The development to watch is whether Serbia's travel-rule implementation translates into concrete VASP-level operational compliance evidence, such as documented travel-rule message exchange between Serbian VASPs and foreign counterparts, which would move this finding from an assessment-level confirmation to an operationally corroborated fact in a future cycle.

1 earlier update not shown here.

###### Standing brief · as of 25 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Serbia's digital-asset regime enters this monitoring cycle anchored by a mature, operative dual-regulator licensing structure. Since 29 June 2021, the National Bank of Serbia (NBS) has held the statutory licensing competence for virtual currency service providers, while the Securities Commission of the Republic of Serbia runs a parallel track licensing digital-token service providers and approving white papers for public token offerings. Both competences sit within the same Law on Digital Assets (RS Official Gazette No 153/2020). The regime carries real teeth: providing virtual currency services without an NBS licence is not merely an administrative breach but a criminal offence under the Criminal Code, a position the NBS has restated in public enforcement warnings. Those same warnings extend the licensing perimeter to foreign entities, which must first establish a Serbian company and obtain an NBS licence before serving Serbian residents through a branch, representative office, or other market-targeting activity -- effectively a market-entry barrier rather than a passporting regime. Supervisory practice has matured unevenly: an NBS report noted that as of end-2021 the first licence applications had been filed but none had yet been granted, a historical marker of the regime's early operational ramp rather than a live constraint. Taken together, this positions Serbia among the more comprehensively licensed Western Balkan EU-candidate jurisdictions for digital-asset activity, with an active public register and ongoing enforcement posture against unlicensed operators.

#### Other Developments

Beneath the licensing spine, token classification follows a three-way statutory taxonomy -- virtual currency, digital token, and a residual hybrid category jointly supervised by the NBS and Securities Commission where an asset exhibits features of both. Digital tokens with financial-instrument characteristics face an aggregate issuance threshold of EUR 3,000,000 per issuer per 12-month period, below which registration exemptions apply and above which Securities Commission licensing and white-paper approval become mandatory. On-chain activity coverage is narrower: tokenization and issuance (including digital-asset crowdfunding) are addressed through the same white-paper mechanism, and mining is treated as excluded from the licensing perimeter on the basis of mining activity alone -- though this exclusion currently rests on secondary reporting rather than a directly corroborated primary-statute citation, holding that finding at Probable confidence pending closer text verification. Staking, DeFi lending, decentralised exchange operation, and validator-level activity remain unaddressed in the statute, consistent with its 2020/2021 vintage predating the more recent wave of on-chain activity typologies.

Stablecoin-type instruments have no bespoke regime: absent any MiCA-style ART/EMT distinction, reserve requirement, redemption right, or systemic-designation mechanism, such tokens fall back entirely on the general digital-token white-paper regime, with the same EUR 3,000,000 threshold and disclosure obligations applying as for any other token issuance. Consumer protection is comparatively well-developed on the disclosure side: an approved white paper must contain issuer, asset, and risk information sufficient for an informed investment decision, and the NBS separately mandates prescribed record-keeping for virtual-currency service providers holding user money or virtual currencies. The NBS also maintains a non-binding public advisory discouraging citizens from investing in virtual currencies, citing volatility and the absence of any central-bank or public-authority guarantee. A marketing restriction -- prohibiting advertising and limiting distribution of tokens issued without an approved white paper -- is asserted this cycle but rests on secondary (CoinDesk) sourcing rather than direct primary-statute confirmation.

Tax treatment remains the thinnest module in this baseline. The only Tier-1-confirmed instrument is an NBS regulatory reporting obligation -- distinct from any tax-return filing -- requiring persons who acquired virtual currency other than through a licensed provider to report their holdings. No primary Ministry of Finance or Tax Administration source was reached this cycle addressing capital-gains rate, mining/staking income characterisation, VAT treatment, or withholding, despite consistent secondary reporting describing a flat capital-gains rate and other mechanisms; those remain open research gaps rather than confirmed findings. Cross-border transfer activity is narrowly but firmly anchored by the same foreign-provider market-entry restriction noted above -- a binding barrier requiring local incorporation and licensing -- while dedicated travel-rule or cross-border reporting-threshold mechanisms specific to digital assets were not identified and are understood to sit primarily within the AML/CFT framework.

#### Cross-Monitor Connections

This cycle's AML/CFT module was intentionally left claim-empty for Serbia: travel-rule application, sanctions screening, and related illicit-finance obligations for Serbian virtual-asset service providers are the subscribed surface owned by the financial-integrity monitor's AML/CFT module, with this record carrying only disambiguation context. Serbia underwent a MONEYVAL/FATF mutual evaluation with an on-site visit in May 2025, a development relevant to that adjacent monitor rather than to this one directly. Separately, the absence of a dedicated stablecoin regime and the unresolved state of digital-asset tax treatment both carry payments-adjacent and cross-border tax-reporting dimensions that intersect with the world-payments monitor's coverage, without this record asserting any additional payments-specific finding of its own.

#### Outlook

The near-term trajectory for Serbia's digital-asset framework is one of consolidation rather than near-term legislative overhaul: the core licensing architecture is stable and enforced, but several structural gaps -- stablecoin-specific rules, NFT classification, staking and DeFi treatment, and confirmed tax mechanics -- sit explicitly pending any future EU-candidacy alignment exercise rather than an imminent domestic reform. Two specific items remain held pending primary-source verification before they can be asserted as confirmed findings: a widely-reported flat capital-gains tax rate on digital-asset disposals, and a described mandatory complaint-handling obligation for digital-asset service providers. Both rest at present on consistent but Tier-4-only secondary sourcing, and the composed record's publication gate remains held pending regulator or primary-statute confirmation of either point.

Read full brief · 1182 words

Key regulatory facts for Serbia Regulatory Dimension Serbia Standing Position

Jurisdiction Serbia (RS)

Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 59 sourced findings)

Crypto Licensing Serbia operates a comprehensive, in-force licensing statute for digital assets — the Law on Digital Assets (RS Official Gazette No 153/2020), applied since June 2021 — that splits supervisory competence between the...

Token Classification The Law on Digital Assets recognises two statutory categories — virtual currencies and digital tokens — plus a residual 'hybrid' category with joint NBS/Securities Commission competence.

On-Chain Activity Regime The Law on Digital Assets regulates digital-token issuance and secondary trading (a form of tokenization) and expressly excludes mining from its licensing scope.

Stablecoin Regime Serbia has no MiCA-style dedicated stablecoin regime (no ART/EMT distinctions, reserve-asset rules, redemption-right provisions, or systemic-designation mechanism).

Primary Instruments Cited National Bank of Serbia, National Bank of Serbia, National Bank of Serbia, CoinDesk, National Bank of Serbia

Last Confirmed / Updated 2026-10-25 (26 sources in cumulative register)

8 of 8 categories

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### Serbia: C1 Crypto LicensingGreenEnacted in forceModule confidence: Probable▾

Serbia operates a comprehensive, in-force licensing statute for digital assets — the Law on Digital Assets (RS Official Gazette No 153/2020), applied since June 2021 — that splits supervisory competence between the National Bank of Serbia (virtual currencies) and the Securities Commission (digital tokens characterised as securities). This places Serbia genuinely ahead of most Western Balkan EU-candidate peers, though full MiCA alignment remains a future candidacy-linked step, not current law.

Open gap — crypto-int-1 Whether NBS has issued 2026 guidance updating the 16 Dec 2022 VASP-licence cohort (only two confirmed licensed firms) not confirmed this cycle. no under-indexing note recorded

Open gap — crypto-int-2 Whether the Securities Commission approved any new digital-token White Paper in the recency window not confirmed this cycle. no under-indexing note recorded

#### Crypto Licensing

Serbia operates one of the more mature digital-asset licensing architectures among Western Balkan EU-candidate states, structured around dual regulators acting under a single statute. The National Bank of Serbia (NBS) holds the licensing competence for virtual currency services, granting and administering licences required for anyone providing virtual currency services in Serbia. Running in parallel, the Securities Commission of the Republic of Serbia licenses digital-token service providers and approves white papers for public offerings of digital tokens. Both competences derive from the Law on Digital Assets (RS Official Gazette No 153/2020), in force since 29 June 2021.

The regime is backed by a criminal-law enforcement mechanism rather than purely administrative sanction: the NBS has issued a public warning notice reiterating that providing virtual currency services without a prior NBS licence is prohibited and constitutes a criminal offence under the Criminal Code. That same warning notice establishes a distinct market-entry constraint for foreign firms -- a company intending to serve the Serbian market must first establish a Serbian entity and obtain an NBS licence before providing virtual currency services through a branch or representative office. This functions as a de facto localisation requirement rather than a passporting or equivalence mechanism, and it is cross-referenced within the cross-border transfer module of this record as the same underlying restriction viewed from a market-access angle.

One further exclusion from the licensing perimeter concerns mining: the statute is understood to exclude acquisition of digital assets by mining from its licensing scope, though this finding currently rests on secondary reporting (CoinDesk) rather than a directly verified primary-statute citation, and is therefore held at Probable rather than Confirmed confidence pending closer textual corroboration.

Supervisory practice took time to mature operationally. An NBS report covering 2021 noted that the first virtual-currency service-provider licence applications had been filed by year-end but that no licence had yet been issued -- a historical, non-normative marker of the regime's early ramp-up rather than an ongoing constraint, and treated accordingly without a forced regulatory-stage classification.

A metadata inconsistency was noted but not treated as substantive: run-level source-tier counts recorded zero Tier-1/Tier-2/Tier-3 sources despite the source register independently confirming correct Tier-1/Tier-2 tiering for the NBS and Securities Commission pages actually cited by Confirmed claims in this module. This is understood as a research-pipeline counting artefact rather than a genuine sourcing gap, and no confidence downgrade was applied on that basis.

#### Outlook

The licensing architecture itself shows no signs of near-term structural change; it is the most settled and best-evidenced module in this baseline. The principal open items are evidentiary rather than substantive: independent verification of the mining exclusion against primary statute text, and continued monitoring of licensing throughput now that the regime has moved past its initial 2021 ramp-up period. The foreign-provider restriction remains a durable feature of the regime and a recurring reference point wherever cross-border market access to Serbian users is assessed.

Read full sub-brief · 481 words No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (12)
- T1[National Bank of Serbia](https://www.nbs.rs/en/ciljevi-i-funkcije/nadzor-nad-finansijskim-institucijama/digital-imo/) — The National Bank of Serbia grants and administers the licence required for the provision of virtual currency services in the Republic of Serbia.
- T1[National Bank of Serbia](https://www.nbs.rs/export/sites/NBS_site/documents/finansijska-stabilnost/podaci/ForeigInvestorsGuide.pdf) — The Securities Commission of the Republic of Serbia issues licences for the provision of digital-token services and approves white papers for digital-token public offerings.
- T1[National Bank of Serbia](https://www.nbs.rs/en/scripts/showcontent/index.html?id=20378&konverzija=no) — Providing virtual currency services without a prior licence from the NBS is unauthorised and not allowed under the Law on Digital Assets, and also constitutes a criminal offence under the Criminal Code.
- T1[National Bank of Serbia](https://www.nbs.rs/en/scripts/showcontent/index.html?id=20378&konverzija=no) — Virtual currency services cannot be provided through a branch or representative office of a foreign company targeting Serbian citizens; a foreign company intending to serve the Serbian market must first establish a company in Serbia and obtain an NBS licence.
- T3[CoinDesk](https://www.coindesk.com/policy/2020/12/30/serbia-legalizes-digital-assets-trading-and-issuance) — Mining of digital assets falls outside the licensing scope of the Law on Digital Assets; persons who acquire digital assets by mining are permitted to do so without triggering the Law's service-provider licensing obligations.
- T1[National Bank of Serbia](https://nbs.rs/en/scripts/showcontent/index.html?id=17677) — As of end-2021, the first virtual-currency service-provider licence applications had been filed with the NBS, but no such licence had yet been issued, indicating an early operative but still-maturing supervisory practice.
- T1[National Bank of Serbia](https://www.nbs.rs/en/scripts/showcontent/index.html?id=20378&konverzija=no) — Virtual-currency service providers must obtain an NBS licence; providing such services without one is unauthorised and a criminal offence under the Criminal Code.
- T1[Serbia (Law on Digital Assets)](https://www.nbs.rs/en/scripts/showcontent/index.html?id=20378&konverzija=no) — A foreign company must first establish a Serbian company and apply for an NBS licence before serving the Serbian market; a foreign branch/representative office cannot provide services directly.
- T3[National Bank of Serbia](https://statt.rs/crypto-regulation-serbia-2026-guide/) — Virtual-currency services (exchange, custody, transfer, brokerage) require NBS authorisation prior to provision; unlicensed provision is a criminal offence per NBS public guidance.
- T3[Securities Commission of the Republic of Serbia](https://practiceguides.chambers.com/practice-guides/fintech-2026/serbia/trends-and-developments) — Digital-token issuance/public offering requires Securities Commission White Paper approval; no licence required to act as issuer.
- T1[National Bank of Serbia](https://www.nbs.rs/en/ciljevi-i-funkcije/nadzor-nad-finansijskim-institucijama/digital-imo/) — Licence required for provision of virtual-currency services in or into Serbia; unlicensed provision is a criminal offence.
- T1[Law on Digital Assets / Criminal Code](https://www.nbs.rs/en/ciljevi-i-funkcije/nadzor-nad-finansijskim-institucijama/digital-imo/) — Unauthorised provision of virtual-currency services is treated as a criminal offence; specific fine/sentencing scale not located at pinpoint level.

### Serbia: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable▾

The Law on Digital Assets recognises two statutory categories — virtual currencies and digital tokens — plus a residual 'hybrid' category with joint NBS/Securities Commission competence. Digital tokens with the features of a financial instrument are conditionally exempt from capital-markets registration below an EUR 3,000,000/12-month issuance threshold. MiCA-aligned categories (ART, EMT) and NFT-specific treatment are not separately codified in the material reviewed.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-10-25

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### Serbia: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable▾

The Law on Digital Assets regulates digital-token issuance and secondary trading (a form of tokenization) and expressly excludes mining from its licensing scope. No statutory provisions addressing staking, DeFi lending, DEX operation, node operation or validator activity were identified in the primary law or secondary NBS/Securities Commission decisions reviewed in this pass.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-10-25

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### Serbia: C4 Stablecoin RegimeRedEnacted in forceModule confidence: Probable▾

Serbia has no MiCA-style dedicated stablecoin regime (no ART/EMT distinctions, reserve-asset rules, redemption-right provisions, or systemic-designation mechanism). The closest operative instrument is the general digital-token white-paper issuance-authorisation and disclosure regime administered by the Securities Commission, which would apply to any stablecoin-type token issued in Serbia absent a bespoke category.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 7 traced claims · Re-verified 2026-10-25

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### Serbia: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾

Consumer protection is delivered mainly through mandatory white-paper risk disclosure, advertising restrictions on unapproved-white-paper assets, and record-keeping requirements for providers holding user money or virtual currencies. The NBS also issues periodic public risk-warning advisories against investing in virtual currencies. No dedicated statutory complaint-handling or suitability/appropriateness-assessment regime for retail digital-asset customers was identified.

#### Consumer Protection

Consumer protection obligations in Serbia's digital-asset regime are concentrated on disclosure, marketing restraint, and custody record-keeping, all anchored in the Law on Digital Assets. A published white paper at issuance must contain risk information sufficient for investors to make an informed decision, mirroring the same disclosure standard applicable under the token-classification and stablecoin modules of this record. A related marketing restriction prohibits advertising of, and limits distribution of, digital assets issued without an approved white paper -- though this specific finding is sourced to secondary reporting (CoinDesk, Tier-4) rather than direct primary-statute text, and a Tier-1 cross-check against the statute is recommended before it is treated as fully corroborated.

On the custody side, the NBS requires prescribed record-keeping by virtual-currency service providers holding user money and/or virtual currencies, under a dedicated Decision on the Contents and Form of Records Kept by such providers (RS Official Gazette No 49/2021) -- a Tier-1-sourced obligation. Separately, and outside any binding legal obligation, the NBS maintains a public advisory practice discouraging citizens from investing in virtual currencies or engaging in virtual-currency transactions, citing high value fluctuations and the absence of any central-bank or public-authority guarantee; this is treated as non-binding supervisory communication rather than a legal requirement.

A more contested question concerns complaint-handling. Secondary sources describe mandatory complaint-handling procedures for digital-asset service providers under the Law on Digital Assets, which would represent a materially different picture from a simple absence-of-provisions framing. All cited evidence for this point is Tier-4, and primary statute-text confirmation is required before it can be asserted as a positive finding; this item remains an open research gap rather than a composed claim in this cycle. No dedicated statutory suitability or appropriateness-assessment obligation for digital-asset advisory or portfolio-management services was identified either, and this too remains an open item for further research.

#### Outlook

The disclosure and custody strands of consumer protection are well-anchored and unlikely to see near-term change. The principal open item is the complaint-handling question: resolving whether the Law on Digital Assets does in fact impose a mandatory complaint-handling obligation, as several secondary sources suggest, would meaningfully change this module's completeness and is the most consequential single verification task carried forward from this cycle.

Read full sub-brief · 367 words No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (10)
- T1[National Bank of Serbia (official translation)](https://www.nbs.rs/export/sites/NBS_site/documents-eng/propisi/zakoni/digitalna_imovina_e.pdf) — A white paper published at issuance of digital assets must contain risk information sufficient for investors to make an informed decision, as defined under the Law on Digital Assets.
- T3[CoinDesk](https://www.coindesk.com/policy/2020/12/30/serbia-legalizes-digital-assets-trading-and-issuance) — Digital assets issued without an approved white paper cannot be advertised in Serbia, and quantitative limitations apply to the distribution of such unapproved-white-paper assets.
- T1[National Bank of Serbia](https://nbs.rs/en/drugi-nivo-navigacije/propisi/propisi-di/) — Virtual currency service providers holding user money and/or virtual currencies must keep prescribed records under the NBS Decision on the Contents and Form of Records Kept by the Virtual Currency Service Provider which Holds User Money and/or Virtual Currencies (RS Official Gazette No 49/2021).
- T1[National Bank of Serbia](https://www.nbs.rs/en/scripts/showcontent/index.html?id=20378&konverzija=no) — The NBS publicly advises citizens not to invest in virtual currencies or engage in virtual-currency transactions, citing high value fluctuations and the absence of central-bank or public-authority guarantee, as a supervisory advisory practice rather than a binding legal obligation.
- T3[NBS-supervised financial institutions](https://www.21analytics.co/travel-rule-regulations/serbia/) — Owning digital assets, offering digital-asset services, or accepting digital assets as collateral, though cryptographic-key custody services may be offered.
- T3[Serbia (no crypto custody regime)](https://statt.rs/crypto-regulation-serbia-2026-guide/) — No Serbia-specific statutory custody-segregation or client-asset-protection regime equivalent to MiCA Art 75 was located for virtual-currency or digital-token service providers.
- T3[Serbia (no crypto market-abuse regime)](https://statt.rs/crypto-regulation-serbia-2026-guide/) — No crypto-specific market-abuse regime (insider dealing, unlawful disclosure, manipulation prohibitions akin to MiCA Title VI) was located for Serbia.
- T3[National Bank of Serbia](https://zuniclaw.com/en/cryptocurrency-license-serbia/) — NBS-supervised financial institutions may provide digital-asset custody limited to safekeeping of cryptographic keys without a separate permit (notification-only), but may not otherwise invest in, hold, or provide services related to digital assets.

### Serbia: C6 Tax TreatmentRedEnacted in forceModule confidence: Probable▾

A crypto-specific tax framework (rates, capital-gains mechanics, income characterisation for mining/staking, VAT/withholding treatment) was not independently confirmed against a Tier-1 Serbian tax-law source in this research pass. A regulatory reporting obligation for certain virtual-currency holdings to the NBS exists and is adjacent to, but distinct from, tax-return reporting. Escalation to primary Ministry of Finance / Tax Administration sources is recommended before publication of specific rate claims.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 9 traced claims · Re-verified 2026-10-25

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### Serbia: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾

Serbia restricts foreign digital-asset service providers from targeting Serbian residents absent local incorporation and NBS licensing, functioning as a de facto market-entry/cross-border-service barrier. No dedicated cross-border digital-asset transfer reporting threshold, sanctions-nexus rule, or travel-rule cross-border mechanism distinct from the general AML framework (owned by the FIM aml_ctf module) was identified in this research pass.

Periodic update · new data 2026-10-25

#### Cross-Border Transfer

Serbia's cross-border virtual-asset transfer compliance regime has registered a confirmed improvement. MONEYVAL, in its assessment covering measures taken since November 2021, confirmed that Serbia has implemented the FATF travel rule for virtual-asset service providers and improved the exchange of prudential and AML/CFT information on virtual-asset matters with counterpart authorities. This assessment directly upgraded FATF Recommendation 15, which governs virtual assets and VASPs, from Partially Compliant to Largely Compliant.

This finding sits on Tier 1 sourcing directly from the Council of Europe/MONEYVAL, the highest-confidence sourcing tier available in this jurisdiction's crypto file, and it is recorded at Confirmed confidence with an in-force regulatory stage, reflecting that the travel-rule implementation described is a present operational reality rather than a pending or proposed measure. The relevant regulatory framework remains the Law on Digital Assets (2021) together with Serbia's AML/CFT Law, under the supervisory authority of the National Bank of Serbia.

The traffic-light assessment for this module has moved to green, reflecting explicit MONEYVAL confirmation of travel-rule implementation, a stronger evidentiary position than is typical for this module across comparable jurisdictions in the region, where travel-rule implementation is frequently asserted by industry commentary rather than confirmed by a primary international-body assessment.

#### Outlook

The item to watch is whether Serbia's next MONEYVAL follow-up cycle documents further improvement or, alternatively, identifies operational gaps in travel-rule execution at the level of individual VASPs, which would refine this assessment-level finding with transaction-level evidence.

Periodic update · new data 2026-09-14

#### Cross-Border Transfer

Serbia's cross-border virtual-asset transfer compliance regime has registered a confirmed improvement this cycle. MONEYVAL, in its assessment covering measures taken since November 2021, confirmed that Serbia has implemented the FATF travel rule for virtual-asset service providers and improved the exchange of prudential and AML/CFT information on virtual-asset matters with counterpart authorities. This assessment directly upgraded FATF Recommendation 15, which governs virtual assets and VASPs, from Partially Compliant to Largely Compliant.

This finding sits on Tier 1 sourcing directly from the Council of Europe/MONEYVAL, the highest-confidence sourcing tier available in this jurisdiction's crypto file this cycle, and it is recorded at Confirmed confidence with an in-force regulatory stage, reflecting that the travel-rule implementation described is a present operational reality rather than a pending or proposed measure. The relevant regulatory framework remains the Law on Digital Assets (2021) together with Serbia's AML/CFT Law, under the supervisory authority of the National Bank of Serbia.

The traffic-light assessment for this module has moved to green, reflecting explicit MONEYVAL confirmation of travel-rule implementation, a stronger evidentiary position than is typical for this module across comparable jurisdictions in the region, where travel-rule implementation is frequently asserted by industry commentary rather than confirmed by a primary international-body assessment.

#### Outlook

The item to watch is whether Serbia's next MONEYVAL follow-up cycle documents further improvement or, alternatively, identifies operational gaps in travel-rule execution at the level of individual VASPs, which would refine this assessment-level finding with transaction-level evidence.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-10-25

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### Serbia: C8 AML/CFT RegimeAmberEnacted in forceModule confidence: Probable▾

Crypto AML/CFT obligations are consumed via the fleet's FIM aml_ctf module rather than produced in this crypto baseline. For disambiguation context only: Serbia's Law on the Prevention of Money Laundering and Terrorism Financing designates virtual-currency and digital-asset service providers as obliged entities, and Serbia underwent a MONEYVAL/FATF mutual evaluation with on-site visit in May 2025. No aml_cft_regime claims are produced in this baseline per the subscription reminder.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-10-25

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