Montenegro still has €2.235 million in escrow accounts linked to five unresolved applications under its former citizenship-by-investment programme, leaving outstanding financial and administrative obligations despite the closure of the scheme to new applicants.
Government data show that the programme received 1,113 applications, of which 869 were approved and 239 rejected, while five cases remain undecided.
The outstanding funds comprise approximately €1.835 million allocated to tourism investment projects and another €400,000 earmarked for innovation development. The money remains associated with individual applicants and cannot be treated as freely available government revenue.
Programme Generated More Than €413 Million
Montenegro’s citizenship-by-investment framework generated approximately €413.85 million in investment and associated payments throughout its operation.
Around €251.47 million was directed towards approved tourism projects, while €86.9 million went to less-developed municipalities. Administrative fees generated approximately €43.58 million, and the Innovation Fund of Montenegro received about €31.4 million. Agriculture and processing accounted for only a marginal share of programme investment.
The five unresolved applications represent a small proportion of the programme’s overall financial volume, but their outstanding status illustrates the administrative challenges involved in settling investment-related obligations after a scheme stops accepting applications.
Escrow Accounts Keep Funds Tied to Pending Cases
Escrow accounts protect applicants and the state by holding funds until specified conditions have been met. When applications remain unresolved, capital can stay immobilised for extended periods, creating uncertainty over potential refunds or the eventual allocation of investments.
Banks administering these accounts must continue to meet documentation, compliance and legal requirements even after the underlying programme has formally ended. The outstanding cases also reflect the programme’s combined structure, which linked citizenship policy with hotel development, regional investment contributions and public administrative fees.
Tourism Projects Account for Most Investment
The scheme brought several hundred million euros into Montenegro, but a substantial share of the investment was concentrated in tourism and real estate. Its longer-term economic impact depends on how much of the capital translated into completed hotels, sustainable employment and recurring tourism revenue.
For investors, the distinction between capital committed to a project and completed operating assets remains important. Tourism developments supported by citizenship investment can deliver their intended economic benefits only when properties are completed, opened and generating revenue.
The remaining €2.235 million is unlikely to have a material effect on Montenegro’s public finances. Resolving the five outstanding applications would nevertheless enable the government to settle another portion of the programme’s remaining administrative and legal obligations. Although the citizenship-by-investment programme has ended, unresolved cases continue to require financial and administrative attention.
