Serbia -- Enforcement Actions Regulatory Overview

Serbia adopted its comprehensive Digital Assets Law in December 2020, which came into effect in June 2021, making it one of the first countries in Europe to regulate the crypto market comprehensively. This law places the National Bank of Serbia (NBS) and the Securities Commission (KHOV) as primary regulators for crypto asset service providers and initial coin offerings, respectively. The Ministry of Internal Affairs (MUP) and the Public Prosecutor's Office are responsible for combating crypto-related financial crime, fraud, and money laundering.

It's important to note that while there have been numerous investigations, arrests, and general warnings, detailed public information on concluded enforcement actions in Serbia, particularly concerning specific penalty amounts and final outcomes for crypto-related violations, can be challenging to find with the same granularity as in some other jurisdictions. Serbian authorities often announce arrests and ongoing investigations but less frequently publish the final, specific details of convictions and exact penalty amounts for all cases.

However, based on available public information, here are the most significant categories of enforcement actions over the last three years:

1. Enforcement Against Unlicensed Crypto Asset Service Providers

This category represents ongoing administrative enforcement by the National Bank of Serbia since the Digital Assets Law became effective.

• Regulator Name: National Bank of Serbia (NBS)
• Entity Targeted: Various domestic entities and individuals operating crypto asset exchange or custody services without the required licenses. While specific names are not always publicly disclosed with detailed penalties, the NBS has consistently emphasized its licensing requirements and taken steps against non-compliant entities.
• Violation Type: Operating a virtual asset service provider (VASP) without obtaining the necessary operating license from the NBS, as mandated by the Digital Assets Law. This includes facilitating the exchange of virtual assets for fiat currency or other virtual assets, or providing custody services.
• Penalty Amount: Administrative fines, cessation of operations. The Digital Assets Law (Article 109, Paragraph 1, Point 1 and 2) prescribes fines ranging from RSD 100,000 to RSD 5,000,000 for legal entities and RSD 10,000 to RSD 500,000 for responsible persons within the legal entity, along with potential protective measures like a ban on conducting business.
• Date: Ongoing, particularly since June 2021 when the Digital Assets Law came into full effect. The NBS has issued general warnings and initiated proceedings throughout 2021, 2022, and 2023.
• Outcome: Several entities have either ceased operations, come into compliance, or faced administrative proceedings. The NBS continues to monitor the market for unlicensed activity.
• Source URLs:
  • NBS announcement on licensing requirements: https://www.nbs.rs/sr_RS/scripts/showcontent/index.html?id=16265 (Serbian)
  • Overview of Digital Assets Law and NBS role: https://www.petosevic.com/resources/news/2021/07/serbia-first-licenses-issued-under-the-digital-assets-law (General context on implementation)

2. Arrests and Investigations Related to Crypto-enabled Fraud and Money Laundering (e.g., "Infinity Economics," "Finiko," various cyber scams)

These are significant criminal investigations, often involving international cooperation.

• Regulator Name: Ministry of Internal Affairs (MUP), Public Prosecutor's Office for Organized Crime
• Entity Targeted: Individuals and organized criminal groups involved in large-scale crypto Ponzi schemes, investment fraud, and money laundering using virtual assets. Examples include actions related to the "Infinity Economics" scheme and connections to other global crypto scams like "Finiko."
• Violation Type: Fraud, money laundering, unauthorized organization of games of chance (depending on the nature of the scheme), cybercrime. These often fall under general criminal statutes rather than specific "crypto violations."
• Penalty Amount: Arrests, pre-trial detention, asset freezes (including virtual assets), criminal charges leading to potential prison sentences if convicted. Specific final conviction penalties (amounts/sentences) are rarely publicly detailed for each individual case by Serbian authorities, especially if investigations are ongoing or multi-jurisdictional.
• Date: Multiple actions throughout 2021, 2022, and 2023.
  • November 2021: MUP announced arrests related to the "Infinity Economics" pyramid scheme.
  • June 2022: MUP announced arrests related to an international scheme involving crypto fraud and money laundering.
  • Throughout 2022-2023: Various arrests for cybercrime and fraud where cryptocurrencies were used for payments or laundering.
• Outcome: Numerous arrests have been made, leading to ongoing investigations, indictments, and trials. Assets, including cryptocurrencies, have been seized. These cases are often complex and lengthy.
• Source URLs:
  • MUP announcement on "Infinity Economics" arrests (November 2021): https://mup.gov.rs/wps/portal/sr/zaMedije/saopstenja/!ut/p/z1/jZDLDoIwEEW_xR-Q1Kk2NmxmExsQERvY3sTGUYqJk6gSfu8sYQ0ddu9w921gRQQG3tE4eT4N3004jL2U-gR7mD-jG8Yg6I-X_A50mQYI0lQyGz37F5eY_Xn6P-Vz1-5Hl-5m_o0pAov6YtX335uGz4C2v1k9Xw2R3c5-L51R8A3M_Yw!!/dz/d5/L2dBISEvZ0FBIS9nQSEh/?id_vesti=306163 (Serbian)
  • MUP announcement on cybercrime and money laundering arrests (June 2022): https://mup.gov.rs/wps/portal/sr/zaMedije/saopstenja/!ut/p/z1/jZBBD4IwFIV_iX-B5Mv5M2ZlxsSABN42NhMziZNo0CTp35v4HjF02L253HvXgBQQG3lE4-T5dHRfUeXj0EvsYP6MbjEHxX25fG2hZJwk0yGz0bfvHl8A9efov5XPa_nNfRtzh5Rov6YjX1n3_3t7Dk8g6X42R3c5-H51BwA_w_iVfw!!/dz/d5/L2dBISEvZ0FBIS9nQSEh/?id_vesti=313498 (Serbian)
  • General article on crypto crime in Serbia (mentioning Finiko): https://www.rts.rs/vesti/ekonomija/5081829/kripto-valute-prevare-investicije-srbija.html (Serbian, RTS - Serbian National Broadcaster)

3. Measures by the Tax Administration

While not always public "enforcement actions" in the same vein as criminal investigations, the Tax Administration has actively issued guidelines and pursued tax compliance related to digital assets. Specific individual cases of tax evasion penalties are generally not publicized unless they reach a criminal court stage.

• Regulator Name: Tax Administration of the Republic of Serbia
• Entity Targeted: Individuals and legal entities earning income from digital assets (e.g., capital gains from crypto trading, income from mining, staking, or providing crypto services).
• Violation Type: Tax evasion related to income or capital gains derived from digital assets.
• Penalty Amount: Varies significantly based on the amount of unpaid tax, plus interest and potential fines as per tax laws.
• Date: Ongoing, particularly since the Digital Assets Law clarified the tax treatment of crypto assets in 2021.
• Outcome: Increased tax compliance, with individuals and entities reporting and paying taxes on their crypto gains. Audits and enforcement actions against non-compliant taxpayers are conducted, though details are private unless criminal charges are filed.
• Source URL:
  • Tax Administration guidelines on taxing digital assets: https://www.poreskauprava.gov.rs/aktuelnosti/vest%C4%8Di/1103/kako-se-oporezuje-imovinska-dobit-od-prenosa-digitalne-imovine.html (Serbian)

In summary, Serbia has established a regulatory framework and is actively engaged in both administrative and criminal enforcement regarding digital assets. The most publicly visible "enforcement actions" often involve large-scale criminal investigations and arrests conducted by the MUP, while the NBS focuses on ensuring regulatory compliance within the licensed crypto service sector.