Portugal
Overview
Law No. 83/2017 is Portugal’s core preventive AML/CFT statute and operates with EU requirements, sector regulation and later national amendments. In 2025 Decree-Law 115/2025 introduced legitimate-interest access for the beneficial-ownership register from 1 November, and Law 70/2025 updated AML obligations for cryptoasset transfer information effective 27 December.
Portugal operates the Central Register of Beneficial Ownership (RCBE), while Law 83/2017 requires beneficial-owner identification within CDD.
Obliged entities conduct risk-based CDD, transaction monitoring and suspicious-transaction reporting under Law 83/2017 and sector rules. From 13 April 2026 suspicious operation communications moved to Portal COS/goAML; through 13 October 2026 the official transition notice requires cumulative portal submission and transmission of the generated PDF to the UIF email address.
Compliance Calendar3
Requirement
Banking / Credit InstitutionsPayments / EMI / Money Transfer
Banco de Portugal annual AML/CFT Prevention Report (RPB)
Authority / Report toBanco de Portugal
Deadline / triggerAnnually · by 31 March of each year, reporting the preceding calendar year.
Requirement
- Sector scope
- Banking / Credit InstitutionsPayments / EMI / Money Transfer
- Subject scope
- Financial entities subject to Banco de Portugal supervision in AML/CFT and within Instruction No. 8/2024.
- Trigger
- Completion of the annual reference period from 1 January to 31 December of the previous year.
- Filing channel
- Submit through the Banco de Portugal reporting environment in accordance with Instruction No. 8/2024 and the current technical instructions.
Impact
- Consequences of non-compliance
- Late, missing or deficient reporting may lead to supervisory/remedial or sanction action under the applicable Banco de Portugal/AML legal framework; no generic fixed fine is asserted.
- Enforcement authority
- Banco de Portugal
- Operational impact
- For in-scope entities this is a genuine calendar deadline and should be tracked annually with preparation beginning before year-end data closure.
Requirement
Suspicious operation communication (comunicação de operações suspeitas)
Authority / Report toUnidade de Informação Financeira (UIF) and DCIAP, in accordance with the Portuguese dual-recipient statutory framework
Deadline / triggerImmediately (de imediato) once the statutory suspicion condition is met.
Requirement
- Subject scope
- Obliged entities under Lei n.º 83/2017, subject to the law’s professional scope.
- Trigger
- Knowledge, suspicion or sufficient grounds to suspect that funds/assets derive from criminal activity or are related to terrorist financing under Article 43.
- Filing channel
- From 13 April 2026, submit suspicious operation communications through Portal COS / goAML. During the six-month transition through 13 October 2026, the official ASAE notice requires cumulative portal submission and sending the generated PDF to [email protected].
Impact
- Consequences of non-compliance
- Failure to communicate can result in administrative/criminal consequences under the statutory sanction framework; exact monetary range depends on breach and entity category.
- Enforcement authority
- Relevant sector authority / enforcement bodies; UIF and DCIAP are report recipients.
- Operational impact
- Maintain Portal COS registration and workflow controls. Through 13 October 2026, ensure each suspicious-operation communication is submitted through the portal and the generated PDF is also sent to the UIF email address; after the transition, follow the current portal procedure.
Requirement
Banking / Credit InstitutionsPayments / EMI / Money Transfer
Institutional AML/CFT risk management and internal controls
Authority / Report toBanco de Portugal for entities within its perimeter
Deadline / triggerOngoing. Maintain risk assessment, internal controls and compliance arrangements; separate reporting requirements such as the RPB have their own deadlines.
Requirement
- Sector scope
- Banking / Credit InstitutionsPayments / EMI / Money Transfer
- Subject scope
- Financial entities under the Portuguese AML law and Banco de Portugal sector framework, where Banco de Portugal is the competent supervisor.
- Trigger
- Continuous activity and material changes to institutional, customer, product, channel and geographic risk.
- Filing channel
- Internal governance plus reporting/provision of information under the applicable supervisory instruments.
Impact
- Consequences of non-compliance
- Deficiencies may trigger supervisory measures and sanction proceedings depending on the breached requirement.
- Enforcement authority
- Banco de Portugal
- Operational impact
- Keep risk assessment and internal controls current and ensure RPB responses are traceable back to operational evidence.
Authorities & FIU1
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline41
ASAE published an official notice on 17 August 2026 confirming that suspicious operation communications had moved to Portal COS from 13 April 2026. During the six-month transition ending 13 October 2026, obliged entities must submit through the portal and also send the generated PDF to the UIF email address.
Law No. 70/2025, published 22 December 2025 and in force from 27 December 2025, updates Law No. 83/2017 to implement Article 38 of Regulation (EU) 2023/1113 and align the domestic AML/CFT framework with cryptoasset service providers and the EU AML Authority. It updates definitions, risk controls, self-hosted-address considerations and supervisory cooperation; the repeal of Article 112-B only took effect on 1 July 2026.
Decree-Law No. 115/2025, published on 27 October 2025 and effective from 1 November 2025, amends Articles 4, 9, 19, 20 and 21 of the Central Register of Beneficial Ownership (RCBE) regime. It introduces a legitimate-interest condition for public access to beneficial-owner information and audit logging for access requests, while clarifying certain exemptions and representative-identification rules.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Banco de Portugal published Notice No. 3/2021 regulating the registration process for virtual-asset service providers subject to Portugal’s AML framework. This records the operational registration layer rather than merely stating that virtual assets are regulated.
FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗RCBE adds a central national beneficial-ownership transparency layer alongside Law 83/2017 CDD obligations.
In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Law 83/2017 was published on 18 August 2017 and entered into force 30 days later, on 17 September 2017. It remains the modern consolidated preventive framework milestone, while earlier 1993–1995 origins are recorded separately.
The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
Current UN depositary relationship to 2003 UN Convention against Corruption. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Decree-Law 304/2002 established the Unidade de Informação Financeira (UIF) functions within Polícia Judiciária, including collection, centralisation, processing and dissemination of AML information. UIF is recorded as the FIU, while Polícia Judiciária is its host institution.
The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
Current UN depositary relationship to 2000 Palermo Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
Current UN depositary relationship to 1999 Terrorist Financing Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The Egmont Group's official Member FIU Information register records Portugal's FIU admission date as 1999-05-28.
FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗Decree-Law 325/95 broadened the laundering framework beyond the earlier drug-proceeds model and expanded the preventive/repressive architecture. The event captures a material scope expansion rather than a minor amendment.
Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗Decree-Law 313/93 transposed Directive 91/308/EEC and created Portugal’s early preventive financial-sector AML framework. This is distinct from the January 1993 criminalisation milestone.
Decree-Law 15/93 created an early criminal-law money-laundering layer tied to proceeds of drug trafficking. It forms part of Portugal’s AML origins before the later broad preventive regime.
FATF records Portugal as a member since 1991.
FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. Direct FATF membership and any listed regional assessment network participation are current profile relationships only. The GLOBAL milestone does not prove membership or domestic implementation on the event date; those remain LOCAL/STATUS evidence.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
Current UN depositary relationship to 1988 Vienna Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗