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Anti-Money Laundering Regulations in Portugal

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Routine Transaction Reporting Requirements

In Portugal, entities subject to anti-money laundering (AML) requirements must communicate certain types of transactions on a regular basis. The following are some key requirements:

Quarterly Reports for Real Estate Transactions and Lease Contracts

Entities must report real estate transactions and lease contracts quarterly.

Cash Transactions above €50,000

Cash transactions above €50,000 (or equivalent by cheque or paper document) and fund transfers above €50,000 to or from risky jurisdictions are also reportable.

Anti-Money Laundering Requirements for the Cryptocurrency Industry

The cryptocurrency industry is subject to AML requirements in Portugal. The following are some key points:

Virtual Currency Exchanges and Crypto Custodian Wallet Services

Virtual currency exchanges and crypto custodian wallet services are subject to AML requirements under Law 83/2017.

Prohibition on Buying, Owning, or Selling Virtual Currency

The Bank of Portugal issued a circular letter in 2015 prohibiting credit, payment, and electronic money institutions from buying, owning, or selling virtual currency.

Reporting Suspicious Activity

Entities must report suspicious transactions if they know, suspect, or have enough grounds to believe that certain funds or assets originated from criminal activity or are related to terrorism financing. The following is a key article:

Article 43 of Law 83/2017

Article 43 imposes a duty to report suspicious transactions.

Information Sharing and Cooperation

The Financial Intelligence Unit (FIU) plays a central role in information sharing and cooperation at the international level. The FIU is responsible for collecting, centralizing, and analyzing information resulting from communications made under Law 83/2017.

Beneficial Ownership and Control of Legal Entities

There is a public corporate registry that provides information regarding the ultimate beneficial ownership of legal entities. This information is accessible through different levels of access for financial institutions and other entities subject to AML requirements.

Accurate Information on Originators and Beneficiaries in Payment Orders

Accurate information on originators and beneficiaries is required depending on the client’s identity verification process.