Financial Crime World

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Banks in Portugal Must Comply with KYC Procedures

In an effort to combat money laundering and terrorist financing, Portuguese banks must implement Know Your Client (KYC) procedures to prevent financial crimes. The Bank of Portugal has issued Notice 1/2022, outlining the requirements for obligated entities to maintain a robust Anti-Money Laundering (AML), Combating the Financing of Terrorism (CTF), & Sanctions internal control system.

Gap Analysis

A gap analysis will help banks identify gaps in their current procedures and implement measures to mitigate any identified risks. This process involves:

  • Reviewing internal controls
  • Conducting meetings with employees
  • Testing controls to ensure compliance with legal and regulatory requirements

Support for Oversight Bodies

Our team of experts provides support to oversight bodies, including the Bank of Portugal, to issue opinions on banks’ AML/CTF & Sanctions internal control systems. We review procedures, conduct tests, and provide a comprehensive report outlining any gaps or areas for improvement.

Roadmaps and Remediation Plans

To address identified risks, we design roadmaps and remediation plans that outline the strategy to mitigate exposure to AML/CTF & Sanctions risks. This process involves:

  • Identifying situations of risk
  • Implementing measures to improve internal controls

Policies and Manuals of Procedures

Developing or revising policies and manuals of procedures is crucial for compliance with regulatory requirements. Our team helps banks create these documents, outlining existing procedures and presenting them to employees and authorities.

Risk Matrix

A risk matrix assesses the risks associated with products, services, and client profiles. This tool identifies:

  • The nature, extension, and probability of occurrence of each risk
  • Implemented controls to mitigate identified risks

Know Your Client/Enhanced Due Diligence

Our team provides Know Your Client analysis for new and existing clients, including searches in public and private databases to identify adverse media, Politically Exposed Persons (PEPs), and sanctions. This process helps banks comply with identification and diligence duties under Law 83/2017.

Training

We provide training sessions for bank employees on AML/CTF & Sanctions controls and practices, aiming to promote a culture of compliance and raise awareness about the importance of AML/CTF & Sanctions.

Whistleblowing Channel

To comply with Law 83/2017, we support the implementation and operation of whistleblowing channels, as well as the adoption of supporting materials on these matters.

By implementing these measures, Portuguese banks can ensure compliance with KYC procedures and prevent financial crimes.