PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
8. Anti-Money Laundering (AML) 8.1 AML Legislation Portugal’s AML regime applicable to gambling is pri- marily governed by Law No 83/2017, as amended by Law No 99-A/2021 and Law No 58/2020, which trans- poses the EU’s Fourth and Fifth AML Directives. The Law applies to both land-based and online gambling operators, which are expressly listed as obliged enti- ties under Article 4. Sector-specific implementation is ensured by the SRIJ, under the oversight of Turismo de Portugal and by the Financial Intelligence Unit (UIF) of the Judicial Police, which receives STRs. Additional provisions in the RJO and Decree-Law No 422/89 complement the AML framework for gaming operators, establishing record-keeping, reporting and customer-identification obligations. The SRIJ also issues sectoral guidance and circulars setting out practical AML measures for casinos, bingo halls and online operators, covering player verifica- tion, internal controls, and STR submission protocols. 8.2 AML Requirements Both land-based and online operators must imple- ment a comprehensive AML/CFT compliance pro- gramme consistent with Law No 83/2017. Core obli- gations include: • CDD – verification of player identity upon registra- tion or entry, before any transaction amounting EUR2,000 or more, or when suspicious circum- stances arise; • enhanced due diligence (EDD) – applied to higher- risk situations, including politically exposed per- sons (PEPs), cross-border transactions, or atypical betting or gaming patterns; • ongoing monitoring – review of player activity and payment flows to detect suspicious or inconsistent transactions; • record-keeping – retention of identification and transaction data for at least seven years; • internal controls – designation of a compliance officer, staff training, written procedures, and inde- pendent audit or review mechanisms; and
• STR – immediate reporting to the UIF/Judicial Police when evidence or suspicion of money laun- dering or terrorist financing arises. Operators must integrate these controls into their approved technical and financial systems, enabling the SRIJ to conduct real-time or remote supervision. The regulator may impose administrative sanctions, suspend operations, or revoke licences for serious or repeated breaches. In practice, Portugal maintains a high-compliance, risk-based AML regime that mirrors the EU framework while adapting to the specificities of casino and online gaming environments. The advertising of gambling and betting activities in Portugal is overseen by the SRIJ in co-ordination with the Direção-Geral do Consumidor (DGC) and the Regulatory Authority for the Media (ERC). The SRIJ supervises advertising practices of licensed gambling operators and ensures compliance with sector-spe- cific restrictions under the RJO and the Advertising Code. 9.2 Definition of Advertising Under the Advertising Code, advertising is defined as “any form of communication made in connection with a commercial, industrial, craft or professional activity, with the purpose of promoting the supply of goods or services”. In the gambling context, this encompasses all direct and indirect communications that promote participa- tion in games of fortune or chance, betting or other gambling activities, including digital marketing, spon- sorship, and affiliate advertising. An amendment to the regime is currently under dis- cussion at the Assembly of the Republic (see 1.1 Cur- rent Outlook and Recent Changes ). 9. Advertising 9.1 Regulatory/Supervisory Agency
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