PORTUGAL Law and Practice Contributed by: Pedro Cortés and Luís Portela de Carvalho, Lektou
allow regulators to reassess the fitness of new share- holders whenever necessary.
working groups on responsible gambling and illegal- operator deterrence. 11.2 Sanctions Portugal’s enforcement system combines administra- tive, contractual, and criminal sanctions. For administrative breaches, the SRIJ may impose warnings, fines, suspension, revocation, or manda- tory remedial actions. Under the Gaming Law, concessionaires may face suspension or termination for violations of legal, con- tractual, AML or responsible-gambling obligations. Under the RJO, the SRIJ may suspend individual games or entire platforms, revoke or suspend licenc- es, or impose corrective measures for repeated or serious non-compliance. Criminal offences, prosecuted by the Ministério Públi- co , include: • the operation or promotion of unlicensed gambling (punishable by imprisonment of up to five years or fine); • fraudulent manipulation of games or bets; and • participation or facilitation of unauthorised gam- bling activities. Convictions may lead to confiscation of proceeds, closure of facilities, and disqualification from future licensing. The SRIJ regularly publishes enforcement summaries detailing illegal-site blocking, unauthorised advertis- ing, and compliance penalties, reflecting a consistent supervisory record. 11.3 Financial Penalties Administrative fines are determined in accordance with the General Regime of Administrative Offences (Decree-Law No 433/82), taking into account the gravity, recurrence, culpability, and economic benefit derived from the infringement.
11. Enforcement 11.1 Powers
The SRIJ exercises comprehensive licensing, supervi- sory and enforcement powers across both land-based and online gambling. For online gambling and betting, the SRIJ holds exclu- sive competence under the RJO to grant, renew, amend, suspend and revoke licences. It homolo- gates technical systems and game types, certifies random-number generators, verifies return-to-player calculations, and conducts both onsite and remote inspections. The SRIJ may also suspend games, func- tionalities or systems, impose corrective measures, and initiate administrative offence proceedings. For land-based operations, including casinos and bingo halls, the SRIJ supervises concession perfor- mance and ensures compliance with the legal and contractual framework under the Gaming Law. Sanc- tioning powers are exercised in co-ordination with the Minister of Finance and the Minister for Tourism, who formally authorise or terminate concessions. Criminal enforcement of gambling-related offences – such as unlicensed operation, illegal promotion or fraudulent manipulation – falls under the jurisdiction of the Ministério Público , with investigation conducted by the Polícia Judiciária , which maintains specialised units for gaming and cybercrime. The SRIJ reports or refers suspected criminal conduct for prosecutorial action. Decisions of the SRIJ are subject to judicial appeal before the Administrative Courts. The SRIJ co-operates closely with the Ministério Público , Polícia Judiciária , the Tax and Customs Authority, and the Bank of Portugal, particularly on AML/CFT enforcement and cross-border payment monitoring. It also exchanges information with EU and EEA regulators under mutual-assistance arrange- ments, and participates in regional and international
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