PORTUGAL Law and Practice Contributed by: Bárbara Marinho e Pinto, Ana Reis Mota, Lua Mota Santos and Jéssica Dinis Bento, Rogério Alves & Associados
dering and terrorist financing. In 2025 it was amended by Law No 70/2025 of 22 December to implement measures under Regulation (EU) 2023/1113 on infor - mation accompanying transfers of funds and certain crypto‑assets. 1.3 Key Industries Sanctions compliance affects the entire economy, but some sectors are particularly exposed. Banking and financial services are at the forefront, given their central role in implementing asset freezes, blocking payments and monitoring transactions; credit and financial institutions are subject to detailed screening obligations under the AML/CTF framework. Capital‑markets participants – including investment firms, fund managers and custodians – are also heav - ily impacted, notably by restrictions on dealing in cer - tain securities, on new debt and equity issues and on providing investment services to listed persons. Insurance and pensions, as well as sectors engaged in international trade in sensitive goods – such as ener - gy, commodities, shipping/logistics and dual‑use or high‑technology products – are likewise significantly affected by trade and sectoral measures in the EU regimes. Other entities affected by sanctions regulations include, in particular, entities engaged in the import, export, purchase, sale, transfer, transit or transport of goods, auditors, statutory auditors and accountants, estate agents, traders dealing in high-value goods, gambling operators and crypto-asset service provid - ers, amongst others. 1.4 Overview 1.4.1 Types of Sanctions Portugal applies the full range of restrictive meas - ures adopted at UN and, in particular, EU level. These include targeted financial sanctions – primarily asset freezes and prohibitions on making funds or economic resources available, directly or indirectly, to listed indi - viduals and entities – as well as travel bans on desig - nated persons. Failure to comply with “restrictive measures” is pun - ishable. The penalties provided for by law range from
administrative offences to imprisonment, depending on the seriousness of the conduct and its potential to cause harm to those whom the “restrictive measure” in question is intended to protect. A ruling may also be made to publish the conviction of natural or legal persons. 1.4.2 Scope of Sanctions “Restrictive measures” are intended to achieve at least one of the following objectives: • the maintenance or restoration of international peace and security and the prevention of conflicts; • the protection of human rights; • democracy and the rule of law; • safeguarding the values, security, independence and integrity of the European Union; • the preservation of national sovereignty and inde - pendence and other fundamental interests of the state; and • the prevention and suppression of terrorism and the proliferation of weapons of mass destruction. “The restrictive measures” provided for in Portuguese law apply to natural persons as well as to legal per - sons, whether public or private, and also to property, funds and economic resources located within national territory, regardless of the nationality, residence or reg - istered office of their owners, beneficiaries or parties involved. 1.4.3 Domestic and/or Supranational Measures Sanctions applicable in Portugal are predominantly supranational in origin. UN Security Council measures are implemented via EU law and, where necessary, through national acts, while EU restrictive measures take the form of regulations and decisions that are directly applicable and binding in Portugal. At a domestic level, Law No 97/2017 of 23 August, regulates the implementation and enforcement of restrictive measures adopted by the UN or the EU and establishes the system of penalties applicable to breaches of these measures. To ensure the effective investigation and prosecution of violations of Union restrictive measures, member
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