PORTUGAL Trends and Developments Contributed by: Ana Reis Mota and Lua Mota Santos, Rogério Alves & Associados
The rapid evolution of financial systems and digital technologies has significantly expanded both the scope and complexity of white-collar crimes, under - scoring the need for comprehensive legal reforms. According to statistical data from the Portuguese Min - istry of Justice, there was an increase in economic and financial crimes reported in 2023, particularly concern - ing money laundering offences. Furthermore, the 2022 Annual Internal Security Report highlighted a frequent suspension of suspicious transactions involving politi - cally exposed persons from Portuguese-speaking countries or with connections to them, indicating the utilisation of national financial, corporate, and banking systems for fund movements. Data released by the Public Prosecutor’s Office fur - ther indicates a rise in the number of investigations into economic and financial crimes, with 3,598 new inquiries related to corruption and related offences initiated in 2023. This marks a significant increase from the 2,865 inquiries initiated in 2021. The Public Prosecutor’s Office also reported that 535 banking operations were suspended, leading to the initiation of 535 inquiries. While official 2025 figures are still pending, early indi - cations suggest that these trends are holding steady or intensifying. Recent years have witnessed a series of institutional, legislative, and operational reforms aimed at reinforc - ing the country’s capacity to detect, investigate, and prosecute complex financial and economic crimes. These measures have been spurred by growing public awareness, heightened international scrutiny, and the government’s commitment to aligning national stand - ards with those of the European Union and global anti- corruption bodies. Strengthened Institutions and Anti-Corruption Enforcement in Portugal In recent years, Portugal has taken decisive steps to modernise its anti-corruption framework. A key mile - stone in this process was the introduction of the Gen - eral Regime for the Prevention of Corruption ( Regime Geral de Prevenção da Corrupção – RGPC), which came into force at the end of 2024. This law applies to
both public bodies and private companies employing 50 or more workers. Under the RGPC, such organisations must put in place comprehensive compliance programmes: • Risk Prevention Plan – a documented, annually reviewed plan that identifies corruption and related risks (such as conflicts of interest, fraud, influence peddling) and sets out mitigation measures. • Code of Conduct – a formal set of ethical rules and behavioural standards, applicable to manage - ment and staff, approved at the highest level of the organisation. • Training Programmes – periodic training for employees and management to ensure awareness of corruption risks and compliance duties. • Whistle-Blowing Channels – confidential and secure reporting mechanisms that comply with the EU whistle-blower Directive (transposed into Portu - guese law in 2021). • Compliance Officer ( Responsável pelo Cumprimen- to Normativo ) – an individual appointed to oversee the implementation and monitoring of the compli - ance programme. While the RGPC sets the rules organisations must follow, Mecanismo Nacional Anticorrupção (MENAC) acts as the oversight and enforcement authority. Together, they represent a shift from reactive enforce - ment (catching corruption after it occurs) to proactive prevention, with a focus on governance structures, transparency, and whistle-blower protection. A particularly important feature is the obligatory reg - istration on the RGPC online platform, managed by MENAC. Entities must provide key organisational data, details of their compliance officer, and upload certain governance documents. The final deadline for registration was 14 February 2025. Late registration can result in administrative fines, even if the entity is otherwise compliant inter - nally. Failure to implement an adequate compliance pro - gramme, to register, or to cooperate with MENAC inspections can lead to administrative offences pun -
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