Anti-money laundering compliance is no longer a concern limited to banks and financial institutions.

In Portugal, Certified Accountants, companies, tax professionals and other obliged entities are subject to specific anti-money laundering and counter-terrorist financing obligations, including client identification, beneficial ownership verification, risk assessment, record keeping and the reporting of suspicious transactions.

The regulatory framework is also becoming more demanding.

In September 2026, the Portuguese Order of Certified Accountants — Ordem dos Contabilistas Certificados, or OCC — published a new practical guide on the prevention of money laundering and terrorist financing from the perspective of the Certified Accountant.

At European level, the new Regulation (EU) 2024/1624, generally referred to as the EU Anti-Money Laundering Regulation or AMLR, will become directly applicable from 10 July 2027.

For accountants and businesses operating in Portugal, the key point is clear:

AML compliance can no longer be treated as a one-off administrative formality. Businesses and professionals must be able to demonstrate how clients were identified, how beneficial ownership was verified, how risk was assessed and how unusual transactions were reviewed.

What is money laundering?

Money laundering is the process through which funds or assets derived from criminal activity are concealed or transformed so that they appear to have a legitimate origin.

The process is commonly divided into three stages:

1. Placement
The introduction of illicit funds into the financial or economic system.

2. Layering
The use of transactions, transfers or structures designed to distance the funds from their criminal origin.

3. Integration
The reintroduction of the funds into the economy with an apparently legitimate source.

In Portugal, the criminal offence of money laundering is regulated under Article 368-A of the Portuguese Criminal Code.

What is terrorist financing?

Terrorist financing differs from money laundering in one important respect.

Money laundering is generally intended to conceal the origin of funds.

Terrorist financing is primarily intended to conceal the destination or purpose of the funds.

This means that funds used for terrorist financing may have a perfectly legitimate origin.

For this reason, AML and counter-terrorist financing rules are generally dealt with together under the broader concept of AML/CFT compliance.

Why are Certified Accountants subject to AML rules in Portugal?

Certified Accountants are expressly included among the obliged entities under Portuguese Law no. 83/2017.

This is because accountants occupy a particularly relevant position within the financial and economic activity of their clients.

They typically have access to:

• bank statements;
• invoices;
• contracts;
• shareholder transactions;
• loans and shareholder contributions;
• company ownership structures;
• international transfers;
• related-party transactions;
• accounting records and financial statements.

As a result, accountants may identify inconsistencies, unusual flows of funds or transactions that would not necessarily be visible to other professionals or authorities.

AML compliance is therefore not separate from the accountant’s professional role. It forms part of the accountant’s legal and regulatory responsibilities.

The OCC is the sectoral supervisory authority responsible for overseeing compliance by Certified Accountants in Portugal.

What are the main AML obligations of Certified Accountants?

Portuguese Law no. 83/2017 imposes a number of preventive obligations.

The most relevant include the following.

1. Internal control obligations

Accounting firms must implement internal policies, procedures and controls appropriate to the size and risk profile of their activity.

In practical terms, knowing the legislation is not enough.

The firm should be able to demonstrate how it complies with the law.

This normally includes documented procedures for:

• client acceptance;
• client identification;
• beneficial owner identification;
• risk classification;
• analysis of unusual transactions;
• suspicious transaction reporting;
• record retention;
• staff training.

2. Client identification and KYC

Before entering into a business relationship, the accountant must carry out appropriate Know Your Customer, or KYC, procedures.

For individuals, the accountant must collect and verify the identification information required by law.

For companies, the analysis should normally include:

• company name;
• tax identification number;
• registered office;
• business activity;
• directors or managers;
• ownership structure;
• shareholders with relevant ownership interests;
• beneficial owners.

KYC is not limited to collecting documents at the start of the relationship.

The information must also be kept up to date throughout the client relationship.

3. Beneficial owner identification

A central concept in AML compliance is the beneficial owner, also commonly referred to as the Ultimate Beneficial Owner, or UBO.

The beneficial owner is the natural person who ultimately owns or controls a company or legal structure.

This means that Portugal’s Central Register of Beneficial Ownership, or RCBE, should not be treated merely as an administrative filing requirement.

The accountant should assess whether the registered beneficial owner actually corresponds to the person who ultimately controls the entity.

Potential warning signs may include:

• inconsistencies between the RCBE and the corporate structure;
• complex ownership chains;
• broad powers of attorney;
• de facto managers;
• individuals controlling bank accounts without appearing in the corporate records.

4. Client risk classification

AML rules are based on a risk-based approach.

This means that not every client requires the same level of due diligence.

A higher level of scrutiny may be appropriate where the client presents factors such as:

• complex corporate structures;
• links to higher-risk jurisdictions;
• frequent use of cash;
• activity in higher-risk sectors;
• difficulty identifying the beneficial owner;
• politically exposed persons, or PEPs;
• transactions that do not appear consistent with the declared business activity.

The important point is not simply to assign a risk category.

The accountant should be able to explain and document why the client was classified at that particular risk level.

5. Ongoing monitoring

AML due diligence does not end when the client is accepted.

Throughout the business relationship, the accountant must assess whether the client’s transactions remain consistent with:

• the declared business activity;
• the information previously collected;
• the ownership structure;
• the known source of funds;
• the assigned risk profile.

For example, a business that historically reports annual turnover of €100,000 but suddenly begins moving several million euros may require additional review.

The same may apply where there are unexplained international transfers, undocumented shareholder loans or significant changes in the ownership structure.

What are common AML red flags?

A red flag does not automatically mean that money laundering has occurred.

It means that the transaction or situation requires further analysis.

Common AML warning signs include:

• frequent or unexplained use of cash;
• unnecessarily complex corporate structures;
• use of nominees or intermediaries without clear commercial justification;
• shareholder loans with no documented source of funds;
• large invoices with vague descriptions;
• transactions between related parties with no clear economic rationale;
• operations inconsistent with the scale or nature of the business;
• repeated refusal to provide supporting documentation;
• discrepancies between registered and actual beneficial ownership.

These factors must always be assessed in context.

No single red flag should automatically be treated as evidence of criminal activity.

What should an accountant do when an unusual transaction is identified?

When a transaction appears unusual, the accountant may be required to carry out an enhanced review under the duty of examination.

In practice, this will generally involve three steps.

First, collect the supporting documentation.

Second, request clarification from the client.

Third, assess whether the explanation is plausible, properly documented and consistent with the client’s known activity.

Written records are particularly important.

Relevant questions, explanations and conclusions should be documented so that the accountant can demonstrate the reasoning followed.

If the concerns are satisfactorily resolved, the analysis should be retained in the compliance file.

If the suspicion remains, other legal obligations may be triggered, including the duties of:

• abstention;
• reporting;
• confidentiality and non-disclosure.

How are suspicious transactions reported in Portugal?

In 2026, Portugal introduced an important operational change in the reporting process.

Suspicious Transaction Reports — commonly referred to as STRs or, in Portuguese practice, Comunicações de Operações Suspeitas, COS — are now submitted through the PortalCOS/goAML platform, which is used by the Portuguese Financial Intelligence Unit and the DCIAP.

Obliged entities should therefore ensure that they are registered on the platform before a suspicious transaction occurs.

This is important because waiting until a report must be submitted may make it difficult to comply with the requirement to report promptly.

Under the general AML regime, suspicious transaction reporting is not dependent on a minimum transaction amount.

The decisive factor is the existence of suspicion, not the value of the transaction.

Can the client be told that a report has been made?

No.

One of the central AML rules is the prohibition on tipping-off.

The accountant must not tell the client that:

• a suspicious transaction report has been submitted;
• an investigation is taking place;
• information has been requested by the competent authorities in connection with the report.

This does not mean that an accountant must carry out an unlawful transaction.

Portuguese AML law allows professionals to discourage a client from engaging in unlawful conduct without breaching the prohibition on disclosure.

How long must AML records be retained?

Under the current Portuguese rules, relevant AML documentation must generally be retained for seven years after the end of the business relationship or the completion of an occasional transaction.

A practical approach is to maintain a separate AML compliance file for each client.

This may include:

• client identification records;
• beneficial owner identification;
• RCBE documentation;
• risk classification;
• sanctions screening;
• requests for clarification;
• internal analysis notes;
• source-of-funds documentation where relevant.

The underlying principle is straightforward:

If the compliance process cannot be documented, it may be difficult to prove that the legal obligations were properly fulfilled.

Are there cash payment limits in Portugal?

Yes.

Under Article 63-E of the Portuguese General Tax Law, there is a general prohibition on cash payments or receipts with a value of €3,000 or more.

For certain non-resident individuals who are not acting as traders or entrepreneurs, a higher threshold of €10,000 may apply.

Portuguese law also contains additional rules requiring traceable payment methods in specific circumstances.

Splitting a transaction into several smaller payments does not necessarily avoid these limits, as related payments may be considered together.

What changes under the new EU AML Regulation in 2027?

The European Union has approved a major reform of its anti-money laundering framework.

The Regulation (EU) 2024/1624, or AMLR, will generally become directly applicable from 10 July 2027.

Unlike a directive, a regulation applies directly across EU Member States.

The objective is to create a common EU AML Single Rulebook and reduce differences between national compliance systems.

Several sectors will be particularly affected.

High-value goods

Businesses dealing in certain high-value goods, including precious metals, jewellery and precious stones, will be subject to more harmonised AML requirements.

These businesses will face stronger obligations regarding:

• customer identification;
• beneficial ownership;
• risk assessment;
• record keeping.

Art market

The art sector will remain subject to specific AML obligations, particularly for higher-value transactions.

Crypto-assets

Crypto-asset service providers will be integrated even more closely into the European AML framework.

Customer identification, transaction traceability and source-of-funds analysis will become increasingly important.

Professional football

Professional football clubs and agents will also come within the EU AML framework.

For certain parts of the football sector, the rules will generally apply from 10 July 2029.

Cash transactions

The AMLR introduces an EU-wide ceiling of €10,000 for certain cash transactions.

However, Member States are allowed to maintain stricter national limits.

Portugal’s existing general €3,000 cash limit therefore remains particularly relevant.

Will beneficial ownership rules also change?

Yes.

The new EU framework strengthens the rules for determining ownership and control of companies.

This will be particularly relevant for:

• international groups;
• holding companies;
• family-owned structures;
• entities with complex ownership chains.

The direction of travel is clear.

Identifying the formal shareholder will increasingly be insufficient.

Professionals will be expected to understand who ultimately controls the entity.

What is AMLA?

The new European framework also creates the Authority for Anti-Money Laundering and Countering the Financing of Terrorism, or AMLA.

AMLA will play a central role in coordinating AML supervision across the European Union.

It will also directly supervise certain higher-risk financial entities with significant cross-border activity.

For businesses and professionals operating in Europe, this means that AML standards are likely to become increasingly harmonised across Member States.

What should accounting firms do in 2026?

Businesses should not wait until July 2027 to begin preparing.

For accounting firms, 2026 should be used to review existing procedures and ensure that the compliance framework is documented and operational.

A firm should be able to answer questions such as:

Who is the beneficial owner of this client?

When was the client’s risk classification last reviewed?

How was the RCBE information verified?

Were sanctions lists checked?

How are unusual transactions analysed?

Is there an internal written record of the analysis?

Have staff received AML training?

Is the firm already registered on PortalCOS?

The difference between a purely formal compliance system and an effective one lies largely in the ability to answer these questions with documented evidence.

What are the consequences of non-compliance?

Failure to comply with AML obligations can have serious consequences.

Depending on the circumstances, these may include:

• administrative offences;
• substantial fines;
• ancillary sanctions;
• disciplinary proceedings before the OCC;
• professional suspension;
• criminal liability in the most serious cases.

The Portuguese AML framework provides for significant financial penalties.

However, the professional consequences can be even more serious where the breach affects the right to practise.

AML is no longer just a banking issue

The broader conclusion from the Portuguese and European regulatory framework is clear.

Anti-money laundering compliance has become a cross-sector requirement.

Accountants, tax advisers, lawyers, financial institutions, crypto-asset businesses, high-value goods dealers and other regulated entities are increasingly part of an interconnected system of prevention, verification and reporting.

The compliance model is also evolving.

The key question is no longer simply:

“Did the client provide the required documents?”

It is increasingly:

“Do we understand who the client is, who controls the entity, where the funds come from, whether the transactions make economic sense, and can we demonstrate the analysis we performed?”

This transition from formal documentation to risk-based, evidence-driven compliance is one of the most important developments businesses and professional advisers in Portugal should prepare for.

Frequently Asked Questions

Are Certified Accountants required to report suspicious transactions in Portugal?

Yes. Certified Accountants are obliged entities under Portuguese Law no. 83/2017 and must report suspicious transactions where the legal conditions are met.

Is there a minimum value for reporting a suspicious transaction?

No. Under the general AML framework, the reporting obligation is based on suspicion rather than a minimum transaction amount.

Must an accountant identify the beneficial owner?

Yes. Identification and verification of the beneficial owner is a core part of AML due diligence.

What does KYC mean?

KYC stands for Know Your Customer. It refers to the procedures used to identify clients, understand their activity, determine beneficial ownership and assess the risk associated with the business relationship.

What is the cash payment limit in Portugal?

The general rule under Article 63-E of the Portuguese General Tax Law prohibits cash payments or receipts of €3,000 or more. Specific exceptions and different thresholds apply in certain cases.

When does the new EU AML Regulation apply?

Regulation (EU) 2024/1624 will generally apply from 10 July 2027. Certain rules relating to professional football will generally apply from 10 July 2029.

What is AMLA?

AMLA is the new European Union authority responsible for anti-money laundering and counter-terrorist financing supervision and coordination.

What is PortalCOS?

PortalCOS is Portugal’s goAML-based platform used for submitting suspicious transaction reports to the competent authorities.

How can GoalSeek assist?

At GoalSeek, we advise companies, business owners, freelancers and international professionals on Portuguese taxation, compliance, corporate structuring and cross-border matters.

As AML requirements become more sophisticated, it is increasingly important that ownership structures, international financial flows and transactions involving non-residents are properly documented and consistent with both tax and regulatory obligations.

A preventive review can help identify compliance gaps before they develop into problems during a tax audit, regulatory review or request for information.

Disclaimer: This article is for general information purposes only and does not constitute legal, tax or accounting advice. The application of AML rules depends on the specific circumstances of the entity, client, transaction and sector.