Prikhodko&Partners
Services
International corporate law
Business Setup and Support in Portugal FINANCIAL MONITORING IN PORTUGAL

Taras Miroshnychenko

Head of practice

E-mail

miroshnychenko@prikhodko.com.ua

Phone numbers

Head of Corporate Law and Fintech Practice. Expert in the creation and reorganization of companies, support of M&A transactions, as well as legal support for opening and running a business in the EU, Asia, and North America.

FINANCIAL MONITORING IN PORTUGAL

In 2024–2025, Portugal has established its reputation as one of the most open and transparent EU countries in terms of financial compliance policy.

However, for individuals and legal entities doing business or residing in Portugal, the procedure for passing financial monitoring (Due Diligence / AML checks) can be a serious challenge.

The team of the international corporate law and fintech practice of the law firm “Prikhodko & Partners” regularly supports clients in compliance issues in Portugal, helping to avoid account blocking, fines and delays in work.

How to undergo financial monitoring for a legal entity and an individual?

Individuals, who open accounts, file tax returns, or make transfers exceeding €15,000, must undergo a basic financial monitoring procedure at a bank, crypto service, or other financial institution.

It includes:

confirmation of the source of income;
check for sanctions/PEP status (Politically Exposed Person);
justification of the purpose of the transaction.

Legal entities, including startups and holding companies, face in-depth analysis:

verification of beneficiaries (UBO);
corporate structure;
business model analysis;
the presence of tax residences in offshore countries.

In Portugal, the number of requests for additional account verification has increased by 28% since the beginning of 2023, according to Banco de Portugal.

What is needed for this, what are the requirements of local legislation?

Key sources of legal regulation of financial monitoring in Portugal:

Law No. 83/2017 of August 18 — the basic law on combating money laundering (AML) and terrorist financing;
Law No. 89/2017 — establishes the obligation to maintain a Register of Beneficial Owners (RCBE);
Regulation No. 276/2019 — technical requirements for customer identification and KYC data collection;
CMVM (Commissão do Mercado de Valores Mobiliários) Regulation No. 2/2020 on compliance for financial companies.

The law requires mandatory compliance with KYC (Know Your Customer), CDD (Customer Due Diligence) requirements, as well as constant monitoring of transactions in real time.

Basic requirements for financial monitoring

Among the most important requirements:

Providing documents confirming the source of funds (contracts, declarations, inheritance documents, stock exchange statements).
Submission of company registration certificates, constituent documents, and description of activities.
Entry in the RCBE (Central Register of Beneficial Ownership).
Regularly update information when the structure or address changes.
Financial audit for companies with a turnover of over 2 million euros or with foreign beneficiaries.

Procedure and deadlines

Financial monitoring lasts on average:

2–5 business days for individuals;
up to 15 working days for legal entities with foreign capital;
in the case of cryptocurrency transactions, the period may be extended to 30 days, especially if the source of funds is not transparent.

Banks of Portugal, such as Millennium BCP, Santander Totta or Caixa Geral de Depósitos, have separate AML departments that request additional information for each risky transaction case.

How much does it cost to conduct a legal audit of a company?

In Portugal, audits for AML/Compliance purposes can be either mandatory (for companies with public money or large turnover) or pro-active:

Basic audit with report preparation – from 1,500 to 5,000 euros.
Advanced audit with verification of relationships, transactions and beneficiaries— from 4,000 to 20,000 euros.
The company “Prikhodko and Partners” also offers a preliminary compliance check (Due Diligence Screening) from 500 euros – this allows you to assess the risks even before submitting documents to a bank or crypto exchange.

It will also be useful: Company Registration in Portugal

The main difficulties in passing financial monitoring

The most common problems include:

Lack of supporting documents for large cryptocurrency receipts.
Company structure with an offshore or nominee director.
Insufficiently understood business model or lack of operational activities.
High turnover without appropriate reporting to tax authorities.
Blocking accounts due to ties to countries under sanctions (in particular, the Russian Federation or Belarus).

“Prikhodko and Partners” provides legal structuring services that allow clients to legalize sources of funds and avoid blocking.

What is the interaction with the EU and Ukraine?

Since 2022, the mechanism for the exchange of tax and financial information (CRS/EOIR) has been actively operating between Ukraine and Portugal. Ukrainian residents are required to declare foreign accounts and income.

In addition, Banco de Portugal participates in the European AMLD (Anti-Money Laundering Directive) mechanism – which means a single monitoring policy for all EU member states.

For Ukrainian clients from Portugal, a preliminary check of tax residency and an assessment of their compliance with their status as a PEP are relevant, which can significantly complicate monitoring.