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Money Laundering and Terrorist Financing

Combating Money Laundering and Terrorist Financing

Law No 83/2017 of 18 August lays down preventive and punitive measures to combat money laundering and terrorist financing, partly transposing to the Portuguese legal system  Directive 2015/849/EU, of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of financial systems and activities and professions specially assigned for the purpose of money laundering and terrorist financing, as well as Council Directive 2016/2258/EU, amending Directive 2011/16/UE on the right to access anti-money laundering information on the part of tax authorities.

Law No 83/2017 repeals Law 25/2008 of 5 June. Article 7, headed “Registrars and Register officers”, states that Registrars and Register officers are deemed ancillary entities to prevent and combat money laundering and terrorist financing. Whilst performing their duties, Registrars and Register officers are subject to the following obligations:

  • obligation to notify (as provided for in Article 43)
  • obligation to cooperate (as provided for in Article 53)
  • non-disclosure obligation (as provided for in Article 54, with respect to notifications under the previous subparagraphs)
  • examination and non-participation obligations when ownership acts are at stake.

The obligations arising from the provisions of Law No 83/2017 and the regulations implementing thereof, are part of the employment relationship in public service of Registrars and Register officers, and therefore its non-compliance is subject to the Regulation.

IRN, by operation of Law No 83/2017 is an entity equivalent to a sector authority, and the respective Regulation shall apply, mutatis mutandis, as specified in Articles 101 et seq. of the law in question.

As far as notaries are concerned, this role falls under the Government of the Member State responsible for the area of justice, assisted by IRN.

To contact IRN for matters concerning compliance with the requirements in preventing and combating money laundering or terrorist financing, the registrar may send an email to: