AML/CTF reporting duties for EU entities providing cross-border financial services in Portugal

Under article 3(2)(d) of Law 83/2017 of 18 August 2017 (“Law 83/2017” or the “AML/CFT Law), financial entities operating in Portugal under the freedom to provide services must comply with the AML/CFT Law requirements with respect to the duties to report to the appropriate supervisory authority concerning their cross-border activities in Portugal.

Recently, the Portuguese Securities Markets Commission (“CMVM”) published Regulation 2/2020 and Banco de Portugal concluded public consultation paper 3/2019, which, among others, includes a draft Instruction setting out the terms and conditions for the annual report to Banco de Portugal). Following this, we are now providing a brief summary of the current and expected regulatory reporting duties for financial institutions providing cross-border services in Portugal under the free provision of services subject to the supervision of the CMVM and/or Banco de Portugal.