"Portugal published a summary of its national ML/TF risk assessment in 2015, whichhighlighted that the main ML predicate offences in the country are tax crimes, drug trafficking, fraudand corruption. The NRA also establishes that vulnerabilities include, inter alia: anonymousoperations and transactions; informal transfer systems; the lack of knowledge of beneficial ownersand existence of bearer securities; the lack of transparency in the real estate sector; and lack of
resources for the supervision of compliance with AML/CFT requirements. Portugal also identifiedspecific business sectors at risk, in particular the banking sector, real estate and high-value goods dealers, as well as countries which pose the most significant ML/TF risks for the country.1 On the TF side, the NRA indicates that the major risks to the country relate to Islamist groups and separatist movements. Portuguese authorities are not able to provide concrete
information and/or comprehensive statistics on the numbers and values of assets effectively
confiscated or lost in favour of the State. Portuguese authorities’ detection and confiscation of illicit
cross-border movements of currency have decreased over recent years, as have the amounts of fines
applied..The impact of the Tax and Customs Authority (AT)
oversight of registered NPOs to protect those entities from abuse by terrorist financiers is limited to
tax compliance..
The evaluation was conducted by an assessment team consisting of:
Rafael Abad, SEPBLAC, Spain
Ayreen Alibux, Dutch Central Bank, The Netherlands
Davide Quattrocchi, Guardia di Finanza, Italy
Swandra Ramachandran, Central Bank of Malaysia
Ritva Sahavirta, Office of the Prosecutor General, Finland
Cristina Schwansee Romano, Ministério Público Federal, Brazil
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