Anti-Money Laundering and Combating Terrorist Financing & Sanction

Your problems 

  • Your organization is an obligated entity in accordance with Law n.º 83/2017 and with the regulation of the respective sectorial authority and needs to assess the degree of compliance of your AML/CTF & Sanctions internal control system.
  • You aim to ensure the strengthening of your institution's AML/CTF & Sanctions internal control system through: (i) resolving legal or regulatory non-compliance; (ii) the creation and/or updating of policies and manuals of procedures in this area, and (iii) reviewing/creating the institution's Money Laundering/Terrorist Financing (“ML/TF”) & Sanctions risk assessment.
  • Your entity's supervisory body intends to obtain support from a team of AML/CTF & Sanctions specialists to issue the opinion required by the paragraph 4 c) of the article 83º (4)(c) of the Notice n.º 1/2022 of Bank of Portugal.
  • You want to ensure the performance of KYC/EDD procedures (including verification of the existence of applicable Sanctions) of its individual clients, corporate clients (including their representatives and beneficial owners), suppliers, potential business partners or other entities with which your entity has business relationships.
  • Provide the organization's employees with knowledge of AML/CTF & Sanctions, at all times and in an up-to-date manner in accordance with the current legal and regulatory framework.
  • You want to follow the guidelines regarding the implementation of whistleblowing channels, according to the Law No. 83/2017 (measures to combat money laundering and terrorist financing) or other applicable sectorial and specific legislation.

How we can help

Anti-Money Laundering and Combating Terrorist Financing (AML/CTF) & Sanctions has been a prominent theme and the center of attention not only for the regulators but also for the obligated entities, in the sense that a robust and effective prevention system is the first line of defense of potential negative impacts to the Institutions reputation.

We provide support in eight big areas:

Gap Analysis

The Gap Analysis will allow you to make a diagnosis to the procedures of AML/CTF & Sanctions of the obligated entities and identify the next steps to keep aligned with the legal and regulatory requirements.

It enables to identify opportunities of improvement as well as gaps in the internal control system, allowing the design and implementation of the most adequate measures for its mitigation/resolution.

The efficiency tests are made considering the dimension, complexity and nature of the activity proceeded by the obligated entity and has as target all the controls implemented in the scope of AML/CTF & Sanctions. They are also designed in order to respond to the requirements of article 17.º from Law n.º 83/2017.

Support to the oversight bodies of financial institutions

Our team of specialists has a wide experience in supporting oversight bodies of retail banks, investment banks, credit institutions, among others, to issue their opinion as required in Notice n.º 1/2022 from the Bank of Portugal.

Our work consists of the reviewing of the AML/CTF & Sanctions internal control system, which includes conducting meetings of understanding of processes and procedures and performing tests to the identified controls, considering the dimension, complexity and nature of the activity proceeded by the obligated entity.

Roadmaps and/or Remediation Plans

Design of roadmaps and implementation of remediation plans with the goal of mitigating the obligated entity’s exposure to the AML/CTF & Sanctions risks.

This process will allow to better outline the strategy to address the situations of risk identified by the obligated entity, to make the AML/CTF & Sanctions internal control system more robust.

Outlining Roadmaps and/or Remediation Plans may be based on a Gap Analysis or other diagnosis exercise made by the obligated entity to the AML/CTF & Sanctions internal control system.

Policies and Manuals of Procedures

The elaboration and/or revision of policies and manuals of procedures of AML/CTF & Sanctions is fundamental to transpose to formal documentation the existing procedures in this scope and present them to the employees and to the legal and sectorial authorities.

The elaboration and/or revision of these Policies and Manuals of Procedures will allow to comply with the requirement of article 12.º from Law n.º 83/2017.

Risk Matrix

Designing a Risk Matrix considers the risks attached to the products made available to the clients, the services and channels of distribution made available to clients, the nature of the clients of the obligated entity and the geographical location in which it operates. This matrix also identifies the nature, extension, and probability of occurrence of each risk, as well as the implemented controls to mitigate the identified risks. Therefore, the obligated entity will be able to measure the global risk of ML/TF & Sanctions.

The Risk Matrix will allow to comply with the requirement of article 14.º from Law n.º 83/2017.

Know Your Client / Enhanced Due Diligence

Our services include (i) from the analysis of new clients and of existing clients of the obligated entity regarding to the analysis of the elements of identification and means of proof and (ii) the necessary diligences to apply, including the searches in public and private data bases, aiming to identify adverse media, Politically Exposed Person (“PEP”) and sanctions.

Our work is concluded through the issuance of a report with the results of our analysis regarding the procedures of filtering made to clients and with the attribution of the respective scoring of ML/TF & Sanctions (if available).

Through these procedures will allow to comply with the requirements of Identification and Diligence duties of the Law n.º 83/2017.


We intend that the employees of the obligated entities are informed about the adequate controls and practices of AML/CTF & Sanctions, aiming the adoption of measures of AML/CTF & Sanctions proportional to the risks of the activity. Our goal is to make the culture of Compliance more robust and aware the employees from several departments to the importance of AML/CTF & Sanctions topic.

Through the training actions will allow to comply with the requirement of article 55.º from the Law n.º 83/2017.

Whistleblowing channel

In order to comply with article 108.º from Law n.º 83/2017, our team supports the implementation and operation of whistleblowing channels, as well as the adoption of supporting materials about these matters.

See our support in more detail here.

Contact us

Carolina Costa

Carolina Costa

Director, PwC Portugal

Rita Maria Pereira

Rita Maria Pereira

Senior Manager, PwC Portugal

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