Portugal does not publish a single national "sanctions and PEP extract" document. Screening a supplier, contractor, or commercial counterparty against sanctions and politically exposed person (PEP) lists in the Portuguese context requires combining at least three separate data layers: the EU consolidated sanctions list (administered by the European External Action Service and binding across Portugal by direct EU regulation). The domestic list maintained by the Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF) and the Banco de Portugal under Law 83/2017 on anti-money laundering. Additionally, commercially aggregated PEP databases that draw on public records. including official gazette publications, Citius court data. Additionally, companies register filings. to identify domestic political figures and their close associates. The practical task for a buyer doing supply-chain due diligence is therefore to build a composite picture from public and semi-public sources. Cross-checked against the company's own registration and financial filing records, rather than to order a single certificate from a single registry.
Why "sanctions extract" is not a single document in Portugal
Under EU Regulation 2580/2001 and the consolidated framework updated by successive Council regulations. Sanctions designations applying in Portugal are EU-level instruments with direct legal effect. they are not re-issued by a Portuguese national authority as a separate certificate. The Banco de Portugal and ASF transpose the obligation to screen and report into their supervisory circulars, and regulated entities (banks, insurers, notaries, real estate agents, lawyers) must maintain ongoing screening processes. A company outside the regulated sector – for example, a manufacturer evaluating a Portuguese distributor – faces no automatic notification; it must conduct screening on its own initiative using available list sources.
EU consolidated sanctions list. The list is publicly searchable through the European Union's official sanctions map portal, updated in real time on each designation date. The list covers natural persons, legal entities, vessels, and aircraft. It includes the legal basis for designation, the date, and any known identifiers (passport numbers, addresses, registration numbers). For Portugal-connected entities, identifiers typically include the NIF (Número de Identificação Fiscal) or NIPC (Número de Identificação de Pessoa Colectiva) where the designating authority has been able to establish one. Absence of a NIF in the list entry does not mean the entity is not listed. it may simply mean the identifier was not available at designation time. This is a known limitation for rapidly designated Russian, Belarusian, and Iranian counterparties.
Domestic AML list and suspicious transaction registers. Law 83/2017 (Portugal's AML statute, transposing the Fourth and Fifth EU AML Directives) requires a national risk assessment and sector-specific customer due diligence. The list of entities subject to enhanced due diligence as PEPs is not published as a downloadable database. it is defined functionally. anyone who holds or has held within the preceding twelve months a prominent public function (member of government. Senior judicial official, member of parliament, board member of a state-owned enterprise, senior central bank official, ambassador) plus their immediate family members and known close associates. Identifying who falls within this functional definition for Portugal requires searching the Diário da República (the official gazette, freely accessible through dre.pt) for appointments to relevant offices. Cross-checking against the Registo de Titulares de Órgãos de Pessoas Coletivas held in the IRN companies register, and. for state-owned enterprise directors. reviewing filings in the Base de Dados de Entidades do Sector Empresarial do Estado.
Layer 1 – Companies register (Registo Comercial)
What it shows. The IRN's Registo Comercial (commercial register) records the identity and tax number of directors, statutory auditors. Shareholders above the disclosure threshold, beneficial owners (under Law 89/2017 on the Central Register of Beneficial Ownership, RCBE). Additionally, changes to these over time. For supply-chain screening, the beneficial ownership register is the most operationally important layer: it is mandatory for all Portuguese companies and branches, and it is publicly searchable without prior registration through the RCBE portal. The RCBE records the name, nationality, date of birth, and nature of the beneficial interest of each person who owns or controls more than 25% of shares, voting rights, or otherwise exercises effective control.
Access and cost. Viewing a certidão permanente using the permanent code issued to the entity is free. Ordering a new certidão permanente – a digitally signed extract covering incorporation data, share capital, directors, and registered charges – is a paid service through the IRN online platform. The RCBE beneficial ownership extract is separately obtainable online. Foreign requestors without a Portuguese NIF must act through a representative or use the document code issued to the company to view the extract directly.
What it does not show. The register shows current and recently registered beneficial owners. However. Registration lags are common: companies are required to update RCBE records annually and on any change. However, enforcement of this obligation has been inconsistent. A counterparty that changed its UBO structure after a share transfer may have a stale entry. The register also does not show whether any listed person appears on a sanctions list – that cross-check is the researcher's own task.
Layer 2 – Citius court records and the Lista Pública de Execuções
Citius portal – what it covers. The Citius portal (administered by the Ministry of Justice) provides free public access to certain court data relevant to supply-chain risk: the list of pending injunctions (providências cautelares). Case distribution in insolvency and restructuring proceedings (insolvência, PER, PEAP, PEVE). Additionally, notices of auction of assets subject to enforcement. Search is by NIF or NIPC. Critically, the default search window in Citius is the last 30 days. a researcher who does not manually extend the date range to "Todos" (all) will receive a false-negative result that suggests the counterparty has no proceedings. This is a frequently overlooked procedural pitfall.
Lista Pública de Execuções. This is a separate public register, also administered under the Ministry of Justice framework, listing debtors against whom enforcement proceedings have been initiated and that remain unsatisfied above a statutory threshold. It is distinct from Citius insolvency search and must be checked independently. A supplier appearing on this list is subject to active enforcement for unpaid debts – a material supply risk indicator regardless of whether it is separately sanctioned.
Citius – what it does not cover. Citius does not replace the Lista Pública de Execuções. Does not cover the Central de Responsabilidades de Crédito (the credit register maintained by Banco de Portugal. This is accessible only to regulated financial institutions and to individuals about their own data). Additionally, does not show historical insolvency proceedings closed before the entity's NIF was indexed. Proceedings in the Tribunal de Comércio de Lisboa prior to digitalisation may have incomplete Citius entries.
Layer 3 – Official gazette (Diário da República) for PEP identification
Mechanism. The Diário da República Electrónico (DRE) is the authoritative publication for all government appointments, dismissals, and official acts. It is freely searchable by name or entity. For PEP identification, DRE is the primary source for confirming whether a named individual has held a qualifying public function: ministerial appointments. Nominations to regulatory board positions, appointments to the boards of state-owned enterprises (publicised under the relevant statutes), and judicial appointments. DRE records go back several decades in digitised form, allowing researchers to check whether a person held a qualifying position within the look-back window relevant to their enhanced due diligence obligation (twelve months post-departure from office under Law 83/2017. Extendable to 18 months at the obliged entity's discretion).
Limitations for foreign-name searches. DRE search is optimised for Portuguese-language name strings. Names transliterated from Arabic, Cyrillic, or Chinese scripts may yield no results even for individuals who do appear in DRE with a different romanisation. This is a known gap when screening suppliers with non-Portuguese directors who have been appointed to advisory or board roles in Portuguese state entities.
Layer 4 – Insolvency register cross-check
Scope of the CIRE framework. Under the Código da Insolvência e da Recuperação de Empresas (CIRE), insolvency proceedings are public. The Citius insolvency section records the opening, creditor meetings, plan approvals, and closure of proceedings. For supply risk, the key indicator is not merely whether the counterparty is currently insolvent but whether it has recently emerged from a PER (Processo Especial de Revitalização) or PEAP. This may indicate recent financial distress that has not yet resolved underlying cash-flow vulnerability. The composition of the insolvent estate (massa insolvente) is a separate section under Article 152 CIRE and is not automatically visible in the standard Citius search result.
Layer 5 – Financial statements (IES / Depósito de Contas)
What is accessible. Portuguese companies above the simplified regime threshold are required to file annual accounts (IES – Informação Empresarial Simplificada) with the Tax Authority, and to deposit annual accounts with the IRN. A certidão de contas anuais can be requested online through the IRN platform. A paper certificate costs €55; the electronic version is available at a lower rate (confirm the current schedule with the IRN at time of order). The official FAQ for this service confirms that information can be provided in English, which is relevant for foreign purchasers. Financial statements allow a researcher to verify revenue scale, liability load, and whether the auditor has issued a qualified opinion – all supply-chain risk indicators independent of formal sanctions status.
Gap: late filers. The IRN deposit obligation and the IES filing obligation are enforced through tax penalties, but filing delays of 12–18 months are not uncommon for small and medium companies. A counterparty whose most recent available accounts are two years old is not necessarily insolvent, but the gap is itself a risk signal that warrants follow-up.
The composite screening workflow
A defensible supply-chain sanctions and PEP screening for a Portuguese counterparty – one that would withstand regulatory scrutiny from a bank, an auditor, or a public procurement compliance review – typically requires the following sequence:
Step 1. Obtain the NIPC of the counterparty from the IRN or from its own documentation. Verify it against the Registo Comercial certidão permanente (ordered or viewed by code).
Step 2. Search the RCBE beneficial ownership register by NIPC. Record the name, nationality, and date of birth of each beneficial owner above 25%.
Step 3. Screen each identified name – legal entity and all beneficial owners – against the EU consolidated sanctions list using the NIPC/NIF as a primary identifier and the name as a secondary check.
Step 4. Search the DRE by each beneficial owner's name to identify any qualifying public function held in the preceding 18 months.
Step 5. Run a Citius insolvency search by NIPC with the date filter set to "Todos." Record the result and the date of the search.
Step 6. Check the Lista Pública de Execuções separately by NIPC.
Step 7. Obtain the most recent available annual accounts from the IRN depósito de contas.
Step 8. Run the same name-screening steps through at least one commercially aggregated PEP/sanctions database to catch designations in non-EU lists (OFAC SDN. UK FCDO, UN) and to capture PEP associations not yet reflected in DRE publications.
Each step should be documented with a screenshot or download timestamped to the search date, because list status can change. an entity may be listed after your initial search or delisted before a follow-up review.
Service tiers – what Ferraz & Whitmore covers
| Tier | What is included | What is not included | Fee (EUR, excl. VAT) |
|---|---|---|---|
| Signal | EU consolidated sanctions list check (by NIPC/NIF and name); RCBE beneficial ownership extract review; Citius insolvency search (full date range); Lista Pública de Execuções check; written one-page summary of findings | DRE PEP history research; commercial database screening; financial statements review; legal opinion on risk classification; ongoing monitoring | 290 |
| Standard | All Signal steps plus: DRE name search for each beneficial owner (12-month PEP look-back); IRN certidão permanente (ordered and reviewed); most recent annual accounts from depósito de contas (reviewed for distress indicators); OFAC SDN and UK FCDO list checks; written two-page due diligence memo with risk classification | Commercial PEP database subscription screening beyond OFAC/UK lists; litigation history beyond Citius insolvency section; legal opinion signed for third-party reliance; ongoing monitoring | 530 |
| Extended | All Standard steps plus: commercial aggregated PEP/sanctions database screening (minimum three list aggregators); 18-month DRE PEP look-back; review of any Citius enforcement and injunction proceedings; cross-border beneficial ownership tracing where parent entities are non-Portuguese; legal opinion suitable for third-party reliance (e.g., for bank KYC file or public tender compliance); 12-month re-screening upon request | Physical on-site verification; interviews with counterparty personnel; forensic accounting; court file retrieval beyond publicly searchable Citius data | 1,100 |
Timeline expectations
Turnaround for Signal tier. Standard turnaround is two to three business days from receipt of the counterparty's NIPC and full legal name. Rush delivery (next business day) is possible for Signal-tier work where no beneficial owner research is required beyond the RCBE extract.
Standard tier. Four to six business days, depending on the volume of beneficial owners identified and whether any require DRE name searches involving variant spellings or historical name changes.
Extended tier. Seven to twelve business days. Cross-border beneficial ownership tracing – where the Portuguese entity is owned through a chain of holding companies in non-EU jurisdictions – is the principal variable. Jurisdictions with opaque registries (some Caribbean, Central American, or Gulf structures) may require additional time or may produce a "not determinable" result for UBO identity, which is itself a reportable finding.
Key limitations and what this procedure will not show
No access to Banco de Portugal credit register. The Central de Responsabilidades de Crédito. This records credit exposures of natural and legal persons across the Portuguese banking system. Is accessible only to regulated financial institutions and to data subjects about their own records. A supplier-side due diligence check cannot access this register. Total debt load can only be estimated from published annual accounts and Citius enforcement data.
RCBE registration lags. As noted, the RCBE is only as current as the most recent update filed by the company. If beneficial ownership changed in the last quarter and the company has not yet updated its RCBE filing, the extract will not reflect the current structure. Comparing the RCBE extract against the IRN certidão permanente (which shows shareholding for SA companies and quota holders for Lda companies based on registered acts) helps identify structural divergence. However. It does not guarantee that an undisclosed UBO change is detected.
Non-EU sanctions lists not automatically covered. The EU consolidated list does not incorporate OFAC SDN designations, UK FCDO designations. Swiss SECO list designations. Alternatively, UN Security Council designations as separate entries. although EU regulations may independently implement UN designations. A counterparty may appear on the OFAC list without appearing on the EU list, or vice versa. For any supply chain with US-dollar settlement, a US correspondent bank, or US-origin goods or technology, OFAC screening is mandatory and cannot be substituted by EU list screening alone.
PEP functional definition – ongoing nature. A person who left a qualifying public function seventeen months ago is no longer a PEP under the twelve-month standard look-back in Law 83/2017. However. Many compliance programmes and international banks apply an 18-month or 24-month window. The extended tier of this service applies the 18-month window by default; clients operating under tighter institutional standards should specify their required look-back period at the time of instruction.
Sanctions evasion structures. No registry search detects deliberate concealment. Complex multi-layered ownership designed to disguise a sanctioned beneficial owner will not be fully revealed by Portuguese registry searches alone. Extended-tier work includes cross-border tracing but cannot guarantee detection of structures that use nominee arrangements in non-cooperative jurisdictions.
Before a transaction or contract – practical checklist
Clients entering a significant supply contract with a Portuguese counterparty – whether as buyer, financier, or subcontracting party – should confirm the following before signature:
NIPC verified. Confirm the NIPC on official IRN documentation, not just from the counterparty's letterhead. Typos and deliberate misstatements of NIF/NIPC are a known due diligence risk.
RCBE extract obtained. An RCBE extract dated within 30 days of contract signature is the minimum standard for new counterparty relationships under Law 83/2017 for obliged entities. Non-obliged parties adopting this standard demonstrate commercially reasonable diligence.
EU list and OFAC checked. Both checks should be run on the entity and on each identified beneficial owner by name and by any known passport number or registration number. Document the exact date of each check.
Annual accounts reviewed. At minimum, confirm that the most recent filed accounts exist and are less than 18 months old. For contracts above €500,000 in annual value, review the accounts for the net equity position, current ratio, and auditor opinion.
Citius search with "Todos" filter. Run with the date filter set to all dates. Document the result.
Contractual AML clause. For ongoing supply relationships, include a contractual representation by the counterparty that no beneficial owner is a designated person or PEP. With an obligation to notify of any change during the contract term and a right of termination for breach of that representation.
How to instruct us
To commission a sanctions and PEP screening for a Portuguese counterparty, contact us at info@ferrazwhitmore.com with the subject line "PT Sanctions Screening – [counterparty name]". Include the NIPC if known, the names of any beneficial owners already identified, the proposed contract value and currency. Additionally. Any US-nexus factors (US-dollar settlement, US-origin goods, US parent entity) that may require OFAC screening as a primary rather than supplementary check. For complex structures or time-sensitive transactions, you may also submit a request through the contacts page and we will revert with a scoping note within one business day.
For context on the broader regulatory environment governing supply-chain compliance in Portugal, see our practice overview at Trade & Sanctions and the related materials in the Analytics section.
Disclaimer: This page is provided for general informational purposes only and does not constitute legal advice. The procedures, timelines, and registry characteristics described reflect publicly available information as of the publication date. Registry interfaces, fees, and applicable law may change. Ferraz & Whitmore accepts no liability for decisions made on the basis of this page without specific legal advice. Readers should seek qualified legal counsel for any compliance, transactional, or regulatory matter.