Anti-Money Laundering (AML)

Preventing money laundering and preventing terrorist groups’ access to means enabling their activities are increasingly becoming societal objectives. Indeed, the majority of economic agents are bound to specific duties aiming to combating money laundering and terrorist financing (AML/CFT).

Considering the transversal negative consequences arising from these practices, a list of preventive duties has been imposed on a very broad set of subjects (obliged entities) and rests not only with those which carry out certain type of activities (such as financial entities, auditors, accountants, companies operating in the real estate market or in virtual assets), but also with traders in general, as regards certain type of transactions.

The implementation of due procedures to comply with the duties obliged entities are bound to is particularly demanding. In fact, it may be difficult to identify the risks they face when making the proportionality assessment required to determine how to comply with the AML/CFT duties. Additionally, for obliged entities’ preventive policies to be effective, it is essential that their employees receive adequate training.

The complex and cross-cutting nature of AML/CFT is reflected at the legal level, requiring the application of several areas of law at different moments in time, during the development of the obliged entities' activities. In order to ensure proper compliance with their duties and legal protection of their position, obliged entities must rely on expert legal advice, from the definition and implementation of preventive policies to the defence in administrative or criminal proceedings.

Sérvulo’s know-how and experience ensure top quality provision of a comprehensive AML/CFT service, regardless of the sector where obliged entities operate. The following services, among others, are particularly relevant: 

• Compliance in AML/CFT matters;
• Definition and implementation of policies, procedures and internal controls;
• Training sessions in AML/CFT matters;
• Compliance with duties to identify clients;
• Compliance with the duty to register with the RCBE (Portuguese Central Register for Beneficiaries);
• Advice on interactions with the competent sectoral authority;
• Internal investigations;
• Disciplinary proceedings for breach of AML/CFT duties;
• Defence in administrative and criminal proceedings.