Portugal — Country Risk Report

Portugal (Europe • Southern Europe). Risk report as of the 19 Jun 2026 FATF plenary.

Low country risk. Portugal's country risk score is 2.9/10, placing it in the low-risk band. The principal driver is weak corruption. Portugal is not currently FATF grey- or black-listed. Portugal is not subject to comprehensive country-wide sanctions.

Recommended treatment

Standard due diligence.

At a glance

• FATF status: Not currently listed (one indicator only; it does not set the overall country risk rating by itself)
• Comprehensive country sanctions: none identified. Targeted sanctions exposure: possible, screen applicable persons, entities and sectors
• Government effectiveness and rule of law: 2.8/10
• Corruption (CPI 2025): 56/100, rank #46 of 182
• Enforcement: 133 actions from 1 regulator

Country Risk Score: 2.9/10 (Low)

Higher score means higher country risk (global average 4.6). Full information available. Limited supporting information. Enforcement activity and CPI are shown for context but do not change the score.

All three parts of the score are available.

How this score was calculated

• Financial crime controls: 4.2/10 — 50% of this score
• Government effectiveness and rule of law: 2.8/10 — 30% of this score
• International sanctions: 0.0/10 — 20% of this score
• The FATF assessment is more than eight years old.

International sanctions contributes 0.0 because the complete UN, UK, EU and US review found no direct country-level sanctions programme. People or organisations connected to the country may still appear on sanctions lists.

Principal risk drivers

• Government effectiveness and rule of law drive the score; no FATF listing or direct country-level sanctions were identified

Mitigating factors

• Not currently on the FATF grey or black list.
• No comprehensive country-wide sanctions programme.
• Comparatively stronger voice and accountability (2.1/10).
• Overall governance and institutional quality are relatively strong.

Business impact

• Customer onboarding (Low): Additional ownership and control verification may be required.
• Payments and transactions (Low): Review transaction purpose, counterparties and geographic routing.
• Trade and export activity (Low): Screen goods, end users and potential dual-use exposure.
• Corporate clients (Low): Assess state ownership, government links and political exposure.
• Ongoing monitoring (Low): Apply alerts for ownership changes, sanctions and geopolitical developments.

Recommended controls

• Verify ultimate beneficial ownership using more than one reliable source.
• Identify state ownership, government influence and politically exposed persons.
• Screen entities, directors and beneficial owners against applicable sanctions lists.
• Apply enhanced review to technology, defence, telecommunications, financial services and dual-use activity.
• Document transaction purpose and source of funds where cross-border structures are complex.
• Escalate unresolved ownership opacity or adverse information to Compliance.

Enhanced due diligence triggers

• State ownership / control
• PEP involvement
• Sensitive / restricted sectors
• Opaque ownership
• Adverse media
• Dual-use goods & technology
• High-risk intermediary routing

FATF status: Not currently listed

Portugal is not on the FATF grey or black list as of the 19 Jun 2026 plenary.

Source details

International sanctions by issuing body

• UN: No
• EU: No
• UK: No
• US: No

No means the complete UN, UK, EU and US review found no direct country-level programme. People or organisations may still appear on sanctions lists.

Government effectiveness and rule of law (World Bank 2024, percentile)

• Government Effectiveness: 70/100
• Regulatory Quality: 67/100
• Rule of Law: 75/100

Enforcement activity

RegActions tracks 133 enforcement actions from 1 regulator in Portugal.

• CMVM — Comissão do Mercado de Valores Mobiliários (133 actions, 1999-2026)

The composite RegActions Country Risk Score does not use enforcement volume.

Regulators and legal framework

FATF network

FATF member.

Last mutual evaluation: 2017 · report

National regulators

• CMVM — Comissão do Mercado de Valores Mobiliários (133 actions, 1999-2026)

FIU: Egmont Group member (UIF)

Framework signals

• FATF listing: Not currently listed
• International sanctions: no listed programme identified
• BO register: Public (live since 2018)
• Corruption (CPI 2025): 56/100, rank #46 of 182
• Rule of law (WGI): 2.9/10 risk

Sector exposure

• Banking & payments (Low): No FATF listing, rule-of-law governance within normal range
• Trade & export controls (Low): No sanctions programme or FATF black-list constraint identified
• Crypto & virtual assets (Low): No FATF listing, accountability governance within normal range
• Real estate & luxury assets (Low): Corruption indicators within normal range for high-value assets
• State-linked & procurement (Low): Political-stability and corruption governance within normal range

Derived from sanctions tier, FATF listing, World Bank WGI governance and CPI; no per-sector dataset is asserted.

Portugal: analysis

Portugal's profile is anchored by sound governance. The weakest domain is corruption (35% weight), though it remains within a range consistent with a well-functioning EU economy. Rule of law and institutions (40% weight) and political stability (15% weight) provide a strong institutional foundation. Voice and accountability (strong) is the lowest risk domain. The CPI reading, validates the moderate-low corruption picture. The CMVM's 133 enforcement actions over more than two decades reflect a regulator with consistent supervisory activity. No FATF listing or sanctions apply.

Outlook

Portugal's risk profile is expected to remain stable within the low-risk band. The CMVM's sustained enforcement record is a positive indicator of supervisory quality. The corruption domain, while the weakest governance score, remains manageable. EU regulatory alignment is likely to continue supporting strong institutional frameworks. No material deterioration is anticipated.

Key watchpoints

• Ongoing enforcement trends at the CMVM and any changes in supervisory priorities or focus areas.
• Corruption domain developments, including any changes to national anti-corruption frameworks or CPI trajectory.
• EU-level regulatory developments, including the EU AML Authority, that may affect compliance obligations.
• Any change to FATF listing status, though the risk of listing is low given current governance indicators.

Assessment currency

• FATF status: Not listed (as of 19 Jun 2026)
• Sanctions exposure: None identified (as of Jul 2026)
• Governance (WGI): Latest dataset incorporated (as of 2024)
• Corruption (CPI): 56/100 (as of 2025)
• RegActions assessment: Reviewed (as of 19 Jun 2026)

Public evidence layer

FATF action: none. No FATF call-for-action or increased-monitoring status was identified at the latest plenary. This does not establish low risk.

Contextual signals (not scored)

• FATF network membership: Direct FATF member (present, as of 2026-07)
• EU non-cooperative tax jurisdictions: Not listed in Annex I (absent, as of 2026-02-17)
• Egmont Group FIU: UIF (present, as of 2026-07-17)
• Beneficial-ownership register: Public (live since 2018) (present, as of 2026-07-17)
• Transparency International CPI: 56/100, rank 46 (present, as of 2025)

Evidence freshness

• FATF monitored-jurisdiction status: current; data 2026-06-19
• FATF mutual evaluation and follow-up ratings: current; data 2026-07-31; follow-up 2017-12; base assessment 2017-12
• World Bank governance indicators: current; data 2024
• UN, UK, EU and US sanctions regimes: current; data 2026-08-16

Contextual signals are public evidence only and do not change the immutable v2 score.

Download evidence PDF · CSV · JSON

Regional peer scores

• Belarus: 6.0/10 (High)
• Bosnia and Herzegovina: 6.0/10 (High)
• Bulgaria: 6.0/10 (High)
• Monaco: 6.0/10 (High)
• Montenegro: 6.0/10 (High)
• Russia: 6.0/10 (High)

Source: FATF black & grey lists · World Bank WGI (CC BY 4.0 — World Bank WGI) · TI CPI (CC BY-ND 4.0 — Transparency International, display only)