Yes. Article 8/3 of the Constitution of the Portuguese Republic provides that sanctions passed by resolutions of the UN Security Council are automatically implemented into Portuguese law. As well, Portugal is also a member of the European Union, which implements UN sanctions in all member states by way of directly applicable regulations.
Does Portugal implement an autonomous sanctions regime?
What is the nature of the sanctions regime in Portugal?
Portugal follows the restrictive measures laid down by the UN, the EU and other international organisations which are binding on Portugal.
Does Portugal maintain a list of sanctioned individuals and entities?
No. Portugal relies on UN and EU sanctions lists.
Are there any other lists related to sanctions in Portugal?
Does Portugal have a licensing or authorisation system in place?
No. All breaches of sanctions are subject to criminal punishment under Law no. 11/2002 of 16 February 2002, which does not permit any exemptions.
What are the consequences for a breach of sanctions in Portugal?
The consequences for a breach of sanctions are set out in Law no. 2011/2002. They are:
for individuals, imprisonment from 3 to 5 years
legal persons are punishable with a fine not lower than the value of the transaction carried out and not more than double that value
when the offence does not involve a financial transaction, the perpetrator may be fined between €5,000 and €2,500,000
Who are the relevant regulators in Portugal and what are their contact details?
The Ministry of Foreign Affairs (Directorate-General for External Policy, Directorate for Multilateral Political Organisations, Directorate for European Political Affairs) is responsible for trade sanctions in Portugal.
Largo do Rilvas
T: (+351) 21 394 633
The Ministry of Finance and Public Administration is responsible for financial sanctions in Portugal.
Avenida Infante D. Henrique
1100 – 278 Lisbon
Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.