Global sanctions guide

  1. Does Portugal have a sanctions regime in place?


  1. Does Portugal implement UN sanctions?

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.

  1. Does Portugal implement an autonomous sanctions regime?


  1. 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.

  1. Does Portugal maintain a list of sanctioned individuals and entities?

No. Portugal relies on UN and EU sanctions lists.

  1. Are there any other lists related to sanctions in Portugal?


  1. 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.

  1. 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
  1. 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
1399-030 Lisbon

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

T: (+351) 21 882 3990/8

Contributor law firm

Rui Tabarra e Castro, FCB & A Sociedade De Advogados, Av. da Liberdade, 249, 1º, 1250-143, Lisboa

T: (+351) 213 587 500
F: (+351) 213 587 501