On 5^th June 2024, the Bank of Portugal published two regulations which establish a new reporting model (abbreviated to ‘RPB’) for the prevention of money laundering (ML) and terrorist financing (TF).

Bank of Portugal Instruction 8/2024 revokes Bank of Portugal Instruction 5/2019 of 30^th January and Bank of Portugal Instruction 6/2020 of 6^th March, establishing a new RPB model. 

This new model must be sent annually to the Bank of Portugal by the financial entities subject to its supervision for the purposes of preventing money laundering and terrorist financing, through the BPnet system. 

In this regard, the RPB must be composed of:

• Part 1 – Main Body;
• Part 2 – Intrinsic Risk;
• Part 3 – ML/TF prevention policies, procedures and controls;
• Part 4 – Deficiencies identified in terms of preventing ML/TF;
• Part 5 – Criminal offences and administrative offences;
• Part 6 – Self-assessment;
• Annex I – Overall opinion of the financial institution's management body;
• Annex II – Opinion of the supervisory body.

Additionally, financial entities are required to notify the Bank of Portugal of any changes to certain categories of data, namely name and email address, concerning the:

• Executive member of the management body;
• Head of the general compliance function;
• The person responsible for monitoring compliance with the regulatory framework for preventing ML/TF and their substitute.

The RPB must be sent by 31^st March of each year, referring to the period between 1^st January and 31^st December of the previous year. Exceptionally, the RPB regarding the period from 1^st January 2023 to 31^st December 2023 can be sent by financial entities until 30^th September of this year.

Bank of Portugal Notice 3/2024 amends article 83 of Bank of Portugal Notice 1/2022 of 6^th june, in order to adapt it to the new reporting model approved.

Both regulations came into force on 6^th June 2024.