What AML training does Portugal's Law 83/2017 require?
Portugal's anti-money laundering law, Law 83/2017 of August 18, requires obliged entities to give managers, employees, and other staff in AML/CFT relevant roles adequate knowledge of their obligations, specific and regular sector-appropriate training, and immediate training for new joiners in AML roles (Article 55). Training must be delivered by competent trainers, cleared by any designated compliance officer, and recorded for supervisors. Failing the duty is a particularly serious administrative offense.
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- Sectoral authorities under Law 83/2017, including Banco de Portugal, the Comissão do Mercado de Valores Mobiliários (CMVM), and the Autoridade de Supervisão de Seguros e Fundos de Pensões (ASF), with the Coordination Commission for AML/CFT policy
Key takeaways
- Article 55 of Law 83/2017 sets the training duty: adequate knowledge, specific and regular training, and training immediately after hiring for people whose roles directly concern AML/CFT.
- Training must be delivered by people or entities with recognized AML/CFT competence and, where a compliance officer is designated, have that officer's prior favorable opinion.
- Entities must keep up-to-date, complete training records, retained for seven years under Article 51 and always available to sectoral authorities.
- Breach of the training duty is listed as a particularly serious administrative offense in Article 169-A, with base fines of up to EUR 5,000,000 for credit and financial institutions under Article 170, which Article 171 can raise.
- Banco de Portugal Notice 1/2022 Article 53 details the training policy content and the minimum fields in training records for supervised financial entities.
What is Law 83/2017 and who does it apply to?
Law 83/2017 of August 18 is Portugal's main anti-money laundering and counter-terrorist financing (AML/CFT) statute. Its summary in the Diário da República states that it establishes measures to combat money laundering and terrorist financing and partially transposes Directive (EU) 2015/849 into Portuguese law. It applies to financial and non-financial obliged entities and is supervised by sector.
As at September 2026 the law is in force with amendments including Law 58/2020, Decree-Law 9/2021, Decree-Law 56/2021, Law 99-A/2021, and most recently Law 70/2025, published on December 22, 2025. None of these changed the text of Article 55. The sectoral authorities named in Article 2 include the ASF, Banco de Portugal, the CMVM, the Inspeção-Geral de Finanças, gambling, real estate, and economic inspection authorities.
Portugal is an EU Member State, and Law 83/2017 exists because the earlier AML rules were a directive, which each country writes into national law. From July 10, 2027 the EU Anti-Money Laundering Regulation applies directly in Portugal and will take over most obligations on obliged entities, including training. National law will still matter for supervision, sanctions, and sector detail.
What does Article 55 of Law 83/2017 require?
Article 55, titled the duty of training (dever de formação), requires proportionate measures so that relevant people know their AML/CFT obligations, receive specific and regular training, and are trained immediately on joining. Its five paragraphs are summarized below from the consolidated text.
- Knowledge (paragraph 1): measures proportionate to risk and to the nature and size of the business, so that managers, employees, and other staff whose functions are relevant to AML/CFT have adequate knowledge of the obligations under the law and its implementing regulations, including on personal data protection.
- Specific and regular training (paragraph 2): specific and regular training actions suited to each sector, enabling people to recognize operations that may be related to money laundering or terrorist financing and to act in line with the law.
- New joiners (paragraph 3): staff whose functions directly concern AML/CFT receive training on the entity's internal policies, procedures, and controls immediately after being hired.
- Trainers and approval (paragraph 4): internal or external training is delivered by people or entities with recognized competence and experience in AML/CFT, and is preceded by a favorable opinion from the compliance officer designated under Article 16(1), where one has been designated.
- Records (paragraph 5): up-to-date and complete records of internal and external training are kept under Article 51 and made permanently available to sectoral authorities.
Paragraph 2 in the original Portuguese reads: "ações específicas e regulares de formação adequadas a cada setor de atividade, que as habilitem a reconhecer operações que possam estar relacionadas com o branqueamento de capitais e o financiamento do terrorismo" (specific and regular training actions suited to each sector of activity, enabling them to recognize operations that may be related to money laundering and terrorist financing).
Who is responsible for AML training inside the organization?
The management body is accountable, and the compliance officer shapes and oversees the training policy. Article 13 makes the management body responsible for applying AML/CFT policies, procedures, and controls, and lists among its duties promoting a prevention culture covering all staff whose functions are relevant to AML/CFT, based on high ethical and integrity standards.
Article 16 requires a senior manager or equivalent to be designated as compliance officer (responsável pelo cumprimento normativo) where appropriate to the nature, size, and complexity of the business or where required by law or the sectoral authority. Article 16(2)(c) gives that person the role of participating in defining, monitoring, and evaluating the internal training policy. Other provisions extend the duty: under Article 75, where a non-financial obliged person works as an employee of a legal person, the training duty falls on the legal person, and under Article 90 professional bodies must ensure their members receive the training Article 55 requires.
What does Banco de Portugal Notice 1/2022 add for financial entities?
For financial entities supervised by Banco de Portugal, Notice 1/2022 (Aviso do Banco de Portugal n.º 1/2022), published June 6, 2022, details what the training policy must cover and what training records must contain. Its Article 53 requires a training policy that ensures full, permanent, and up-to-date knowledge of, among other things:
- the applicable AML/CFT legal and regulatory framework
- the entity's own AML/CFT policies, procedures, and controls
- guidance, recommendations, and information from judicial, police, and supervisory authorities or sector associations
- risks, typologies, and methods linked to criminal proceeds or terrorist financing
- vulnerabilities of the entity's business areas, products, services, operations, distribution channels, and customer communication channels
- reputational risks and the administrative offense consequences of breaching preventive duties
- each person's specific professional AML/CFT responsibilities
Article 53(2) requires new-joiner training to suit the person's experience and qualifications and to cover at least basic AML/CFT principles, the entity's internal control system, and the main risks and suspicion indicators for each business area. Article 9 of the Notice also requires the periodic independent effectiveness assessments under Article 17 of the law to cover the training policy, including the adequacy and scope of training delivered. The Notice was later amended by Notices 1/2023 and 3/2024, which changed other articles and left Articles 9 and 53 unchanged.
| Record field | What to capture in practice |
|---|---|
| Name of the training | Course or session title linked to a version of the content |
| Date | Delivery date, or completion date for self-paced learning |
| Training provider | Internal team or external provider |
| Duration in hours | Planned or measured hours |
| Nature | Internal or external training |
| Setting | In person or remote |
| Supporting teaching material | The materials used, kept or referenced by version |
| Trainees' names and roles | Internal and external participants |
| Final assessment of trainees, where one exists | Score or pass result against the assessment used |
What are the penalties for breaching the AML training duty in Portugal?
Failing the training duty in Article 55(1) to (4) is a particularly serious administrative offense (contraordenação especialmente grave) under Article 169-A(jj), and failing to keep and make available the training records under Article 55(5) is listed in Article 169-A(kk). Article 170 sets the fine ranges for these offenses.
| Entity type | Legal person | Natural person |
|---|---|---|
| Credit institution or financial institution | EUR 50,000 to EUR 5,000,000 | EUR 25,000 to EUR 5,000,000 |
| Other financial entity | EUR 25,000 to EUR 2,500,000 | EUR 12,500 to EUR 2,500,000 |
| Non-financial entities in Article 4(1)(a) to (c) | EUR 50,000 to EUR 1,000,000 | EUR 25,000 to EUR 1,000,000 |
| Other non-financial entities, except certified accountants, lawyers, solicitors, and notaries | EUR 5,000 to EUR 1,000,000 | EUR 2,500 to EUR 1,000,000 |
Law 83/2017 also states that the fine should, where possible, exceed the economic benefit derived from the offense. The ranges above are the base ranges in the consolidated text. Under Article 171, the maximum rises to twice the economic benefit where that is determinable and higher, and for legal persons that are credit or financial institutions or non-financial entities in Article 4(1)(a) to (c), to 10% of total annual turnover. Other rules in the law can also affect the final amount, so legal advice is needed for any specific case.
How should an obliged entity evidence Article 55 compliance?
Evidence should show that the right people received the right training at the right time, from a competent source, with compliance officer approval and complete records. The checklist below is illustrative and draws on the law and the Banco de Portugal Notice.
| Requirement | Evidence to hold |
|---|---|
| Proportionate measures for relevant staff (55(1)) | Role list or training matrix showing which functions are AML/CFT relevant and why |
| Specific, regular, sector-appropriate training (55(2)) | Curriculum mapped to the entity's risk assessment, refresh schedule, and knowledge checks |
| Immediate training for new joiners (55(3)) | Onboarding records showing training dates relative to start dates |
| Competent trainers (55(4)(a)) | Trainer qualifications or provider due diligence |
| Compliance officer favorable opinion (55(4)(b)) | Dated sign-off by the compliance officer on each program or material change |
| Records kept and available (55(5)) | Complete records retained for seven years under Article 51, retrievable on request |
Records that also capture assessment results make it easier to show effectiveness, which Notice 1/2022 asks independent reviews to test. Related methods are covered in how to prepare training records for an audit and how to evidence training effectiveness to a regulator.
How will the EU AMLR change AML training in Portugal from 2027?
From July 10, 2027, Article 12 of Regulation (EU) 2024/1624 sets the training duty directly, alongside a written training policy (Article 9) and skills, knowledge, and integrity assessments for staff in AML/CFT roles (Article 13). Portugal must also transpose Directive (EU) 2024/1640, mostly by the same date (Article 78 sets earlier dates for a few provisions), which will reshape the national supervisory and sanctions framework.
Much of Article 55 already aligns with the Regulation, so a program built to Law 83/2017 and Notice 1/2022 is a strong starting point. The main gaps to plan for are explicit coverage of agents and distributors, formal pre-appointment and repeated assessments under Article 13, and management body approval of the training policy. As at September 2026, Portugal's national implementing legislation for the new EU package should be checked on the Portal BCFT and in the Diário da República before finalizing 2027 plans.
How does Knowledge Foundry approach this?
Knowledge Foundry maps Article 55, Notice 1/2022, and the incoming AMLR articles to shared concepts, role competencies, and assessment points, so one curriculum can show which Portuguese and EU obligation each module and assessment satisfies. Record fields such as content version, duration, and assessment result are captured with the evidence trail.
Frequently asked questions
Does Law 83/2017 set a minimum number of AML training hours per year?
No. Article 55 requires specific and regular training proportionate to risk, nature, and size, but sets no hours or fixed frequency. Banco de Portugal Notice 1/2022 requires training records to include duration in hours, but it also sets no minimum. Entities define frequency in their training policy.
How long must AML training records be kept in Portugal?
Article 55(5) requires training records to be kept under Article 51 of Law 83/2017, which sets a seven-year retention period, and to be permanently available to the sectoral authorities.
Does AML training count toward the Labor Code's annual continuous training entitlement?
It can, where the training meets the Labor Code conditions for continuous training, but the two duties have different purposes and legal bases: Law 83/2017 sets what AML/CFT training must achieve, while the Labor Code sets a minimum amount of training per employee. See the page on Portugal's Labor Code continuous training.
Who approves AML training content under Law 83/2017?
Where a compliance officer is designated under Article 16(1), training must be preceded by that officer's favorable opinion (Article 55(4)(b)). The compliance officer also participates in defining, monitoring, and evaluating the training policy, while the management body remains responsible under Article 13.
Sources
- Lei n.º 83/2017, de 18 de agosto (versão consolidada), Diário da República, Imprensa Nacional-Casa da Moeda
- Aviso do Banco de Portugal n.º 1/2022, de 6 de junho, Diário da República (issued by Banco de Portugal)
- Portal BCFT: prevention of money laundering and terrorist financing, Comissão de Coordenação das Políticas de Prevenção e Combate ao Branqueamento de Capitais e ao Financiamento do Terrorismo
- Regulation (EU) 2024/1624 (Anti-Money Laundering Regulation), EUR-Lex, Publications Office of the European Union
This page is general information, not legal or compliance advice. Check the primary sources above and obtain advice for your circumstances. See our editorial standards.