Source of Funds & AML Compliance

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Portugal has robust anti-money laundering (AML) and compliance measures in line with the EU’s 6th AML Directive. All applicants must provide full transparency regarding the origin of funds used for the qualifying investment. This includes:

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• Proof of lawful acquisition: tax returns, sale agreements, company divestitures, dividend income, or inheritance documents.
  
• Banking evidence: account statements, SWIFT confirmations, and transaction ledgers.
  
• Source tracing for layered wealth structures such as offshore trusts, foundations, or corporate holdings.
  
  

Documents not in Portuguese must be professionally translated and apostilled. Fund transfers must come from accounts held in the applicant’s name and be routed through licensed financial institutions. Third-party transfers require notarized declarations of relationship and purpose.

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Enhanced due diligence is required for:

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• Applicants from high-risk jurisdictions.
  
• Politically exposed persons (PEPs).
  
• Crypto-asset holders or investors with opaque corporate structures.
  
  

Applicants with complex financial profiles are advised to engage international legal counsel in coordination with Portuguese advisors to mitigate red-flag issues and ensure procedural clarity.

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