Global sanctions guide

  1. Does Portugal have a sanctions regime in place?


  1. Does Portugal implement UN sanctions?

Yes. According to Article 25 of the Charter of the United Nations and Article 8/3 of the Constitution of the Portuguese Republic, sanctions imposed by the UNSC are automatically applicable in Portuguese internal legal order by mere effect of such resolutions and need no incorporation.

  1. Does Portugal implement an autonomous sanctions regime?


  1. What is the nature of the sanctions regime in Portugal?

Portugal is a member state of the EU. The EU has the power to impose restrictive measures both on its own initiative and in accordance with Resolutions of the UNSC. Restrictive measures are set out by EU Regulations which have direct effect and direct applicability. Therefore, restrictive measures are binding on EU member states, applying to EU nationals, whether or not they are in the EU, companies and other entities incorporated or constituted under the law of a member state, to any business done in whole or in part within the EU or on board of aircrafts or vessels under the jurisdiction of a member state.

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

No. The only list Portugal refers to is the EU and UN sanctions lists.

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


  1. Does Portugal have a licensing or authorization system in place?

There is no such system in force in Portugal. Any breach of sanctions is subject to criminal punishment under Law no. 11/2002, of 16 February 2002, which does not foresee any kind of exemption regime.

  1. What are the consequences for a breach of sanctions in Portugal?

In 2002, criminal legislation was adopted by the Parliament establishing sanctions in case of violation of sanctions imposed by Security Council resolutions and EU Regulations (Lei n.o 11/2002, of 16 February 2002).

  1. Who are the relevant regulators in Portugal and what are their contact details?

Ministry for Foreign Affairs Directorate-General for External Policy, Directorate for Multilateral Political Organisations, Directorate for External Policy and Common Safety

Ministry for Foreign Affairs
Largo do Rilvas
1399-030 Lisbon

T: (+351) 213 946 433

The Ministry of Finance and Public Administration
Office for the Planning, Strategy, Evaluation and International Affairs
Avenida Infante D. Henrique, n.. 1C
1st floor

T: (+351) 218 823 390/8

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