White-Collar Crime 2025

Last Updated October 23, 2025

Portugal

Trends and Developments


Authors



Rogério Alves & Associados is a full-service law firm with national and international reach, established in 2013 in Lisbon. The firm has significant experience in criminal law and the lawyers that work in this team cover most types of criminal law proceedings. They represent clients in economic and financial crimes (white-collar crimes), crimes against honour and against property, as well as in the context of regulatory offences litigation, the scope, importance and intensity of which continue to grow. The connection between the lawyer and the court is historical and traditional, and Rogério Alves & Associados does justice to this tradition.

The rapid evolution of financial systems and digital technologies has significantly expanded both the scope and complexity of white-collar crimes, underscoring the need for comprehensive legal reforms.

According to statistical data from the Portuguese Ministry of Justice, there was an increase in economic and financial crimes reported in 2023, particularly concerning money laundering offences. Furthermore, the 2022 Annual Internal Security Report highlighted a frequent suspension of suspicious transactions involving politically exposed persons from Portuguese-speaking countries or with connections to them, indicating the utilisation of national financial, corporate, and banking systems for fund movements.

Data released by the Public Prosecutor’s Office further indicates a rise in the number of investigations into economic and financial crimes, with 3,598 new inquiries related to corruption and related offences initiated in 2023. This marks a significant increase from the 2,865 inquiries initiated in 2021. The Public Prosecutor’s Office also reported that 535 banking operations were suspended, leading to the initiation of 535 inquiries.

While official 2025 figures are still pending, early indications suggest that these trends are holding steady or intensifying.

Recent years have witnessed a series of institutional, legislative, and operational reforms aimed at reinforcing the country's capacity to detect, investigate, and prosecute complex financial and economic crimes. These measures have been spurred by growing public awareness, heightened international scrutiny, and the government’s commitment to aligning national standards with those of the European Union and global anti-corruption bodies.

Strengthened Institutions and Anti-Corruption Enforcement in Portugal

In recent years, Portugal has taken decisive steps to modernise its anti-corruption framework. A key milestone in this process was the introduction of the General Regime for the Prevention of Corruption (Regime Geral de Prevenção da Corrupção – RGPC), which came into force at the end of 2024. This law applies to both public bodies and private companies employing 50 or more workers.

Under the RGPC, such organisations must put in place comprehensive compliance programmes:

  • Risk Prevention Plan – a documented, annually reviewed plan that identifies corruption and related risks (such as conflicts of interest, fraud, influence peddling) and sets out mitigation measures.
  • Code of Conduct – a formal set of ethical rules and behavioural standards, applicable to management and staff, approved at the highest level of the organisation.
  • Training Programmes – periodic training for employees and management to ensure awareness of corruption risks and compliance duties.
  • Whistle-Blowing Channels – confidential and secure reporting mechanisms that comply with the EU whistle-blower Directive (transposed into Portuguese law in 2021).
  • Compliance Officer (Responsável pelo Cumprimento Normativo) – an individual appointed to oversee the implementation and monitoring of the compliance programme.

While the RGPC sets the rules organisations must follow, Mecanismo Nacional Anticorrupção (MENAC) acts as the oversight and enforcement authority. Together, they represent a shift from reactive enforcement (catching corruption after it occurs) to proactive prevention, with a focus on governance structures, transparency, and whistle-blower protection.

A particularly important feature is the obligatory registration on the RGPC online platform, managed by MENAC. Entities must provide key organisational data, details of their compliance officer, and upload certain governance documents.

The final deadline for registration was 14 February 2025. Late registration can result in administrative fines, even if the entity is otherwise compliant internally.

Failure to implement an adequate compliance programme, to register, or to cooperate with MENAC inspections can lead to administrative offences punishable by substantial fines. In severe or repeated cases, MENAC can refer the matter to prosecutorial authorities if there is evidence of criminal conduct.

MENAC – Portugal’s National Anti-Corruption Agency

As noted earlier, MENAC is responsible for overseeing the implementation of the RGPC and making sure that both public and private organisations comply with its rules. While the police and the Public Prosecutor’s Office handle the investigation and prosecution of crimes, MENAC focuses on prevention and compliance oversight.

MENAC’s work covers three main areas:

  • Prevention – the agency ensures that organisations have robust rules, processes, and internal controls to minimise the risk of corruption before it occurs.
  • Enforcement – MENAC investigates failures to meet RGPC obligations and can impose administrative penalties when necessary.
  • Compliance monitoring – it regularly reviews the internal preventive systems of organisations, identifies weaknesses, and offers recommendations for improvement.

A key aspect of MENAC’s mandate is its secure whistle-blower channel, which allows employees, contractors, and other stakeholders to report suspected corruption or irregularities safely and without fear of retaliation.

Although MENAC was formally established some time ago, 2025 marks the year when it became fully operational. It now has a defined organisational structure, clear oversight and investigative powers, and greater independence. Its operational model includes direct coordination with prosecutorial authorities and financial regulators, which enables faster information sharing and reduces delays in urgent cases.

In 2025, MENAC was also integrated into a broader national anti-corruption strategy, moving away from the previously fragmented approach to enforcement. This centralisation aims to provide a single point of contact for compliance matters, detect systemic vulnerabilities across sectors, and promote ethical standards through guidance, training, and practical support for organisations.

The Anti-Corruption Agenda

In early 2025, the Portuguese government unveiled a structured and long-term anti-corruption strategy covering the period from 2025–30. This plan reflects both domestic political priorities and commitments undertaken at the European and international level, including obligations under EU anti-corruption frameworks and recommendations from bodies such as the Council of Europe’s Group of States against Corruption (GRECO) and the OECD.

The 2025–30 programme builds upon legislative reforms implemented in the previous years, most notably the RGPC and the operationalisation of National MENAC. These are now considered the backbone of the national compliance and prevention framework.

The government’s vision is that, by 2030, Portugal will have an anti-corruption ecosystem where prevention and enforcement are integrated, public trust is reinforced, and the cost of engaging in corrupt practices – whether legal, reputational, or operational – is significantly increased. The plan emphasises not only the repression of offences already committed but also the creation of a culture of integrity within both the public and private sectors.

Law No 26/2025 of 19 March

Law No 26/2025, of 19 March, introduced targeted yet substantial amendments to both the Portuguese Criminal Code and the Code of Criminal Procedure, reflecting a concerted legislative effort to enhance the protection of public servants and other professionals whose work places them at heightened risk of aggression. The law represents a clear policy shift toward recognising the societal value and vulnerability of certain professions and ensuring that offences committed against these individuals are met with both stricter sanctions and more efficient procedural handling.

Regarding the Criminal Code:

  • Article 132 (Qualified Homicide) – the scope of qualified homicide was broadened to include a wider set of protected victims. In addition to the categories previously recognised, the law now explicitly protects magistrates, police officers, firefighters, educators, healthcare professionals, and journalists whenever a homicide is linked to the performance of their professional duties. This expansion ensures that offences against individuals performing critical societal functions are treated with the utmost seriousness. By connecting the legal protection to the victim’s professional role, the law reflects the heightened vulnerability and social importance of these individuals, while also providing a stronger deterrent against attacks that threaten public service and societal welfare.
  • Article 143 (Simple Assault) – the provisions governing simple assault were significantly strengthened. When assaults target the newly defined protected professional categories, the applicable prison term was increased to one to four years. Moreover, offences of this nature are now prosecuted ex officio, meaning that the public prosecutor can pursue the case independently of a formal complaint by the victim. This change underscores the public interest in protecting individuals who serve in essential roles and ensures that assaults against them cannot be disregarded due to procedural technicalities or the absence of a complaint.
  • Article 145 (Qualified Assault) – similarly, the rules for qualified assault were revised to impose more severe penalties in cases involving protected professionals. Aggravated assaults now carry a prison term ranging from one to five years. This amendment reflects the recognition that assaults on public servants and other critical professionals have a higher social and legal impact, given the potential consequences for public safety, justice, and societal stability. By differentiating the penalties for ordinary assaults from those directed at protected victims, the law reinforces the moral and legal significance of safeguarding these roles.
  • Article 293 (Projectile Attacks on Vehicles) – projectile attacks targeting vehicles were also addressed. Under the new framework, vehicles operated by police officers, firefighters, and civil protection services fall within the scope of enhanced legal protection. Individuals committing attacks on these vehicles may face imprisonment of up to two years or a fine of up to 240 days. This amendment recognises the specific risks associated with assaults on vehicles used in the performance of critical public functions. Such attacks can have immediate physical consequences for the occupants and broader implications for public order and emergency response effectiveness, warranting the application of stricter penalties.
  • Article 347 (Resistance or Coercion Against Public Authorities) – resistance or coercion against public authorities saw an expansion both in sentencing and scope. The applicable prison range was increased to one to eight years when violence or resistance is directed at a protected public servant. The law also explicitly covers attacks carried out via vehicles or objects used in the commission of the offence, ensuring that the legal framework addresses emerging and unconventional forms of aggression. By doing so, the law strengthens the State’s capacity to protect public agents and maintain the integrity of its institutions in situations where authority is directly challenged.

Beyond substantive criminal law, Law 26/2025 also enacted procedural reforms aimed at improving access to justice for victims. The amendments to procedural cost rules ensure that individuals belonging to the protected professional categories are exempt from paying court fees when criminal proceedings arise from harm suffered in the course of their professional duties. This removes financial barriers that could discourage victims from seeking legal redress, while reinforcing the principle that the State has a responsibility to protect those whose roles are vital to societal functioning. By alleviating procedural burdens, the law facilitates swifter and more effective enforcement of criminal provisions.

Taken together, the reforms introduced by Law 26/2025 signal a broader legislative strategy aimed at deterring violence against public servants, reinforcing procedural safeguards for victims, and ensuring more assertive enforcement when the authority of the State or the public interest is directly challenged. These changes reflect an acknowledgement of the increasing complexity and intensity of threats faced by public service professionals and demonstrate the necessity of aligning criminal sanctions and procedural mechanisms to provide adequate protection.

Conclusion

Portugal’s legal and institutional framework in 2025 reflects a strong commitment to reinforcing integrity, accountability, and the protection of public service roles. The full operationalisation of MENAC, together with the enforcement of the RGPC, represents a major step forward in creating a coordinated and preventive approach to corruption. The RGPC requires public and private organisations with 50 or more employees to implement comprehensive compliance measures, including risk prevention plans, codes of conduct, training programmes, whistle-blowing channels, and the appointment of compliance officers. MENAC oversees compliance with these obligations, audits organisational procedures, and provides guidance to ensure that preventive measures are applied effectively.

At the same time, Law No 26/2025, of 19 March addresses a separate but complementary area of reform. While it is not directly related to anti-corruption, the law strengthens legal protections for public servants and other professionals performing essential public duties. By increasing penalties for offences such as qualified homicide, assault, resistance, and attacks on official vehicles, and by simplifying access to judicial proceedings through procedural cost exemptions, the law reinforces the safety and procedural rights of those who serve the public. Protecting individuals in public service indirectly supports the broader culture of professionalism and ethical conduct within public institutions.

The 2025–30 Anti-Corruption Strategy builds on these developments to promote a wider culture of transparency and accountability. Its emphasis on prevention, compliance monitoring, and public awareness aims to integrate integrity into both public administration and the private sector. By combining institutional capacity-building with the legal safeguards provided by Law 26/2025, Portugal is fostering an environment where misconduct can be identified early, investigated efficiently, and systematically discouraged.

Together, the RGPC, MENAC, and Law No 26/2025 demonstrate a dual approach: preventive measures and compliance oversight target corruption directly, while legal protections for public servants strengthen the resilience of the institutions themselves. If fully implemented, this framework is expected to enhance public trust, support institutional integrity, and promote a more transparent and accountable society. While challenges remain, Portugal’s progress shows a clear determination to improve governance, safeguard public resources, and create a sustainable environment for ethical conduct. Nevertheless, ongoing efforts in training, funding, and cooperation with European partners will be essential to ensure these reforms translate into measurable reductions in corruption and financial crime.

Rogério Alves e Associados

Av. Álvares Cabral
No 61
4 Andar
1250-017
Lisbon
Portugal

+351 21 391 10 40

+351 21 391 10 41

geral@raassociados.pt www.raassociados.pt
Author Business Card

Trends and Developments

Authors



Rogério Alves & Associados is a full-service law firm with national and international reach, established in 2013 in Lisbon. The firm has significant experience in criminal law and the lawyers that work in this team cover most types of criminal law proceedings. They represent clients in economic and financial crimes (white-collar crimes), crimes against honour and against property, as well as in the context of regulatory offences litigation, the scope, importance and intensity of which continue to grow. The connection between the lawyer and the court is historical and traditional, and Rogério Alves & Associados does justice to this tradition.

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