Money Laundering and Terrorist Financing: The New Rules Introduced by CMVM Regulation No. 5/2025

These entities, which were already subject to the Law on the Prevention of Money Laundering and Terrorist Financing (LMLTF), are now required to submit annual information by March 31 of each year, referring to the period between January 1 and December 31 of the previous year. On a transitional basis, however, the first submission of information under this new regime, relating to the 2025 financial year, may be made until June 30, 2026.

The annual information report must cover:

• Active and new contractual relationships for the provision of equity or lending-based crowdfunding activities, distinguishing between promoters and investors;

• The number of relationships, transactions, and amounts that gave rise to the obligation to report suspicious transactions and other information, in accordance with Articles 43 and 144 of the LMLTF;

• The structure and size of the activity (turnover, branches, subsidiaries, and any links to high-risk jurisdictions);

• The communication of money laundering and terrorist financing risks identified by the entity, with reference to the sources of information used.

It should be noted that Regulation No. 5/2025 introduces new fields and detailed elements, strengthening the collection of information on risk classification and review systems, monitoring automation, and processes for assigning risk profiles to clients and counterparties.

The regulation also introduces a relevant technical change: the transition from the “.DAT” format to the “.XML” format for the electronic submission of reporting files, while also establishing a new file nomenclature and structure. This change aims to optimize the collection and processing of information, enhancing the compatibility and reliability of the data transmitted to the CMVM.

Finally, it should be recalled that the failure to provide, or the incomplete provision of, the information required by sectoral authorities within the established deadlines constitutes a particularly serious administrative offence. Timely and accurate compliance with these new reporting obligations is therefore of particular importance.

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