Circular Letter No. CC/2025/00000008: Disclosure of FATF Communications (February 2025 Plenary Meeting)

Circular Letter No. CC/2025/00000008 Sent to: Credit Institutions, Financial Companies, Payment Institutions, Electronic Money Institutions, and Entities carrying out activities with virtual assets. Mod. 99999924/T – 01/14 Subject: Disclosure of FATF communications (February 2025 plenary meeting)

I. COMMUNICATIONS ISSUED BY THE FATF With the aim of protecting the international financial system from the risks associated with money laundering and terrorist financing, as well as fostering adequate compliance with AML/CFT standards, the FINANCIAL ACTION TASK FORCE (FATF) acts to identify jurisdictions presenting strategic deficiencies in money laundering and terrorist financing prevention and to develop coordinated and decisive responses worldwide to combat these realities.

Following the plenary meeting held between February 19 and 21, 2025, the FATF published the following documents: • HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION, dated February 21, 2025, which identifies jurisdictions subject to countermeasures and jurisdictions with strategic deficiencies in money laundering and terrorist financing prevention that have not made sufficient progress in overcoming these deficiencies and/or have not agreed with the FATF on an action plan for this purpose. The full content of this document can be consulted at: High-Risk Jurisdictions subject to a Call for Action - 21 February 2025. • JURISDICTIONS UNDER INCREASED MONITORING, dated February 21, 2025, which identifies jurisdictions with strategic deficiencies in money laundering and terrorist financing prevention that have developed an action plan to overcome them and are subject to a monitoring process by the FATF. The full content of this document can be consulted at: Jurisdictions under Increased Monitoring - 21 February 2025.

Regarding these documents, the following should be noted: • Regarding the list of High-Risk Jurisdictions Subject to a Call for Action: • The FATF reiterates its call for the application of countermeasures against the Democratic People's Republic of Korea (North Korea) and the Islamic Republic of Iran, emphasizing an increased risk of proliferation financing (“Given heightened proliferation financing risks, the FATF reiterates its call to apply countermeasures on these high-risk jurisdictions.”). • The Republic of the Union of Myanmar remains in the category of jurisdictions subject to the application of enhanced identification and due diligence measures proportional to the risks resulting from them, with the FATF reiterating that if no progress is made by June 2025, countermeasures will be considered. • Regarding the list of Jurisdictions Under Increased Monitoring: • Since October 2024, the FATF has assessed the progress of 16 jurisdictions, and their respective statements have been updated;

Mod. 99999924/T – 01/14 • With regard to the People's Democratic Republic of Algeria, the Republic of Angola, the Republic of Côte d'Ivoire, the Republic of Haiti, the Lebanese Republic, the Principality of Monaco, the Syrian Arab Republic, and the Republic of Yemen, the previous FATF statements were included in this document, but they may not reflect the current state of their respective money laundering and terrorist financing prevention regimes; • Two new jurisdictions have been identified and included: the Lao People's Democratic Republic and Nepal; • It is worth noting the exit of one jurisdiction: the Republic of the Philippines.

In addition, it is important to note the continued maintenance of the suspension of the membership status of the Russian Federation.

I. COMPARATIVE FRAMEWORK WITH COMMUNICATIONS ISSUED BY THE FATF IN OCTOBER 2024

HIGH-RISK JURISDICTIONS SUBJECT TO A CALL FOR ACTION | JURISDICTIONS UNDER INCREASED MONITORING JURISDICTIONS SUBJECT TO THE APPLICATION OF COUNTERMEASURES | JURISDICTIONS SUBJECT TO THE APPLICATION OF ENHANCED MEASURES | JURISDICTIONS SUBJECT TO A MONITORING PROCESS | JURISDICTIONS THAT EXITED THE MONITORING PROCESS

PLENARY MEETING 19-21 FEBRUARY 2025 Democratic People's Republic of Korea (North Korea) Islamic Republic of Iran; Republic of the Union of Myanmar People's Democratic Republic of Algeria, Republic of Angola, Burkina Faso, Republic of Bulgaria, Republic of Cameroon, Republic of Côte d'Ivoire, Republic of Croatia, Republic of the Democratic Republic of the Congo, Republic of Haiti, Lao People's Democratic Republic, Lebanese Republic, Republic of Mali, Principality of Monaco, Republic of Mozambique, Republic of Namibia, Nepal, Federal Republic of Nigeria, Republic of Kenya, Republic of South Africa, Republic of South Sudan, Syrian Arab Republic, United Republic of Tanzania, Republic of Vietnam, Republic of Yemen, and Bolivarian Republic of Venezuela; Republic of the Philippines

PLENARY MEETING 23-25 OCTOBER 2024 Democratic People's Republic of Korea (North Korea) Islamic Republic of Iran; Republic of the Union of Myanmar People's Democratic Republic of Algeria, Republic of Angola, Burkina Faso, Republic of Bulgaria, Republic of Cameroon, Republic of Côte d'Ivoire, Republic of Croatia, Republic of the Democratic Republic of the Congo, Republic of Haiti, Lebanese Republic, Republic of Mali, Principality of Monaco, Republic of Mozambique, Republic of Namibia, Federal Republic of Nigeria, Republic of the Philippines, Republic of Kenya, Republic of South Africa, Republic of South Sudan, Syrian Arab Republic, United Republic of Tanzania, Republic of Vietnam, Republic of Yemen, and Bolivarian Republic of Venezuela; Republic of Senegal

II. PROCEDURES AND MEASURES TO BE ADOPTED BY INSTITUTIONS Considering the content of the documents produced by the FATF and within the framework of the duty to disseminate information to which supervisory authorities are bound (Article 120 of Law No. 83/2017, of August 18 - “Law No. 83/2017”), the Bank of Portugal informs the following, regarding business relationships, occasional transactions, and operations carried out with persons, entities, and collective interest centers without legal personality1 residing or established in the jurisdictions identified below:

a. Considering the existence of a very high risk of money laundering, terrorist financing, and proliferation of weapons of mass destruction, it is determined, under the terms and for the purposes of paragraph 1(b) of Article 99 of Law No. 83/2017, the maintenance of countermeasures, proportional to those risks, with respect to the DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA (NORTH KOREA) and the ISLAMIC REPUBLIC OF IRAN, which must in any case include the countermeasures identified in the High-Risk Jurisdictions Subject to a Call For Action and in paragraphs (f) to (h) and (k) of paragraph 3 of Article 99 of the aforementioned Law No. 83/2017.

b. Enhanced identification and due diligence measures shall continue to be adopted, under paragraph 2 of Article 36 and paragraph 3(b) of Article 37 of the aforementioned Law No. 83/2017, and examined with special care, all business relationships, occasional transactions, and operations involving the DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA (NORTH KOREA) or the ISLAMIC REPUBLIC OF IRAN – necessarily including the measures specified in the High-Risk Jurisdictions Subject to a Call For Action –, as well as the REPUBLIC OF THE UNION OF MYANMAR.

c. Regarding business relationships, occasional transactions, and operations involving jurisdictions subject to a monitoring process, or other third countries of high risk that are part of Delegated Regulation (EU) 2016/1675 of the Commission, of July 14, 2016, in its currently valid version, enhanced measures that prove proportional to the risk concretely identified must be adopted, without prejudice to the above, under paragraph 2 of Article 36, paragraph 1, and paragraph 3(b) of Article 37, all of the aforementioned Law No. 83/2017.

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Supplementary information on the conclusions of the FATF plenary meeting can be obtained on the website www.fatf-gafi.org.

1 Including their respective representatives and beneficial owners.