Through Circular UIF-SEPRELAD/SE No. 01/25 dated January 16, 2025, the Secretariat for the Prevention of Money or Asset Laundering (“SEPRELAD”) reminded reporting parties of the provisions set forth in Articles 20 and 32 of Law No. 1015/97 “Preventing and repressing illicit acts aimed at legitimizing money or goods” (the “Law”).

Article 20 of the Law establishes the duty of confidentiality, which prohibits reporting parties from disclosing to clients or third parties any actions or communications carried out in compliance with the obligations set forth in the Law and its regulations.

Meanwhile, Article 31 of the Law regulates the duty of professional secrecy, imposing on all individuals who perform activities for SEPRELAD, as well as those who receive confidential information or become aware of its actions or data of a similar nature, the obligation to preserve professional secrecy. Failure to comply with this provision will result in the sanctions provided by the Law.  

Additionally, the Circular emphasizes that reporting parties must handle with strict confidentiality both Suspicious Transaction Reports (ROS) submitted to SEPRELAD and any Requests for Complementary Transactional Information (ITC) that SEPRELAD may require. Both are classified as confidential and must be managed under a strict confidentiality process.