Combating commercial concealment: Decree-Law No. 78 of 2026

Workshop outline

1. 1Definitions and key termsKey definitions · The legal concept of commercial concealment · The elements of commercial concealmentSlide 5
2. 2The legislation and the objectives of the Decree-LawThe legislative context: why this Decree-Law now? · The Decree-Law, its basis and practical scope, and the “hidden beneficial owner” test · The main objectives of the Decree-LawSlide 10
3. 3Timeline and the statutory grace period for regularisationTimeline for applying Decree-Law No. 78 of 2026Slide 15
4. 4Prohibitions and responsibilitiesThe basic prohibition: Article 2 of the Decree-Law · Persons prohibited from carrying on the activity · Means of commercial concealment prohibited in practice · Scope of criminal liability and the roles of the partiesSlide 17
5. 5Criminal and administrative penaltiesCriminal and administrative penalties · Administrative violations and the doubling of penalties · Table of offences and criminal and administrative penaltiesSlide 23
6. 6Risks to companies and warning signsRisks to companies · The main red flags for internal audit · Prohibited activitiesSlide 30
7. 7Settlement and whistleblower rewardsSettlement mechanisms and whistleblowing rewards · The settlement regime (Article 8) · Whistleblower reward (Article 9)Slide 34
8. 8Oversight and judicial enforcement powersExpanded powers for MOCI inspectors · The establishment’s duties and the competent Ministry staff · What must employees not do?Slide 38
9. 9Effect of the Decree-Law on companies, and the financial and accounting indicators of concealmentEffect of the Decree-Law on companies: where is the company affected? · Financial and accounting indicators of concealment · Risk indicators: governance and ownership, accounting, banks and cash flows, operations and employeesSlide 42
10. 10Compliance roadmap and the role of audit firmsRoles within the compliance framework · Compliance roadmap, practical steps and timeline · Alternative legal routes to immediate correction · The audit firm’s protocol for protecting companies and clientsSlide 49
11. 11Questions, discussion and interactive casesPractical cases, examples and a test of legal characterisation · Interactive quizzes · A client checklist and messages for management · Summary and recommendationsSlide 57

This material is general educational content prepared for training. It is not professional advice and is no substitute for it. Rules and instructions may change after the date shown, so please refer to the official texts or contact the firm before taking any decision.

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