Retaining counterfeits

Recirculation

Intelligent Banknote Neutralisation Systems

Cash offices

Retaining counterfeits

Credit institutions, exchange offices and payment institutions

Cashiers at credit institutions, exchange offices and payment institutions have the obligation to detect and retain counterfeit or suspect banknotes and coins, whether they are expressed in euros or not.
This obligation applies to banknotes and coins presented over the counter in person and banknotes and coins submitted via customer-operated machines.
If the retained banknote or coin was presented over the counter at a credit institution, exchange office or payment institution information must be collected based on the data model provided in BPnet and in accordance with Instruction of the Banco de Portugal No 19/2021, which allows for:
 1. The identification of the person presenting/depositing the banknote or coin (including, name and address, ID registration, contact number and account number/IBAN);
 2. The recorded information for further police investigation (including the date, place and circumstances where the person presenting/depositing obtained the counterfeit banknote or coin – how, where and when).
If customer-operated machines retain a banknote, they must issue a receipt complying with the information laid down in Instruction of the Banco de Portugal No 19/2021. The receipt must indicate the number of retained banknotes by denomination and explicitly state that:
 1. retained banknotes are suspected not to be genuine;
 2. The retained objects shall be sent to the competent authority for analysis; within a maximum of ten business days from the date of the operation;
 3. The customer must be notified as soon as possible of the decision to send the object to the competent authority, observing the maximum period of ten business days referred to in the previous paragraph;
 4. The result of the authenticity analysis  shall be provided to the account holder and the effective credit will depend on it.
If banknotes or coins are retained, the Police (Polícia Judiciária) must be informed as soon as possible, at the most within ten business days following retention, by sending the objects that were retained and the information collected as specified above.
In the case of euro banknotes or coins, and if, exceptionally, it is not possible to identify the person presenting them, the procedure is identical, but they must be sent to the Banco de Portugal.

Cash-in-transit companies

Professional cash handlers, specifically cash-in-transit companies, have the obligation to retain counterfeit or suspect banknotes and coins in euro or in a foreign currency.
Banknotes and coins retained by cash-in-transit companies must be sent to the Banco de Portugal, together with the information collected based on the data model provided in BPnet and in accordance with Instruction of the Banco de Portugal No 19/2021, duly filled out, within ten business days of the retention of the banknotes or coins.
Where there is a link between the retained objects and a natural person presenting/depositing them, the banknotes and coins must be handed over to the Police within the same time period.

Other entities

If you are a merchant/retailer, see also Banco de Portugal’s recommendations on how to act if you come across a suspect banknote or coin.

Recirculation

The Banco de Portugal is responsible for supervising the recirculation of euro banknotes and coins.
Professional cash handlers must only recirculate banknotes and coins that have been checked and found to be genuine and fit.
In Portugal, recirculation is regulated by Decree-Laws No 195/2007 of 15 May 2007 and No 184/2007 of 10 May 2007.

Entities required to recirculate euro banknotes and coins

Entities which are professionally responsible for handling euro banknotes and coins and delivering them to the public – credit institutions, cash-in-transit companies, exchange offices and payment institutions – are required to check whether they are genuine and fit.

Rules on banknote recirculation 

1. Banknotes may only be returned to circulation via automated teller machines (ATMs) or other customer-operated machines if they have been checked for both authenticity and fitness by banknote handling machines recognised by any Eurosystem central bank and are included in the list published on the European Central Bank’s website.
 2. Banknotes which have been checked for authenticity by trained staff members, either manually or without the use of banknote handling machines recognised by a Eurosystem central bank, must not be returned to circulation via ATMs or other customer-operated devices, but can only be distributed over the counter after being checked for fitness.
 3. Professional cash handlers must comply with the provisions laid down in Instruction of the Banco de Portugal No 19/2021, namely the obligation to retain banknotes that are clearly counterfeit, or have sufficient reasons to be considered counterfeit, and present them, within ten business days after the retention, as follows:
  • If euro banknote, and the person presenting it is identified, to the Police (Polícia Judiciária);
  • If euro banknote and in the exceptional situations where it is not possible to identify the person presenting them, or there is no connection between the object and the holder, to the Banco de Portugal;
  • If foreign banknotes, to the Police (Polícia Judiciária).
 4. Euro banknotes that do not meet minimum fitness requirements to remain in circulation or that have not been duly checked may not be released to the public and must be handed over to the Banco de Portugal.
 5. Professional cash handlers may recirculate banknotes directly provided by Eurosystem central banks either through ATMs or over the counter.
 6. Credit institutions with remote branches and a very low level of cash operations may supply ATMs and other customer-operated machines with banknotes which have been checked only manually for fitness. In these cases, the authenticity check is carried out by a successfully tested banknote authentication machine. This exception only applies to up to 5% of the volume of banknotes that are provided through ATMs and other customer-operated machines in Portugal. Credit institutions intending to operate under this scheme must communicate their intention to the Banco de Portugal in advance.

Banknote handling machines 

Euro banknotes may be recirculated through banknote handling machines recognised by any Eurosystem central bank.
These machines must be able to identify and separate counterfeit euro banknotes from genuine ones and banknotes that do not meet Eurosystem fitness standards from banknotes fit for circulation, in a reliable way. They must also be adaptable to new authenticity and fitness standards for euro banknotes and ensure the detection of new types of counterfeits.
Only manufacturers may request that Eurosystem central banks perform tests on their machines. In the case of the Banco de Portugal, this request should be addressed to recirculacao@bportugal.pt.

Rules on coin recirculation 

1. Euro coins may only return to circulation if they have been checked for authenticity and fitness by coin-processing machines or qualified professionals with training in euro coin authenticity and fitness that is recognised by the Banco de Portugal.
 2. Professional cash handlers must comply with the provisions laid down in Instruction of the Banco de Portugal No 19/2021, namely the obligation to retain coins that are clearly counterfeit, or have sufficient reasons to be considered counterfeit, and present them, within ten business days after the retention, as follows:
  • If euro coins, and the person presenting it is identified, to the Police (Polícia Judiciária);
  • If euro coins and in the exceptional situations where it is not possible to identify the person presenting them, or there is no connection between the object and the holder, to the Banco de Portugal;
  • If foreign coins, to the Police (Polícia Judiciária).
 3. Euro coins unfit for circulation, either because they are defective or because their technical properties and identification features have been altered by accident, may not be released to the public and must be submitted to the Banco de Portugal, in accordance with the rules laid down in Instruction of the Banco de Portugal No 18/2021.
 4. Professional cash handlers may distribute over the counter euro coins directly provided by Eurosystem central banks.

Coin-processing machines

Euro coins may be recirculated through coin-processing machines that have been successfully tested by the European Technical and Scientific Centre, national coin analysis centres or a Eurosystem central bank.
These machines must be able to process all euro coin denominations and detect/reject euro coin-like objects, in particular counterfeit coins and medals. They must also be adaptable to new standards on the authenticity and features of euro coins and be able to detect new types of counterfeits and implement new criteria for checking euro coins.

Professional trainings

The Banco de Portugal promotes training for professionals involved in cash recirculation activities.
Entities recirculating euro banknotes and coins should promote training among cash professionals, ensuring that they are qualified to manually check euro banknotes and coins received from the public for authenticity and fitness before these are recirculated.
Training on euro banknotes and coins for professionals working at cash-in-transit companies must always be delivered face to face. 
Face-to-face courses are conducted at the Banco de Portugal’s training centres – Braga, Carregado, Castelo Branco, Coimbra, Évora, Faro, Funchal, Lisbon, Ponta Delgada, Porto and Viseu – and through e-learning.
Face-to-face training courses have a duration of two hours, either for banknotes or for coins, and include a theoretical presentation and a practical session on the analysis of counterfeit and genuine banknotes/coins. Courses are limited to 14 trainees.
E-learning training may be attended free of charge through the entity’s e-learning platform or the BANCA platform of Instituto de Formação Bancária (Portuguese Banking Training Institute).
The e-learning course also has a duration of two hours. In order to successfully complete it, cash professionals must pass the questionnaires at the end of each of the course’s modules. Approval requires at least 80% in each questionnaire.
Trainees attending the face-to-face course or passing the e-learning course receive a certificate issued by the Banco de Portugal and may exercise cash recirculation activities for a period of three years (banknotes, coins or both).
For more information, contact the National Counterfeit Centre: cncontrafaccoes@bportugal.pt.

Reporting to Banco de Portugal

Entities entering into a contract with the Banco de Portugal to recirculate euro banknotes and coins are required to report on developments in this activity.
Information to be reported is set out in Instruction of the Banco de Portugal No 9/2014 (euro banknotes) and Instruction of the Banco de Portugal No 5/2012, amended by Instruction No 31/2013 (euro coins).
Reporting to the Banco de Portugal should take place exclusively through the dedicated application in BPnet, the Banco de Portugal’s website for operational communication with the financial community (SIN – Sistema Integrado de Numerário > RAR-Nota > Aplicação RAR-Nota).
Deadlines and frequency of reporting on recirculation activities are as follows: