AML Framework Development

Lagom Sports Compliance AML Framework Development support.

A complete AML framework built for how football actually operates.

From policy suite and governance to KYC workflows, agent onboarding playbooks, sanctions screening and training, our AML frameworks are designed for professional football, defensible to everyone who will scrutinise it.

What's Included

  • Policy and Governance

    • AML policy framework and risk appetite statement

    • Sanctions framework and escalation procedures

    • Counterparty risk model and tiering methodology

    • Governance structure and board reporting framework

    • Recordkeeping standards

  • Counterparty Onboarding and Due Diligence

    • KYC/KYB workflows for owners, investors, directors and agents

    • UBO identification and verification including offshore structures

    • Source-of-wealth and source-of-funds processes

    • Agent and sponsor onboarding playbooks

    • Transfer counterparty onboarding controls and risk-rating

  • Technology, Screening and Training

    • Sanctions and PEP screening configuration (technology delivered separately via partner technology)

    • Adverse media screening protocols and ongoing monitoring triggers

    • Board-level, finance team and transfer team training delivery

Book a call to discuss the development of your AML Framework

If you're interested in our AML Framework Development support, please complete the form with a few details about your project. We'll review your message and get back to you within 48 hours.

Questions about the AML Framework Development support

  • A complete AML framework implementation for a professional football club, such as the Lagom Sports Compliance AML Framework Development engagement, includes seven interconnected components.

    First, a policy and governance layer: AML policy, risk appetite statement, sanctions framework, counterparty risk model, escalation and reporting framework, governance structure and recordkeeping standards. Second, counterparty onboarding processes: KYC and KYB workflows for every counterparty category, ultimate beneficial ownership identification processes, source-of-wealth and source-of-funds procedures, and risk-rating methodology.

    Third, football-specific onboarding playbooks: agent onboarding, sponsor onboarding and transfer counterparty controls, each designed for the actual documents and information flows in a professional football environment. Fourth, transfer governance controls: transfer process mapping, payment approval controls, agent commission review processes, third-party payment assessment and transfer red-flag frameworks.

    Fifth, technology and screening configuration: sanctions and PEP screening deployed via partner technology, adverse media screening protocols and ongoing monitoring triggers. Sixth, staff training: board-level AML awareness, finance team operational training, transfer team and recruitment training, and agent sanctions awareness. Seventh, full documentation of every component in a format ready for board adoption and regulatory review.

  • Lagom Sports Compliance AML Framework Development support differs from a generic compliance implementation in three fundamental ways.

    First, every artefact, including every policy, workflow, playbook and control, references football's actual financial structure: transfer fees with contingent payments, image-rights vehicles, multi-party agent commission arrangements, offshore ownership structures, UEFA licensing requirements and the Transfer Matching System. Nothing is transplanted from a banking or legal sector template.

    Second, the proportionality principle is applied throughout. The framework is calibrated to the specific risk profile of the client club or agency, not built at maximum intensity regardless of size or complexity.

    Third, the output is designed to be operational in a football environment. It reflects how transfers, agent relationships and ownership structures actually work, rather than how a banking compliance framework imagines they might work. Generic implementations frequently produce documentation that is technically correct but operationally rejected by football staff because it does not map to their actual processes.

  • The AML Framework Development engagement builds and delivers the complete AML framework, including initial screening configuration and staff training, but does not include ongoing counterparty monitoring, transfer-window oversight or annual independent review after the initial delivery.

    Those services are available through the Lagom Sports Compliance Outsourcing and Resourcing retainer, which operates the framework on an ongoing basis, or through individual modular services. Many clients choose to maintain the AML framework in-house after delivery and commission specific modular services, such as transfer transaction oversight during a window or an annual independent review, as needed.

    The AML Framework is specifically designed to be maintainable in-house. The policies, workflows and processes are documented in operational language that club staff can work with without specialist support for routine matters.

  • An AML Framework Development engagement typically takes two to six months from scoping to full delivery.

    The process has five phases. Phase one is scoping and risk profiling, where we conduct an initial assessment of the club's ownership structure, transfer activity, agent relationships and governance to determine the appropriate scope. This takes two to three weeks. Phase two is policy and governance build, where we draft the AML policy framework, risk appetite statement, sanctions framework, counterparty risk model and governance documentation, iterating with the client to ensure these reflect the club's actual operating environment. This takes four to six weeks.

    Phase three is process and playbook development, where we build the KYC workflows, UBO processes, agent and sponsor onboarding playbooks, transfer governance controls and transfer red-flag framework, taking four to six weeks. Phase four is technology configuration and training, covering the screening platform setup, staff training across all relevant functions, and completion of the training register, taking two to four weeks.

    Phase five is final documentation review and formal adoption, where we support the board adoption process and deliver the complete documented framework. This takes one to two weeks.

  • Yes. The Lagom Sports Compliance AML framework is designed with correspondent banking due diligence explicitly in mind. The policy suite, governance documentation and onboarding procedures are written in a register that a bank's AML function will recognise, assess and accept.

    The documentation package directly answers the questions that banks most commonly ask of football clients: what is your AML policy? Who is your MLRO? How do you screen counterparties? How do you handle transfer transactions? What training have your staff received?

    Clubs that have completed a Foundation engagement are materially better positioned in banking reviews because they can produce documented, professionally structured responses to these questions rather than ad hoc explanations. We also have direct experience supporting clients through banking reviews following a Foundation implementation and can advise on presenting the framework to banking counterparties most effectively.

  • Yes. The Lagom Sports Compliance AML framework is available to football agencies and is adapted to reflect an agency's specific risk profile and operating model.

    The differences are material. An agency's primary counterparty relationships are with players, clubs and sub-agents rather than owners and investors. The primary transaction risk is commission flows and image-rights structures rather than transfer payments. The client due diligence processes must address the specific requirements around representing minors, cross-border client relationships and image-rights vehicles.

    The policy framework, KYC workflows, onboarding playbooks and training are all adapted accordingly. The UEFA licensing and ownership integrity components relevant to clubs are replaced with agent-specific content covering FIFA registration, RSTP commission obligations and the banking-readiness documentation that agencies increasingly need to maintain their correspondent bank relationships.

  • After the AML framework is delivered, clients can access three tiers of ongoing support.

    The first is modular services commissioned as needed, including annual independent review, transfer transaction oversight, specific counterparty due diligence exercises, additional training sessions and regulatory or banking support.

    The second is the Lagom Sports Compliance Outsourcing and Resourcing support , which operates the complete AML function on an ongoing basis: counterparty screening, transfer-window oversight, MLRO support, board reporting and annual independent review.

    The third is ad hoc advisory for specific situations, including ownership change due diligence, sanctions events, banking reviews and regulatory queries. Most clients begin with the AML framework and access modular services or ad hoc advisory as specific needs arise, transitioning to the Outsourced retainer if ongoing operational demands justify continuous support.

  • The Lagom Sports Compliance AML framework includes a dedicated sanctions framework covering the specific sanctions regimes most relevant to professional football: UK sanctions (OFSI), EU sanctions (consolidated list), US OFAC sanctions and UN Security Council designations.

    The framework defines screening requirements for each counterparty category, including owners, investors, transfer parties, agents and sponsors, the frequency of ongoing screening, the alert-handling procedure and the escalation requirements when a potential match is identified.

    The 2022 UK sanctions on Roman Abramovich and the subsequent operation of Chelsea FC under a special licence demonstrated that sanctions risk in football is immediate, operational and reputationally severe. The AML framework's sanctions framework is calibrated to this reality. It assumes that sanctions exposure is a live risk for any club with international ownership, cross-border transfer activity or commercial relationships in higher-risk jurisdictions.