AML Outsourcing & Resourcing Support

An outsourced AML function for a professional football club can provide up to four interconnected services on a continuous basis.

First, ongoing advisory and MLRO support: AML advice available in real time to the club's finance, legal and transfer teams; fulfilment of the MLRO function including suspicious activity report assessment and filing; policy updates as regulation evolves; and escalation support for complex situations including sanctions events and ownership changes.

Second, counterparty due diligence: ongoing KYB, UBO verification, sanctions and PEP screening, and adverse media monitoring for the club's sponsors, agents, investors and ownership structure.

Third, transfer-window oversight: pre-transaction review of transfer structures and payment flows, agent commission validation, intermediary assessment, red-flag analysis and source-of-funds review for high-value transactions, through every window.

Fourth, governance and reporting: annual AML independent review, quarterly board reporting, banking support for AML questionnaires and reviews, and regulatory support if a supervisory review is initiated.

No, but it is the most common and effective entry point. The Outsourced model operates most efficiently when applied to a club that already has a documented AML framework in place, because the service is designed to run and maintain that framework rather than build it from scratch.

Clubs that complete an AML framework engagement with Lagom Sports Compliance and transition to Outsourcing and Resourcing support benefit from continuity. We already know the club's ownership structure, counterparty universe, risk profile and the specific design decisions made during implementation.

Clubs that come to us with an existing framework built elsewhere can also access Outsourcing and Resourcing support directly, following an initial review of the existing framework to assess its adequacy and calibrate the ongoing service accordingly.

The MLRO support function within Lagom Sports Compliance Outsourcing and Resourcing covers the core responsibilities of a designated Money Laundering Reporting Officer.

In practice, this means receiving and assessing internal suspicious activity reports from club staff who identify potential concerns; determining whether the circumstances require an external Suspicious Activity Report (SAR) to be filed with the National Crime Agency in the UK or the relevant financial intelligence unit in another jurisdiction; maintaining the SAR log and escalation records; acting as the first point of regulatory contact on AML matters; and providing guidance to staff on AML obligations as they apply to specific situations.

We do not act as the formally registered MLRO in jurisdictions where that designation requires individual regulatory registration. In those cases, we support the designated individual and provide the operational expertise, capacity and documentation behind the role.

Transfer windows are the most operationally intensive period for football clubs from an AML perspective and the period when the consequences of inadequate controls are most immediate.

During a window, our oversight service operates in near real-time. For each proposed transaction, we conduct a pre-commitment review covering the transfer structure, payment mechanics, the identity and status of all parties, the agent commission arrangement and any third-party payment requests. Before payment is released, we validate the payment flow against the agreed documentation.

Throughout the window, we monitor for red flags including unusual payment structures, unregistered intermediaries, last-minute counterparty changes and requests to direct payments to unexpected parties. We escalate immediately when any are identified. Every review is documented, creating a complete decision trail for the window. Post-window, we produce a summary report covering all transactions reviewed, findings and any outstanding matters.