EU AML 2024/1624 Readiness Assessment

Lagom Sports Compliance Readiness Assessment.

Know exactly where you stand against EU AML 2024/1624.

A fixed-scope diagnostic that maps your club or agency against EU Regulation 2024/1624 expectations and delivers a clear, prioritised path to compliance.

What's Included

Enterprise risk assessment against EU AML 2024/1624
Football-specific risk mapping: transfers, agents, sponsorship, ownership
Transfer-flow risk review
Ownership exposure analysis — including offshore structures and holding vehicles
Sanctions exposure assessment — ownership, investor and sponsor layer
Gap analysis against EU AML obligations
Banking-readiness review
Governance maturity assessment

Deliverables

Executive report suitable for board presentation
Risk heat map — red/amber/green by control area
Residual risk scoring
Prioritised remediation roadmap

Readiness Credit

The fee charged for our EU AML 2024/1624 Readiness Assessment is credited in full against a Framework Development engagement if you proceed for that service within six months of completing the Readiness Assessment.

Want to book an EU AML 2024/1624 Readiness Assessment?

If you're interested in an EU AML 2024/1624 Readiness Assessment, 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 EU AML 2024/1624 Readiness Assessment

A football AML readiness assessment is a structured diagnostic engagement that maps a professional club's or agent's current compliance position against the requirements of EU Regulation 2024/1624, identifies specific control gaps and produces a prioritised remediation roadmap.
The Lagom Sports Compliance Readiness Assessment covers eight areas: enterprise risk assessment calibrated to EU AML 2024/1624 requirements; football-specific risk mapping across transfer activity, agent relationships, sponsorship and commercial partnerships; transfer-flow risk review examining payment structures, deferred fees and agent commission routing; ownership exposure analysis including offshore holding companies, trusts and multi-jurisdiction investor structures; and beneficial ownership identification review.
It also covers sanctions exposure assessment across the ownership, investor and sponsor layers; gap analysis against each EU AML 2024/1624 obligation relevant to the entity; banking-readiness review against correspondent bank AML expectations; and governance maturity assessment covering policy, board oversight and escalation.
Deliverables include an executive report suitable for board presentation, a risk heat map, residual risk scoring and a prioritised remediation roadmap.
The Lagom Sports Compliance EU AML 2024/1624 Readiness Assessment is specifically designed for professional football clubs and agents, not adapted from a banking audit template. The risk categories it assesses, the benchmarks it uses and the language of its outputs all reflect football's actual financial model: transfer fee mechanics, agent commission structures, image-rights vehicles, UEFA licensing criteria and the specific provisions of EU Regulation 2024/1624 as they apply to professional sport.
A generic AML audit produced by a non-specialist firm will typically miss football-specific risk vectors, apply disproportionate control benchmarks derived from banking practice, and produce a report that is difficult to act on in a football operational environment.
The Readiness Assessment output is also specifically designed to be presentable to a bank's AML function or a regulatory supervisor, a practical requirement that shapes both the content and the presentation of findings.
Very little. The assessment is designed to work with whatever documentation currently exists, not against an idealised baseline.
We typically ask for any existing AML, compliance or governance policy documentation; basic ownership structure information; an overview of recent transfer activity and current agent relationships; and details of any current sanctions screening or KYC procedures.
Most clubs and agencies at this stage have limited or no formal documentation. That is precisely what the assessment is designed to diagnose. The absence of documentation is not an obstacle to commencing the assessment. It is one of the findings the assessment will record and address in the remediation roadmap.
Yes, and we recommend doing so proactively. The executive report component of the Readiness Assessment is specifically written to be board-presentable and shareable with external counterparties including banking partners, auditors and regulatory supervisors.
It establishes a documented, professionally produced baseline of the club's AML risk profile and control gaps, which is substantially more credible to external scrutinisers than the absence of any documentation.
Clubs that have completed a Readiness Assessment are materially better positioned in banking reviews and investor due diligence processes, even before a full framework has been built, because it demonstrates that the organisation has assessed its position and has a credible plan to address it.

No. The EU AML 2024/1624 Readiness Assessment is a standalone engagement with no obligation to proceed further. Some clients complete the assessment, review the roadmap and choose to build the framework in-house using the roadmap as their guide. Others use it to inform a board decision about compliance investment.
The assessment stands alone as a deliverable.
That said, the Readiness Assessment fee is credited in full against a Framework Development engagement if the client proceeds within six months of completion of the Assessment. So if a club does decide to commission a full framework build, the diagnostic cost is not an additional expense on top of the implementation.
These are different engagements serving different purposes.
An EU 2024/1624 Readiness Assessment is a starting-point diagnostic for clubs or agents that do not yet have an AML framework in place. It assesses the current position against what is required and produces a roadmap for building the necessary controls.
An Annual AML Independent Review is a testing engagement for clubs or agents that already have a framework in place. It tests whether the existing controls are working effectively, whether policies are current, and whether identified weaknesses have been remediated.
Clubs typically commission a Readiness Assessment before building their framework and an Annual Independent Review each year after it has been implemented.
Typical delivery is four to eight weeks from kick-off to final report.
The timeline has four phases. First, an initial scoping conversation and document collection, taking one to two weeks. Second, football-specific risk analysis and gap assessment, taking two to three weeks. Third, drafting of the executive report, risk heat map and remediation roadmap, taking one to two weeks. Fourth, a presentation of findings to senior leadership with a question and answer session.
For clubs with more complex ownership structures or higher transfer volumes, the analysis phase may extend to the outer end of the range. We agree the timeline explicitly at kick-off and flag any factors that may affect it.
EU Regulation 2024/1624 includes a proportionality principle: member states can exempt genuinely lower-risk smaller clubs from some obligations in limited circumstances. However, the assessment itself is the tool that establishes whether a club qualifies for any such exemption and what level of control is proportionate.
Proceeding without an assessment, and therefore without documented evidence of having considered the question, is itself a compliance weakness.
For smaller clubs, an EU AML 2024/1624 Readiness Assessment typically confirms that a proportionate and lighter-touch framework is appropriate. That is a more defensible position than having no documentation at all, and the cost of establishing it is modest relative to the risk of regulatory or banking scrutiny without it.