Europe is closing the AML perimeter: what South and Central American clubs and agents need to know before 2029

EU Regulation 2024/1624 does not apply directly to clubs in Brazil, Argentina, Colombia, Uruguay, Chile, Costa Rica, Mexico or Panama. But if your club sells players to Europe, works with European agents or aspires to attract international investment, European rules already shape the terms on which those transactions can happen. This guide explains why and, more importantly, what you need to do about it.

If you want to read this article in Spanish, click here.

The new European perimeter: what EU Regulation 2024/1624 establishes

EU Regulation 2024/1624, the new Anti-Money Laundering Regulation (AMLR), was adopted by the Council of the European Union on 30 May 2024. From 10 July 2029, professional football clubs and football agents operating within the EU are formally classified as 'obliged entities' under European AML law, alongside banks, law firms and payment institutions.

That means from that date, European clubs are legally required to conduct due diligence on their counterparties across four transaction categories: investors, sponsors, football agents and player transfers. Article 3 of the AMLR is explicit. Beneficial ownership identification, source-of-funds analysis, sanctions and PEP screening, and suspicious activity reporting become legal requirements, not voluntary best practice.

Why it affects Latin American clubs even if they are not in the EU

The European perimeter does not stop at the EU border. It extends through every transaction a European club has with an external counterparty. And that is precisely where Latin American clubs are directly caught by this regulation, even though they never play a match in Europe.

Consider the mechanics of a standard South America-to-Europe transfer. A Bundesliga club buys a player from a Brasileirao club. From July 2029, the German club is an obliged entity under the AMLR. It has to conduct due diligence on the selling entity: verify its beneficial ownership structure, the source of funds associated with the transaction, and the identity of the real owners behind any corporate structures. If the Brazilian club cannot produce that documentation cleanly, the transfer stalls. Not delayed. Stalled.

The same applies to agents. Brazil registered the largest volume of international transfers in the world in 2025. Argentina is the largest exporter of players by volume. Colombia, Uruguay and Chile have active and growing export markets. Mexico leads Concacaf transfer flows. Every one of those transfers generates agent commission flows, the majority of which run through entities that no European buyer has seriously investigated to date. That is going to change.

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From July 2029, every European club buying a player from Latin America has a legal obligation to verify the beneficial ownership of the selling entity. If the selling club cannot demonstrate it, the transfer stalls.

CONMEBOL and Concacaf: the regional compliance framework already exists

One point consistently overlooked in discussions of the AMLR and Latin America is that CONMEBOL already operates a functioning AML framework. CONMEBOL's AML Manual, published in 2023 under the oversight of the confederation's Ethics and Compliance Department and aligned with the requirements of SEPRELAD (the Paraguayan anti-money laundering authority), establishes a full compliance system for CONMEBOL's own operations: counterparty due diligence policies, risk management, suspicious transaction reporting and internal audit cycles.

More importantly for clubs, this establishes an institutional precedent within South America: the idea that football should operate with documented financial controls is not a European imposition but something CONMEBOL itself already acknowledges as necessary. The gap is not between European standards and Latin American standards; it is between the institutional frameworks established at confederation level and the controls most individual clubs currently have in place, which in many cases are effectively none.

Concacaf, which covers clubs across North America, Central America and the Caribbean, also conditions competition access on financial integrity standards through its club licensing criteria. For clubs in Costa Rica, Mexico, Panama, Honduras, Guatemala and El Salvador, compliance pressure comes from two directions: downward from the confederation through licensing requirements, and outward from European buyers requiring due diligence documentation.

The due diligence problem: what European clubs will ask for

The practical problem for Latin American clubs is not the regulation itself. It is that they are not accustomed to being asked to prove anything. For decades, due diligence in outgoing transfers flowed mostly the other way: the European buying club investigated the player, not the selling club. That is fundamentally changing.

From July 2029, every European club buying a player from Latin America will have a legal obligation to verify the beneficial ownership of the selling entity, including any holding structure above it. They will need documentation on the source of funds associated with the transaction. They will need agent commissions paid to entities whose beneficial ownership has been verified. And they will need to be able to demonstrate to their national supervisor, and to AMLA, that they conducted that due diligence.

A Latin American club that cannot produce that documentation will not lose the transfer because the player is not good enough. They will lose it because the European counterparty cannot fulfil its own legal obligations in dealing with them. That is a different kind of problem, and it requires a different kind of solution.

What a Latin American club needs to have in place before 2029

The good news is that the controls European buyers will require are known, documentable and proportionate to the actual risk profile of most Latin American clubs. The bad news is that practically none of them have those controls in place yet.

1. Beneficial ownership map. Every club needs a documented, verified map of its legal ownership structure -- from the club entity up to the ultimate beneficial owner, through any intermediate holding structures, trust vehicles and investor stakes. This documentation needs to be current, accurate and deliverable to a European buyer within the timeframe the transfer market requires.

2. Agent and commission assessment. Agent commissions paid in outgoing deals will generate due diligence by the European buyer on the receiving entities. Clubs that work with agencies whose ownership structure is opaque, domiciled in jurisdictions with minimal beneficial ownership registers, or recently incorporated with no prior trading history are creating a problem for their own transfer capacity.

3. Financial governance framework. A European buyer conducting due diligence on a Latin American club as a selling entity will look for evidence of internal financial controls: a documented approval process for transfer payments, agent invoicing records, contractual documentation and governance decision records. A club with none of this cannot demonstrate it is a reliable counterparty.

4. Understanding of the regional regulatory landscape. Clubs affiliated to CONMEBOL and Concacaf should understand the compliance frameworks that already operate at confederation level and identify how their own governance structures relate to those expectations. The CONMEBOL AML manual, the Concacaf compliance cycle and the national frameworks in each jurisdiction form the regulatory context within which individual clubs already operate, even if most of them do not recognise it as such.

How far is your club from readiness?

Lagom Sports Compliance works with clubs and agents across Latin America on beneficial ownership documentation, proportionate AML compliance frameworks and readiness for European counterparty due diligence requirements. Our firm offers a free readiness checker at lagomsportscompliance.com/am-i-compliant — available for clubs and agents in any jurisdiction.

For a structured readiness assessment: lagomsportscompliance.com/eu-aml-2024/1624-readiness-assessment

Lagom Sports Compliance | lagomsportscompliance.com

The window is open. It will not stay open.

Lagom Sports Compliance is a specialist GRC, AML and financial-crime advisory firm built exclusively for professional football. The name is deliberate: lagom is Swedish for 'not too much, not too little -- just right'. The firm advises clubs, agents, leagues and confederations on AML compliance across EU Regulation 2024/1624, the IFR framework, UEFA's 2025 Club Licensing Regulations and the regional frameworks of CONMEBOL and Concacaf.

Start with the free compliance checker. It will tell you if you are in scope of the EM AML Regulation 2024/1624. For club-specific AML compliance guidance visit lagomsportscompliance.com/aml-compliance-for-football-clubs, and for agents: lagomsportscompliance.com/aml-compliance-for-football-agents.

European clubs are already building their frameworks. Latin American clubs that start now will be the preferred transfer partners in 2029. Those that wait will learn it the hard way.

Frequently asked questions: Latin American clubs and the EU AML perimeter

• Does EU Regulation 2024/1624 apply directly to South American or Central American football clubs?

  No. EU Regulation 2024/1624 applies directly only to clubs and agents operating within EU Member States. A club in Brazil, Argentina, Colombia, Uruguay, Chile, Costa Rica, Mexico or Panama is not itself an obliged entity under the regulation. However, every European club that transacts with a Latin American club -- in a player transfer, sponsorship arrangement or investment deal -- is itself an obliged entity from July 2029, and is legally required to conduct beneficial ownership verification, source-of-funds analysis and sanctions screening on the Latin American counterparty. If the Latin American club cannot provide the required documentation, the European club cannot complete its own legal obligations. The practical effect for Latin American clubs is equivalent to a direct requirement.

• What documentation will European clubs require from Latin American selling clubs after July 2029?

  At minimum, a European buying club will require: verified beneficial ownership documentation tracing the selling club's legal group structure to the ultimate natural person in control; source-of-funds information for the transaction; agent commission payment details and verified beneficial ownership of any agent entities involved; and sanctions and PEP screening confirmation. The European club's national AML supervisor, and ultimately AMLA, will assess whether its due diligence on Latin American counterparties was adequate. Clubs that present opaque ownership structures, recent corporate restructuring or unverifiable agent commission flows will create problems for their European transaction partners.

• Does CONMEBOL have AML requirements for its affiliated clubs?

  CONMEBOL operates its own AML compliance framework under its Ethics and Compliance Department, aligned with the requirements of SEPRELAD (Paraguay's anti-money laundering authority). The CONMEBOL AML Manual, published in 2023, establishes policies for due diligence, risk-based controls, suspicious transaction reporting and internal audit cycles for CONMEBOL's own operations. While this framework applies to CONMEBOL as an organisation rather than directly to individual affiliated clubs, it establishes an institutional precedent within South American football that AML controls are a recognised operational necessity. Individual clubs operating under CONMEBOL's licensing and competition framework should engage with those standards in building their own compliance programmes.

• What is the risk for Latin American agents operating in the European market after 2029?

  Football agents are listed as obliged entities under Article 3(n) of EU Regulation 2024/1624, with no size or turnover exemption available. Every agent providing intermediary services for a fee in respect of a transaction involving an EU club is in scope from July 2029. This means Latin American agents representing players in European transactions, receiving commissions from EU clubs, will be on the receiving end of enhanced due diligence from those clubs. An agent whose ownership structure is opaque, recently incorporated or unverifiable will find it increasingly difficult to receive commission payments from European clubs that are meeting their own AMLR obligations. Establishing a documented, verifiable agency structure is a commercial as well as a compliance priority.

• What should a Latin American club do now to prepare for the EU AML perimeter?

  The four priority areas are: first, producing and maintaining a verified beneficial ownership map of the club's full legal structure; second, reviewing agent relationships and ensuring commission-receiving entities have verifiable ownership structures; third, building basic financial governance documentation including internal approval processes for transfer payments and agent invoicing records; and fourth, understanding the CONMEBOL and Concacaf compliance frameworks relevant to the club's operations. Lagom Sports Compliance offers a free compliance assessment at lagomsportscompliance.com/am-i-compliant and structured readiness assessments for clubs and agents in any jurisdiction.