Agent fees hit $1.37 billion in 2025: what that means for AML obligations on both sides of the transaction

From 10 July 2029, every football agent who earns a fee for intermediary services becomes an obliged entity under EU Regulation 2024/1624. Every club that pays that fee has been an obliged entity since the same date. The money flowing through agent relationships is now the most scrutinised transaction category in professional football, and the regulatory framework that governs it is almost entirely unbuilt.

The numbers that explain why regulators acted

According to FIFA's Football Agents Report 2025, clubs in men's professional football paid USD 1.37 billion in agent service fees for international transfers between January and December 2025. That figure represents a 90% increase on the previous year, itself a record, and is nearly double the 2023 figure of USD 889.4 million. English clubs led all markets at USD 375 million. German clubs were second at USD 165 million. UEFA member associations accounted for the largest share globally.

The growth trajectory, not just the absolute figure, is what concerns regulators. Agent fee flows in international football have more than doubled in two years. They are routed through agencies incorporated across dozens of jurisdictions, many with minimal public beneficial ownership registers. They are paid in complex structures -- dual representation fees, club-to-club commission splits, image-rights arrangements -- that are specifically designed to separate the economic outcome from the formal contractual description. And until July 2029, they are subject to virtually no mandatory AML scrutiny at all.

The 90% year-on-year surge in reported fees is itself partly a product of FIFA's mandatory disclosure requirements through the Transfer Matching System, which requires clubs to formally declare all agents and commissions. Previously unreported or under-reported fees are now being captured. The true scale of agent-related flows has been larger for longer than the pre-2025 figures suggested. Regulators have been watching this number grow for years. EU Regulation 2024/1624 is the outcome. 

What the regulation actually says about agents and fees

EU Regulation 2024/1624 is unambiguous. Article 3(n) lists football agents as obliged entities -- every natural or legal person who, for a fee, provides intermediary services and represents football players or clubs in negotiations. Article 3(o) lists professional football clubs as obliged entities in respect of four transaction types, one of which is explicitly transactions with football agents or other intermediaries.

The consequence is that every agent fee transaction from July 2029 generates AML obligations on both sides simultaneously. The agent must conduct customer due diligence on the club or player it is representing. The club must conduct customer due diligence on the agent it is paying. Both must maintain records, screen for sanctions and PEPs, assess source of funds and, where warranted, file suspicious activity reports.

There is no size threshold, no volume exemption, and no carve-out for smaller agencies. A solo operator representing two players in the French second division carries the same formal obligations as the largest multi-national agency. The only distinction the regulation draws is proportionality: the intensity of controls should reflect the actual risk profile of the entity applying them. A smaller agency with domestic clients and straightforward commission flows may operate a lighter-touch framework than a major cross-border operator. But it must still have a framework.

What clubs must do on agent payments

• Identify and verify the beneficial ownership of the agent entity before the fee is approved
• Screen the agent and any beneficial owners against sanctions lists and for PEP status
• Assess whether the fee is consistent with services actually rendered to the club
• Conduct source-of-funds assessment for agent entities with opaque ownership structures
• Maintain a documented record of the due diligence performed
• Refresh the assessment if circumstances change between transactions

What agents must do to earn their fee

• Conduct customer due diligence on the club (or player) they represent before acting
• Identify the club's beneficial ownership structure where relevant to the relationship
• Screen counterparties against sanctions and PEP lists with ongoing monitoring
• Maintain an AML policy, documented procedures and a risk assessment framework
• Designate a senior person responsible for AML compliance within the agency
• File suspicious activity reports where warranted and maintain records for five years

EU Regulation 2024/1624, Article 3(n) and (o) | Lagom Sports Compliance commentary

The club perspective: why agent fee payments are the highest-risk line item

Agent fee payments are the single transaction type where the combination of volume, opacity and structural complexity creates the greatest AML exposure for clubs. The USD 1.37 billion figure represents tens of thousands of individual payments, routed through agencies incorporated across dozens of jurisdictions, many of which clubs have never meaningfully investigated.

The most common failure, described in detail in our article on transfer-window AML controls, is that clubs approve agent fee payments as part of the deal workflow without first establishing who actually owns the receiving entity, where the funds will ultimately go, and whether the agency has a legitimate commercial history consistent with the services described. The compliance question is asked too late, or not at all.

From July 2029, that approach is non-compliant. The club must, before approving the payment, have verified the beneficial ownership of the agency, conducted a sanctions and PEP screen, and documented why the fee is consistent with genuine services to the club. Where any of those steps reveals a red flag -- an agency incorporated weeks before the deal, a beneficial owner connected to a high-risk jurisdiction, a commission disproportionate to the services described, the club must either resolve the concern or escalate to its designated AML function.

The practical implication for clubs is that the agent payment approval process needs to be rebuilt around an AML checkpoint. This is not a post-deal documentation exercise. It is a pre-approval verification requirement. A club that builds that checkpoint into its transfer workflow before 2029 will find the incremental cost modest. A club that builds it under supervisory pressure after 2029 will find the cost considerably higher.

The agent perspective: a new compliance architecture from scratch

Football agents face a more fundamental challenge than clubs. Clubs have finance and legal functions. They have existing governance frameworks. Their AML obligations represent an extension of structures that already partially exist. Agents, particularly the individual operators and smaller agencies that represent the majority of the 10,525 licensed agents worldwide, have none of this infrastructure and have never operated under any formal AML framework.

The agent's AML obligations under the AMLR are comprehensive: a risk assessment framework, documented policies and procedures, customer due diligence on counterparties, transaction monitoring, sanctions and PEP screening, a designated senior person responsible for compliance, and a suspicious-activity reporting capability. This is not a checklist to be ticked once. It is a compliance architecture that needs to be designed, built and maintained.

The proportionality principle offers some relief. A solo agent representing domestic clients in straightforward domestic transactions does not need the same framework as an agency managing EUR 50 million in cross-border commission flows annually. But proportionality does not mean nothing. It means a risk-assessed, documented framework appropriate to the agent's actual profile. And that framework needs to exist before July 2029 -- not be commissioned in 2028 when the market for qualified compliance support will be under maximum pressure.

There is also a commercial dimension that many agents have not yet absorbed. Banks, clubs and institutional partners are increasingly applying AML due diligence to agents as part of their own compliance obligations. An agent without a demonstrable compliance framework will find it harder to maintain banking relationships, complete cross-border transactions and demonstrate to club counterparties that they are an acceptable, verified party to a deal. Compliance, in the agent market, is becoming a commercial prerequisite as well as a legal one.

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If agent fee flows grew at even half the 2025 rate through 2029, the annual total will exceed USD 2 billion by the time the AMLR obligations come into force. Every pound and euro of that flows through a transaction where, from July 2029, both the paying club and the receiving agency are obliged to have conducted verified due diligence on each other. The scale of the compliance build required across the agent market -- 10,525 licensed agents, the majority of them with no existing AML infrastructure -- is the reason the regulation gave football an extended transition period to 2029. That transition period ends in three years. For most agents, it has not yet begun.

On both sides of the transaction, the clock is running.

Lagom Sports Compliance works with football clubs and agents on AML compliance frameworks proportionate to their actual risk profile and sized to their capacity. Whether you are a CFO approving agent payments or an agent preparing for your first regulatory framework, the starting point is the same.

Our free EU AML 2024/1624 compliance checkergives an immediate read on where you stand. We also have dedicated AML guidance for agents and clubs.

For clubs and agents ready to build, the ourEU AML 2024/1624 Readiness Assessmentdelivers a documented gap analysis and prioritised roadmap. We can also build a full anti-financial crime framework build for your club as well as provide outsourcing and resourcing support, saving you from hiring directly.

$1.37 billion in 2025. Both sides of every transaction. Three years to build the controls.

Frequently asked questions: football agent fees and AML obligations

• Do football agents have AML obligations under EU law?

  Yes. EU Regulation 2024/1624, Article 3(n), explicitly lists football agents as obliged entities from 10 July 2029. Every natural or legal person who, for a fee, provides intermediary services and represents football players or clubs in negotiations with a view to concluding a contract or transfer agreement is in scope. There is no size or turnover threshold for agents -- every licensed agent providing paid intermediary services is subject to the full AML framework, with proportionality determining the intensity of controls rather than whether they apply at all.

• What AML obligations apply to football clubs when paying agent fees?

  Under EU Regulation 2024/1624, transactions with football agents or other intermediaries are one of the four transaction types that bring professional clubs within the AML perimeter from July 2029. Before approving an agent fee payment, a club must identify and verify the beneficial ownership of the receiving entity, conduct sanctions and PEP screening, assess whether the fee is consistent with genuine services rendered to the club, and maintain a documented record of the due diligence performed. Where any element raises a concern, the club must either resolve it or escalate to its designated AML function before the payment proceeds.

• How much did football agents earn in fees in 2025?

  According to FIFA's Football Agents Report 2025, clubs in men's professional football paid USD 1.37 billion in agent service fees for international transfers between January and December 2025. This represented a 90% increase on the previous year and was the highest annual total ever recorded, exceeding the previous record of USD 889.4 million set in 2023. English clubs were the largest payers at USD 375 million, followed by German clubs at USD 165 million. The surge was partly driven by FIFA's mandatory disclosure requirements through the Transfer Matching System, which are capturing previously unreported or under-reported agent fees.

• When do EU AML obligations apply to football agents?

  The football-specific obligations under EU Regulation 2024/1624 apply from 10 July 2029. This is two years after the rest of the regulation comes into force for other sectors in July 2027. The extended transition was a deliberate legislative choice to give clubs and agents, who have never previously been classified as obliged entities under EU AML law, time to build compliance frameworks from scratch. Most agents have not yet begun that build.

• What does a football agent need to do to comply with EU AML 2024/1624?

  An agent must: conduct a business-wide risk assessment identifying the AML and terrorist financing risks specific to their activities; put in place a documented AML policy and procedures proportionate to that risk profile; conduct customer due diligence on the clubs, players and other counterparties they represent; screen counterparties against sanctions lists and for PEP status, with ongoing monitoring; designate a senior person responsible for AML compliance; maintain records of due diligence and transactions for a minimum of five years; and file suspicious activity reports with the relevant Financial Intelligence Unit where warranted. For smaller agents with straightforward domestic practices, a proportionate version of this framework will be lighter than for major cross-border operators, but the requirement to have something documented and operational applies universally.

• Is an agent fee payment a suspicious transaction under AML rules?

  An agent fee payment is not inherently suspicious, but certain features of agent fee transactions should prompt enhanced scrutiny. These include: agencies incorporated in jurisdictions with weak beneficial ownership registers; payment to an entity incorporated recently with no prior trading history; fee amounts disproportionate to the services described in the representation agreement; split payments to multiple entities rather than a single identified agency; beneficial owners of the agency connected to PEPs or high-risk jurisdictions; and dual representation arrangements where the agent's genuine services to the club cannot be independently documented. Where any of these factors is present and cannot be satisfactorily resolved, the transaction may need to be escalated or reported.

• Does the 90% increase in agent fees in 2025 affect AML risk?

  The rapid growth in agent fee flows increases AML risk in two ways. First, larger absolute sums create greater incentive for criminal actors to misuse agency structures as conduits for illicit funds. Second, the compression of transfer activity into short windows means due diligence is routinely conducted under time pressure, increasing the probability that a concerning structure is overlooked. The FIFA Agents Report 2025 also notes that part of the year-on-year increase reflects previously unreported fees now being captured by FIFA's mandatory TMS disclosure requirements, suggesting the true historical scale of agent flows has been consistently larger than reported figures indicated. Regulators and supervisors will use these numbers as evidence of why the AML perimeter needed to be extended to football.