How criminals launder money through football: the mechanics, the cases and why regulators finally acted
Football moved USD 8.59 billion in international transfer fees in 2024 and a record USD 1.37 billion in agent commissions in 2025, flowing through ownership structures, image-rights vehicles and cross-border payment chains that span virtually every jurisdiction on earth. The Financial Action Task Force warned in 2009 that the sport's regulatory framework had not kept pace with its own growth. Sixteen years later, the European Union has finally acted. This article explains, in detail, how the laundering actually works, and why football's structure makes it uniquely exploitable.
Why football, and why now
In July 2009, the Financial Action Task Force, the global standard-setter for anti-money laundering policy, published a report titled "Money Laundering through the Football Sector." It was, at the time, a genuinely novel piece of analysis: the first systematic attempt by an international standard-setting body to map how the world's most popular sport could be exploited as a laundering vehicle. Drawing on more than 20 case examples gathered from 25 countries, the report identified three categories of vulnerability specific to football: structural factors (the sector's low barriers to entry and informal connections between business, sport and, in some cases, organised crime); financing-related factors (the scale, speed and opacity of the money moving through transfers, sponsorship and ownership); and cultural factors (an industry historically resistant to the kind of governance and financial transparency expected of comparable commercial sectors).
Sixteen years on, every one of those vulnerabilities has intensified rather than diminished. Football clubs spent USD 8.59 billion on international transfer fees in 2024 -- the second-highest figure ever recorded, following an all-time high of USD 9.66 billion the year before. A record 78,742 international transfers were completed across men's, women's and amateur football. And in 2025, clubs paid a record USD 1.37 billion in agent service fees -- a 90% increase on the previous year, itself the highest annual total ever recorded. None of that growth has been accompanied by a comparable increase in financial transparency.
That gap between scale and scrutiny is precisely why the European Union has now brought professional football clubs and agents inside the formal AML perimeter. Under Article 3 of EU Regulation 2024/1624, both are classified as obliged entities -- the same legal category as banks, law firms and payment institutions -- from 10 July 2029. AMLA's Chair, Bruna Szego, explained the rationale directly in an April 2026 interview with Calcio e Finanza: football was included because of its "global popularity, the amount, frequency and internationality of cash-flows involved, and the opacity of corporate ownership structures." That is, in three clauses, a near-perfect restatement of the FATF's 2009 warning, arriving sixteen years after the original alarm was raised.
The three-stage model
Anti-money laundering frameworks traditionally describe laundering as a three-stage process: placement, the introduction of illicit funds into the financial system; layering, the creation of complexity to disguise their origin; and integration, the return of funds to the legitimate economy with the appearance of legality. It is a useful starting framework, and football can, in principle, facilitate all three stages.
But the model has a real limitation when applied to football, and it is worth naming directly rather than glossing over: laundering through football rarely follows the model's neat, linear sequence. The same transaction -- a single transfer, a single sponsorship agreement, a single ownership stake -- can simultaneously serve placement, layering and integration functions, because football's structure is circular and networked rather than linear. A club is not one counterparty. It is the central node of a web of simultaneous relationships -- investors, sponsors, agents, intermediaries, banks, payment providers, betting operators, broadcasters and image-rights vehicles, and a single payment can move value across several of those relationships in one transaction. With that caveat in place, the three-stage framework remains a useful map for understanding the individual mechanisms football makes available, so long as it is read as a set of overlapping risk areas, not a strict sequence every laundering scheme must follow.
Placement: how illicit funds enter the football system
Placement is the point at which criminal proceeds first enter a financial system. Football offers several distinctive placement routes that a conventional bank or retail business does not.
The most direct is club acquisition and investor funding. Buying or investing in a football club is, in financial terms, an unusually opaque way to deploy large sums of capital. Club valuations are imprecise and emotionally driven rather than asset-backed in any conventional sense. Ownership structures routinely run through multiple holding companies, often in jurisdictions chosen for reasons that have nothing to do with football. A buyer with capital of uncertain origin can inject that capital as equity, as a shareholder loan, or as related-party financing, and the recipient club, historically, has had little incentive and even less obligation to ask searching questions about where the money came from.
A second placement route runs through capital injections disguised as ordinary commercial activity: sponsorship payments from entities with no genuine commercial rationale for associating with the club; loans from related parties on terms no independent lender would offer; or payments for ill-defined consultancy and advisory services. None of these payments need to look unusual on the club's books. They simply need a counterparty willing to pay, and a club willing not to ask why.
Layering: where football's complexity becomes the criminal's advantage
Layering is where football's specific structural features do the most work for a launderer, because the sport offers genuine, legitimate-looking complexity that ordinary financial layering schemes have to manufacture artificially.
The transfer market itself is the clearest example. A transfer fee is, by its nature, a subjective valuation, there is no equivalent of a public market price for a 22-year-old midfielder. That subjectivity creates room for inflated or deflated transfer valuations: a fee set above or below the player's genuine market value as a mechanism for moving the difference between two parties under cover of a legitimate sporting transaction. Layered on top of that is the structure of the deal itself, sell-on clauses, add-ons, image-rights components and third-party economic interests can split a single transfer's value across multiple payment streams, multiple recipients and multiple tax jurisdictions, each layer adding distance between the original source of funds and their eventual destination.
Agent commissions compound the problem. The record USD 1.37 billion paid in agent fees in 2025 flowed through thousands of individual transactions, a significant proportion of them to entities incorporated specifically around a single deal, in jurisdictions with minimal beneficial ownership transparency. FIFA's own reporting noted that a substantial part of the 90% year-on-year increase in disclosed agent fees reflects previously unreported or under-reported commissions now being captured through mandatory disclosure in FIFA's Transfer Matching System, which tells its own story about how much of this money flow has historically gone undocumented entirely.
Image rights and offshore structures add a further layering mechanism specific to football's commercial model. A significant proportion of a star player's earnings can legitimately be routed through a separate image-rights company, frequently incorporated offshore, which licenses the player's name, likeness and brand to clubs and sponsors. This is a genuine and widely used commercial structure -- but the same architecture, with weak transparency and minimal scrutiny of the underlying ownership, is equally capable of being used to mis-price transactions, shift profits between jurisdictions and disguise the ultimate beneficiary of payments that have nothing to do with the player's actual commercial activity.
Betting markets provide a final, distinct layering channel -- one that converts illicit funds into apparently legitimate gambling winnings, while simultaneously creating the conditions for match manipulation. Europol's Operation VETO, a Joint Investigation Team running from July 2011 to January 2013 across thirteen European countries, identified more than 380 suspicious matches in fifteen countries and a further 300 outside Europe, implicating 425 match officials, club officials, players and organised criminals. The operation traced betting profits exceeding eight million euros and corrupt payments to officials and players exceeding two million euros, with bribes of up to one hundred thousand euros paid to fix a single match, evidence, in Europol's own words at the time, of "illegal profits made on a scale and in a way that threatens the very fabric of the game."
Risk in football does not exist in isolation. Ownership structures, transfer fees, agent commissions, sponsorship arrangements and betting markets all intersect, and that intersection, not any single transaction, is where the real exposure to financial crime sits.
Integration: how laundered funds re-enter the legitimate economy
Integration is the final stage: returning laundered funds to the legitimate economy with the appearance of legality. Football provides an unusually effective integration mechanism because of one specific feature commercial revenue from a football club is genuinely difficult to distinguish from criminal proceeds once it has passed through the club's accounts. Match-day income, broadcasting revenue, merchandising, sponsorship receipts, transfer proceeds and dividend distributions all sit in the same revenue lines. A club's accounts do not, by default, separate funds by their origin. Once capital has entered the system through placement and moved through one or more layering mechanisms, it can exit as apparently ordinary club revenue or as the proceeds of a club sale, legitimised, not by any specific laundering technique, but simply by having passed through a credible commercial institution.
Why football is structurally attractive to criminals
The scale of what regulators are now confronting
The figures involved are not marginal. Football clubs spent USD 8.59 billion on international transfers in 2024, following USD 9.66 billion the year before, both among the highest totals ever recorded. Agent commissions reached USD 1.37 billion in 2025. English clubs alone spent over USD 375 million on agent fees in a single year. And FIFA's own data shows that nearly 40% of all transfer spending in men's professional football is concentrated in the top 2.5% of deals -- transactions worth USD 20 million or more, the exact value bracket where mis-pricing and layering risk is most acute and most difficult to detect through conventional due diligence.
None of this proves that any given transaction is illicit. The overwhelming majority of transfer activity, sponsorship income and agent commission is entirely legitimate. What the figures demonstrate is scale: a sector moving tens of billions of dollars annually, across every jurisdiction on earth, through transaction types that are structurally resistant to the kind of beneficial ownership verification, source-of-funds analysis and ongoing monitoring that banks have applied as a matter of routine for decades. That resistance, not any specific scandal, is what brought football inside the EU's AML perimeter.
What EU Regulation 2024/1624 actually changes
From 10 July 2029, professional football clubs and football agents become obliged entities under Article 3 of EU Regulation 2024/1624. The obligations that follow are not abstract. Clubs and agents will be legally required to conduct customer due diligence on investors, sponsors, agents and transfer counterparties; to identify and verify beneficial ownership through every layer of corporate structure; to screen counterparties against sanctions and PEP lists on an ongoing basis; to analyse source of funds and source of wealth for higher-risk relationships; and to maintain a governance framework capable of identifying and reporting suspicious activity.
Applied to the mechanisms described in this article, the practical effect is direct. Beneficial ownership verification closes the placement route that depends on opaque holding structures. Source-of-funds analysis on transfer payments and agent commissions addresses the layering mechanisms built around subjective valuation and intermediary opacity. Ongoing monitoring obligations, which most clubs have never operated in any form, address the integration problem of laundered funds disappearing into undifferentiated commercial revenue once a deal has closed. None of these are exotic requirements. They are what banks, law firms and payment institutions have done as standard practice for years. Football is simply the latest, and arguably the most overdue, sector to be brought up to that standard. For the full detail on what the regulation requires, see Lagom Sports Compliance's complete guide to EU Regulation 2024/1624.
What this means in the transfer window specifically
Most of the laundering mechanisms described in this article converge at a single operational moment: the transfer window. A small number of weeks in which clubs must complete beneficial ownership checks, agent due diligence and source-of-funds analysis under intense commercial time pressure — precisely the conditions under which controls are most likely to be skipped.
A separate Lagom Sports Compliance article examines the five specific control failures that recur most often in transfer-window activity.
Understanding the mechanism is the first step. Controlling it is the next.
Lagom Sports Compliance is a specialist AML and financial-crime advisory firm built exclusively for professional football. The firm advises clubs, agents, leagues and their advisers on building compliance frameworks that address the specific mechanisms set out in this article, not generic controls imported from banking, but football-native frameworks designed around how the transfer market, agent commissions, sponsorship and ownership structures actually function.
The starting point is the free compliance checker. For a structured gap analysis and prioritised roadmap, the our Readiness Assessment covers beneficial ownership documentation, source-of-funds frameworks and ongoing monitoring design. We also have dedicated AML guidance for clubs and agents.
Football did not create money laundering. But for sixteen years, its structure has provided exceptional mechanisms through which laundering could occur, largely unexamined. That window is closing.
Frequently asked questions: how money laundering works through football
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Criminals can exploit several distinct features of football's financial structure. At the placement stage, illicit funds can enter through club acquisitions, investor funding or capital injections disguised as sponsorship or consultancy payments. At the layering stage, the subjective valuation of transfer fees, the complexity of agent commission structures, offshore image-rights vehicles and betting markets all provide mechanisms to disguise the origin and ownership of funds while creating apparent commercial legitimacy. At the integration stage, laundered funds can re-enter the legitimate economy as undifferentiated club revenue -- match-day income, sponsorship receipts or transfer proceeds -- which is structurally difficult to trace back to its original source once it has passed through a club's accounts.
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The FATF's July 2009 report, 'Money Laundering through the Football Sector', identified three categories of vulnerability: structural factors (low barriers to entry and informal connections between business, sport and criminal networks), financing-related factors (the scale, speed and opacity of money flowing through transfers, sponsorship and ownership), and cultural factors (an industry historically resistant to the financial transparency and governance standards expected of comparable commercial sectors). The report drew on more than 20 case examples from 25 countries and concluded that money laundering through football was deeper and more complex than previously understood.
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EU Regulation 2024/1624 (the AMLR) classifies professional football clubs and football agents as obliged entities under Article 3, applicable from 10 July 2029. AMLA's Chair, Bruna Szego, explained in an April 2026 interview that football was brought into scope because of its global popularity, the amount, frequency and internationality of its cash flows, and the opacity of its corporate ownership structures -- effectively the same concerns the FATF identified in 2009, sixteen years earlier. The regulation requires clubs and agents to conduct customer due diligence, verify beneficial ownership, screen for sanctions and politically exposed persons, analyse source of funds and wealth, and maintain governance frameworks capable of identifying suspicious activity.
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According to FIFA's own reporting, clubs spent USD 8.59 billion on international transfer fees in 2024, the second-highest figure ever recorded after USD 9.66 billion in 2023. A record 78,742 international transfers were completed across men's, women's and amateur football. Separately, FIFA's Football Agents Report 2025 recorded a record USD 1.37 billion paid in agent service fees in 2025 -- a 90% increase on the previous year. English clubs alone spent over USD 375 million on agent fees in that period. Nearly 40% of all men's professional transfer spending is concentrated in the top 2.5% of deals, each worth USD 20 million or more.
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The traditional model describes money laundering in three stages: placement (introducing illicit funds into the financial system), layering (creating complexity to disguise their origin), and integration (returning funds to the legitimate economy with the appearance of legality). The model provides a useful starting framework for understanding football's vulnerabilities, but it does not map cleanly onto the sport's actual structure. Because a football club sits at the centre of a dense, interconnected network of investors, sponsors, agents, intermediaries and other commercial relationships, a single transaction can serve placement, layering and integration functions simultaneously, rather than following the model's linear sequence. Effective analysis of football's financial crime risk therefore needs to treat these as overlapping risk areas rather than a strict sequential process.
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Agent commissions are one of the clearest layering mechanisms in football's financial structure. FIFA reported a record USD 1.37 billion paid in agent service fees in 2025, a substantial part of which reflects previously unreported or under-reported commissions now being captured through FIFA's mandatory disclosure requirements, which itself indicates how much of this money flow has historically gone undocumented. Commission payments frequently flow to entities incorporated specifically around a single transaction, often in jurisdictions with minimal beneficial ownership transparency, creating distance between the original commercial relationship and the eventual recipient of funds.
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Operation VETO was a Joint Investigation Team led by Europol, running from July 2011 to January 2013 across thirteen European countries. It identified more than 380 suspicious football matches across fifteen countries, with a further 300 identified outside Europe, implicating 425 match officials, club officials, players and organised criminals. The investigation traced betting profits exceeding eight million euros and corrupt payments exceeding two million euros, with bribes of up to one hundred thousand euros paid to fix individual matches. Europol's then director, Rob Wainwright, described the findings as evidence of illegal profits made on a scale that threatened the integrity of the sport. The case illustrates how betting markets function as both a layering mechanism for illicit funds and a direct driver of match manipulation.