Football sponsorship due diligence: how clubs can avoid regulatory, legal and reputational risk

This morning, the Financial Conduct Authority -- the UK's statutory regulator of financial services firms and markets -- wrote to every Premier League club and the wider professional football community warning that sponsorship deals with unauthorised financial firms expose clubs to legal liability, money laundering risk and serious reputational damage. The letter names no specific clubs. The press coverage that followed named several. Every club in the English pyramid needs to read this carefully.

Breaking

What the FCA said this morning — 3 June 2026

The Financial Conduct Authority wrote to all UK football clubs on 3 June 2026, stating it had seen ‘an increase in football club partnerships with unauthorised firms, some of which appear to be operating unlawfully.’ The FCA warned that such arrangements risk conferring legitimacy on firms that may be breaking UK law, and may expose consumers to harm.

“Millions of football fans trust their club’s badge. Clubs should not let unauthorised financial firms exploit that loyalty by putting potentially dodgy products in front of millions of fans.”

Lucy Castledine, Director of Consumer Investments, FCA

The FCA letter also stated that funds received from an unauthorised firm ‘may also constitute criminal property under the Proceeds of Crime Act 2002.’

This is not a reputational warning. It is a statement about potential criminal liability. The FCA confirmed it has written directly to clubs where it has specific concerns, has engaged with the Premier League, and ‘will take action where needed.’

Source: FCA letter to Premier League clubs & FCA press release, 3 June 2026

Why this is happening now: the gambling shirt ban and the crypto rush

The context for today's warning is not hard to find. From the 2026/27 season, Premier League clubs can no longer display gambling brands on the front of matchday shirts, following a voluntary agreement reached in April 2023. The Premier League's own analysis estimated the ban would leave an estimated £80 million gap in club commercial revenues. Cryptocurrency firms and unregulated trading platforms moved aggressively to fill that gap.

The results are now visible across the top flight. According to reporting by Investigate Europe, a significant number of Premier League clubs in the 2025/26 season were sponsored by crypto and investment firms not listed on the FCA register of authorised firms. Chelsea extended its sponsorship with crypto exchange BingX in April 2026. Manchester City carries OKX on its sleeves. Newcastle United partners with VT Markets -- a trading company that has been on the FCA's warning list of unauthorised firms since 2023. Wolverhampton Wanderers were sponsored by LAK3 Company, also on the FCA warning list, before their relegation from the Premier League.

None of this is accidental. These firms specifically seek football partnerships because association with a Premier League badge confers the legitimacy that their regulatory status denies them. That is precisely the mechanism the FCA is now acting to close. And the liability that flows from enabling it sits, under POCA, with the club that accepted the money.

The legal exposure clubs may not have fully absorbed

The FCA letter is unusually direct about the legal risk. It identifies two categories of breach by the unauthorised firms involved: providing regulated financial services without FCA authorisation (in breach of section 19 of the Financial Services and Markets Act 2000), and making unauthorised financial promotions (in breach of section 21 FSMA). Both are criminal offences.

The club's exposure is threefold. First, POCA criminal property risk. If the funds received from a sponsor constitute the proceeds of criminal activity -- and providing regulated services without authorisation is a criminal offence -- accepting those funds may constitute handling criminal property under the Proceeds of Crime Act 2002. That is not a theoretical risk. The FCA stated it explicitly.

Second, financial promotion liability. A club that promotes its sponsor's financial products or services in its own communications -- social media posts, matchday programmes, LED perimeter advertising, shirt sleeve branding -- may itself be making an unauthorised financial promotion in breach of section 21 FSMA. The FCA letter specifically flags this: 'Football clubs' own promotional content relating to a sponsor's products or services may constitute a financial promotion.'

Third, reputational and banking consequences. Major correspondent banks increasingly treat professional football clubs as higher-risk clients. A club that has accepted sponsorship funds from an entity later found to be operating unlawfully faces not only regulatory scrutiny but the prospect of banking counterparties withdrawing services, enhanced due diligence requirements and the reputational consequences of public association with a firm that has harmed its customers.

What the FCA expects clubs to do -- and what good looks like

The FCA letter sets out a clear baseline expectation. It is worth treating this not as a minimum to satisfy but as a starting point for a robust sponsorship due diligence framework that will withstand scrutiny from the FCA, the IFR, the club's own bankers and, increasingly, the EU AML supervisory regime from 2029.

The FCA's baseline sponsorship due diligence steps — and what each really requires

1

Confirm FCA authorisation status.

Check the FCA Firm Checker (fca.org.uk/consumers/fca-firm-checker). If the firm is not on the register and does not qualify for an exemption, it cannot legally provide or promote financial services to UK consumers. This is non-negotiable. VT Markets has been on the FCA warning list since 2023. A club that signed with them after that date cannot claim it did not know.

2

Check the FCA Warning List.

A firm's absence from the warning list does not confirm it is acting lawfully. The FCA is explicit: clubs must always conduct their own checks. The warning list is a floor, not a ceiling.

3

Understand the nature of services offered.

Does the sponsor provide, facilitate or promote regulated financial activities — investment products, trading platforms, crypto exchanges, payment services? If so, FCA authorisation is required. A firm that positions itself as a ‘technology company’ or ‘data provider’ but operates a trading platform is not exempt.

4

Review the source of sponsorship funds.

Under EU Regulation 2024/1624, transactions with sponsors are one of the four transaction categories that bring football clubs inside the AML perimeter from July 2029. Source-of-funds and beneficial ownership verification for sponsors are regulatory requirements, not optional best practice. Starting that process now is good preparation.

5

Audit the club's own communications.

Every social media post, LED board display, programme advertisement or website banner promoting a financial sponsor's products is a potential financial promotion. The club's marketing and digital teams need clear guidance on what they can and cannot say about a sponsor's services.

6

Conduct ongoing monitoring.

The FCA does not just require upfront due diligence. It expects clubs to maintain ongoing monitoring throughout the sponsorship agreement. A firm that was not on the warning list when the deal was signed may appear on it during the contract term. There needs to be a process for catching that.

Source: FCA letter to Premier League clubs, 3 June 2026 — Lagom Sports Compliance commentary

Where this sits in the broader compliance picture

Today's FCA warning does not exist in isolation. It is the most visible signal yet of a fundamental shift in how football's commercial relationships are being scrutinised. That shift is operating simultaneously from multiple directions.

EU Regulation 2024/1624 brings professional football clubs formally inside the AML perimeter from July 2029. Under Article 3, transactions with sponsors are one of the four transaction types triggering full AML obligations -- customer due diligence, beneficial ownership verification, source-of-funds analysis, sanctions and PEP screening. A club that builds its FCA-compliant sponsorship due diligence framework now is building the foundation of its EU AML compliance simultaneously.

The Independent Football Regulator, operational since autumn 2025, has the power to attach discretionary conditions to a club's operating licence restricting its ability to accept funding it 'reasonably suspects is connected to serious criminal conduct' -- a provision that maps directly onto the POCA risk the FCA described this morning. The IFR has confirmed it is coordinating with the FCA on the sponsorship issue.

The Failure to Prevent Fraud offence, in force since September 2025, means larger clubs face criminal liability where fraud is committed for their commercial benefit. A sponsorship arrangement that involves an unauthorised firm making unlawful financial promotions -- and the club facilitating that promotion through its own communications -- sits uncomfortably close to that territory.

The thread connecting all of these is the same. Clubs that treat commercial partnerships as purely a revenue and brand question, without applying the same governance discipline to their counterparties that they apply elsewhere, are accumulating regulatory exposure across multiple frameworks simultaneously. The FCA warning issued this morning is the most immediate of those exposures. It will not be the last.

Act today. The FCA already has.

Lagom Sports Compliance works with football clubs on the sponsorship due diligence frameworks, AML compliance programmes and regulatory readiness assessments that the FCA, IFR and EU AML Regulation now require. The firm's advisory bench includes former bank and regulator-side professionals who have operated inside every one of the frameworks described in this article.

If your club has live sponsorship arrangements involving financial services firms -- crypto exchanges, trading platforms, payment providers, investment firms -- and you are not certain of their regulatory status, the starting point is the free compliance checker. It takes minutes. Given what the FCA published this morning, it is worth doing today.

For clubs ready to build a proper sponsorship due diligence and AML framework, our Readiness Assessment covers the full picture: FCA authorisation status checks, source-of-funds assessment, EU AML readiness and IFR alignment.

The FCA wrote to your club this morning. The question now is what your club writes back -- in its actions, not its correspondence.

Frequently asked questions: football sponsorship due diligence and the FCA warning

• What did the FCA warn football clubs about on 3 June 2026?

  The Financial Conduct Authority -- the UK's statutory regulator of financial services firms and markets -- wrote to every Premier League club and the broader professional football community on 3 June 2026, warning about sponsorship arrangements with firms operating cryptocurrency exchanges or trading platforms without FCA authorisation. The FCA stated it had seen an increase in football club partnerships with unauthorised firms, some of which appear to be operating unlawfully. It warned that clubs may face legal liability, money laundering risks and serious reputational damage, and that funds received from an unauthorised firm may constitute criminal property under the Proceeds of Crime Act 2002.

• What is the FCA and why does it have authority over football club sponsorships?

  The Financial Conduct Authority is the UK's statutory conduct regulator for financial services firms and markets, established under the Financial Services and Markets Act 2000. It has authority over football club sponsorships because firms providing financial services in the UK -- including crypto exchanges, trading platforms and investment firms -- require FCA authorisation to do so. When a football club accepts a sponsorship from such a firm, or promotes that firm's financial products and services in its own communications, it enters the regulatory perimeter of financial services law. The FCA's concern is that clubs are conferring legitimacy on firms operating unlawfully, exposing their fans to harm and potentially handling criminal property.

• Which football clubs have sponsorships with firms on the FCA warning list?

  According to reporting published on 3 June 2026, several Premier League clubs in the 2025/26 season had sponsorship arrangements with firms not on the FCA register of authorised companies. Newcastle United sponsors VT Markets, which has been on the FCA warning list since 2023. Wolverhampton Wanderers -- relegated at the end of 2025/26 -- were sponsored by LAK3 Company, also on the FCA warning list. Manchester City carries OKX on its sleeves and Chelsea extended a deal with BingX in April 2026; neither OKX nor BingX is listed on the FCA register of authorised firms. The FCA has not publicly named the specific clubs it has written to with particular concerns.

• What is POCA and how does it affect football club sponsorship income?

  The Proceeds of Crime Act 2002 (POCA) makes it a criminal offence to acquire, use or possess criminal property, or to enter into arrangements that facilitate the acquisition, retention, use or control of criminal property. Under the FCA's analysis, benefits obtained through the provision of regulated financial services without authorisation -- which is itself a criminal offence under section 19 of the Financial Services and Markets Act 2000 -- may constitute criminal property. A football club that receives sponsorship income from an entity operating such services unlawfully may therefore be handling criminal property under POCA, regardless of whether the club was aware of the unauthorised status. This is not a reputational risk. It is a potential criminal liability.

• What due diligence must a football club do on a financial services sponsor?

  Based on the FCA's stated baseline expectations, football clubs should: confirm the firm's FCA authorisation status using the FCA Firm Checker; check the FCA Warning List and conduct their own independent checks beyond it; assess whether the firm's products or services constitute regulated activities under UK law; verify the source of sponsorship funds; review the club's own communications to ensure they do not constitute unauthorised financial promotions; and maintain ongoing monitoring throughout the contract term. Under EU Regulation 2024/1624, which applies to football clubs from July 2029, sponsor transactions also trigger AML obligations including beneficial ownership verification, sanctions and PEP screening, and source-of-funds analysis.

• Can a football club be liable for promoting a sponsor's financial products on social media?

  Yes. The FCA explicitly flagged this risk in its June 2026 letter. Under section 21 of the Financial Services and Markets Act 2000, communicating a financial promotion in the course of business without FCA authorisation -- or without the promotion being approved by an authorised firm -- is a criminal offence. A football club's social media posts, website content, matchday programme features or LED perimeter advertising that promote a sponsor's financial products or services may constitute a financial promotion. The FCA warned clubs to take appropriate measures to ensure their own communications do not breach section 21 FSMA.

• Why are crypto firms targeting Premier League clubs now?

  The timing reflects two converging pressures. From the 2026/27 Premier League season, clubs can no longer display gambling brands on the front of matchday shirts following a voluntary industry agreement reached in April 2023. The Premier League estimated this would leave approximately £80 million in annual shirt sponsorship revenue to be replaced. Cryptocurrency exchanges and unregulated trading platforms have aggressively targeted that gap, offering commercial terms that reflect football's global marketing value. These firms specifically seek football partnerships because association with a Premier League club badge confers the legitimacy that their regulatory status denies them. The FCA is now acting to prevent that mechanism from operating.

• How does the FCA warning connect to EU AML Regulation 2024/1624?

  The FCA warning and EU Regulation 2024/1624 address overlapping risks from different regulatory directions. The FCA's concern is that clubs are accepting funds from unauthorised firms that may constitute criminal property under POCA, and facilitating unlawful financial promotions. EU Regulation 2024/1624 brings professional football clubs inside the formal AML perimeter from July 2029, with explicit obligations including customer due diligence, beneficial ownership verification and source-of-funds analysis on sponsor transactions -- one of the four Article 3 transaction categories. A club that builds a proper sponsorship due diligence framework in response to the FCA warning is simultaneously building the foundation of its EU AML compliance for 2029.