An open letter to Gianni Infantino: why FIFA needs independent financial crime oversight, and our proposal to help

Dear Mr Infantino,

Football has just concluded its largest World Cup, and by most measures a hugely successful one. Forty-eight teams, a record prize pool, and, as FIFA's own Integrity Task Force confirmed this week, all 104 matches monitored in real time for suspicious betting activity with nothing found. That is a genuine achievement and it reflects a serious well-resourced integrity operation that football, and the wider sporting world, should be grateful for.

It is precisely because that operation is so evidently capable that we write to you now about a different kind of integrity: financial crime governance. Not match-fixing. Not betting fraud. The quieter, less visible work of anti-money laundering compliance, beneficial ownership verification, source-of-wealth scrutiny and sanctions screening -- the standards that the world's regulated financial institutions, and increasingly its football clubs and agents, are now required to meet, and that FIFA, as the sport's global governing body, has the opportunity to lead on rather than simply watch unfold at national and regional level.

The same rigour FIFA brings to protecting a match result should extend to protecting the money that flows through the game.

A capability that exists, and a gap that sits beside it

The Integrity Task Force's work this summer is worth dwelling on for a moment, because it demonstrates something important: when FIFA decides a form of integrity matters enough, it can build genuinely sophisticated, multi-agency infrastructure to protect it. The Task Force for this tournament included the FBI, INTERPOL, the United Nations Office on Drugs and Crime, the Council of Europe, national competition authorities and specialist sports-data providers, all coordinating in real time. That is not a modest undertaking, and it is to FIFA's credit.

What that same infrastructure does not yet extend to, as far as the public record shows, is an equivalent standing capability for financial crime  (the movement of money through transfer fees, agent commissions, sponsorship structures, club ownership vehicles and investment flows that now run to billions of dollars annually across global football). This is not a criticism unique to FIFA; it reflects a gap the entire sport has been slow to close. But FIFA, uniquely, is positioned to close it at the level that actually matters: globally, consistently, and before individual confederations and member associations are left to build inconsistent standards of their own.

Why this moment, specifically

We recognise this letter arrives at a moment when FIFA's own governance and transparency are already the subject of public scrutiny. European lawmakers wrote to FIFA's Ethics Committee earlier this month raising concerns about political neutrality, transparency and accountability, and the tournament just concluded has drawn its own share of public criticism over ticket pricing and commercial arrangements. We do not raise these matters to pile on, they are well covered elsewhere, and it is not our place to adjudicate them. We raise them only because they illustrate a broader point: an organisation under this level of public attention has a genuine opportunity, right now, to demonstrate leadership on the one governance dimension that is entirely within its own control and free of political entanglement, financial crime prevention. It is difficult to imagine a more universally welcomed initiative from FIFA at this moment than a credible, independently supported commitment to global best practice on anti-money laundering and financial transparency.

What global best practice actually looks like, and where FIFA could lead

The European Union's AMLR, Regulation 2024/1624, does not apply directly to FIFA, which is a Swiss-incorporated association rather than an EU obliged entity. But it does not need to apply directly for its standards to be instructive. AMLR represents the most comprehensive anti-financial crime framework any major jurisdiction has yet applied to football specifically: from 10 July 2029, it brings professional football clubs and agents within the EU's obliged entity regime for the first time, requiring a designated compliance officer, documented risk-based due diligence, beneficial ownership verification and ongoing monitoring. FIFA does not need to wait for a regulator to compel it toward these standards. It could adopt them voluntarily, at global level, well ahead of any jurisdiction's enforcement deadline -- and in doing so, set the benchmark the rest of the sport eventually follows, rather than the other way round.

There is a second, more specific reason this is a timely moment to look closely at governance around player representation. The Court of Justice of the European Union's ruling in Case C-209/23 (a preliminary ruling on FIFA's own agent regulations) does not, by itself, annul those regulations, and we are careful not to overstate what the judgment establishes. But it does provide the EU-law framework that the referring national court must now apply, including conclusions on data protection that may narrow what personal data can be disclosed or published through FIFA's agent platform. Whatever the ultimate national court outcome, the case is a clear signal that the intersection of agent regulation, data handling and financial oversight deserves closer, more independent attention than it has so far received, precisely the kind of intersection where specialist support adds the most value.

Our proposal, in outline

We would welcome the opportunity to support FIFA in developing and implementing a global anti-financial crime framework, built on the following principles.

1

A designated financial crime compliance function.

Modelled on the compliance officer and MLRO structure AMLR will require of clubs and agents from 2029, but implemented at FIFA level now -- giving the organisation the same kind of dedicated, senior ownership of financial crime risk that it already applies to match integrity.

2

A risk-based due diligence framework for club ownership and investment flows.

Extending the principle already embedded in national regulatory regimes, including England's own Independent Football Regulator, that those acquiring influence or control over football clubs should be subject to genuine source-of-wealth and beneficial ownership scrutiny, applied consistently across confederations rather than left to vary by jurisdiction.

3

Beneficial ownership and source-of-funds standards for agent transactions.

Addressing the transfer and commission payment typologies that AML practitioners across football consistently identify as higher-risk, and doing so through a framework FIFA itself governs rather than one imposed piecemeal by individual national regulators.

4

An independent review of the agent platform's data governance in light of Case C-209/23.

Using the CJEU's ruling as the occasion, not the cause, for a proactive assessment of how personal data is collected, disclosed and published through FIFA's own systems -- getting ahead of the national court's eventual application of the ruling rather than waiting for it.

Lagom Sports Compliance | Proposal to FIFA

A respectful close

We make this proposal in good faith and without presumption. FIFA has built genuinely impressive integrity infrastructure where it has chosen to prioritise it, and the Integrity Task Force's work this summer is proof of what is possible when the organisation applies itself to a specific form of protecting the game. We believe financial crime governance deserves the same priority, the same rigour and, if FIFA judges it useful, the same willingness to draw on independent, specialist expertise built specifically for football rather than adapted from another sector.

We would welcome the opportunity to discuss this proposal further, at whatever level and pace FIFA considers appropriate.

Yours sincerely,

Jonathan Greenstein and Isabel Lemes

Co-founders and Directors, Lagom Sports Compliance

About Lagom Sports Compliance

Lagom Sports Compliance is the leading governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. Founded by Jonathan Greenstein and Isabel Lemes, the firm advises clubs, agents, leagues and governing bodies on compliance with the EU's Anti-Money Laundering Regulation, the UK's Independent Football Regulator licensing regime, and UEFA's Club Licensing and Financial Sustainability Regulations. Its name, Swedish for "not too much, not too little, just right", reflects its underlying philosophy: proportionate, practitioner-led compliance built specifically for football, not adapted from another industry. The firm's guiding principle is that it is not there to say no. It is there to help football, at every level, get to a compliant yes.

This article is brought to you by Lagom Sports Compliance -- the leading governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. We help clubs, agents and leagues navigate the IFR, UEFA licensing and EU AML obligations with proportionate, practitioner-led support.

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Frequently asked questions: Football and financial crime governance

• Does FIFA have anti-money laundering standards?

  FIFA has built a well-resourced integrity operation focused on match-fixing and betting-market manipulation, including a multi-agency Integrity Task Force that monitored all 104 matches of the FIFA World Cup 2026 in real time. As a Swiss-incorporated association, FIFA is not directly bound by the EU's Anti-Money Laundering Regulation (AMLR) in the way individual football clubs and agents operating within the EU will be from 10 July 2029. There is no publicly documented equivalent to FIFA's betting-integrity infrastructure specifically dedicated to financial crime, beneficial ownership verification or source-of-wealth scrutiny at the global governing body level.

• Is FIFA subject to EU AML regulation?

  Not directly. EU Regulation 2024/1624 applies to obliged entities within the EU's regulatory perimeter, including football clubs and agents operating in EU member states from 10 July 2029. FIFA, as a Swiss-incorporated association headquartered outside the EU, is not itself an obliged entity under the regulation. However, the standards AMLR sets -- a designated compliance officer, risk-based due diligence, beneficial ownership verification -- represent a template FIFA could choose to adopt voluntarily at global level, ahead of any jurisdiction's enforcement deadline.

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• What did the Court of Justice of the European Union rule on FIFA's agent regulations?

  In Case C-209/23, a preliminary ruling, the Court of Justice provided the EU-law framework for interpreting FIFA's agent regulations, which the referring national court must now apply to the underlying dispute. The ruling does not, by itself, annul FIFA's agent regulations as a whole. Any conclusions the Court reached on data protection may narrow the scope of personal data that can be disclosed or published through FIFA's agent platform, but do not establish, without more, that the entire platform or its underlying data processing is unlawful. Any cap-specific or fully detailed conclusion should be assessed against the full judgment in an official-language version.

• What is the FIFA Integrity Task Force and what does it cover?

  The FIFA Integrity Task Force is a multi-agency body established to safeguard FIFA competitions against match manipulation. For the FIFA World Cup 2026, its members included national confederations, the FBI, INTERPOL, the United Nations Office on Drugs and Crime, the Council of Europe, national competition authorities and specialist sports-data and betting-integrity providers, monitoring betting markets and on-field activity in real time across all 104 tournament matches. Its published scope is specifically match manipulation and suspicious betting activity, not financial crime, money laundering or ownership integrity.

• Who regulates financial crime risk in football more broadly?

  Regulation currently operates unevenly across football. In England, the Independent Football Regulator assesses owner and officer suitability, including source of wealth, for regulated clubs under the Football Governance Act 2025. Within the EU, AMLR will bring football clubs and agents within its obliged-entity regime from 10 July 2029. UEFA's Club Licensing and Financial Sustainability Regulations address financial sustainability at competition level. No global governing body currently applies an equivalent, consistent financial crime standard across the sport as a whole, which is the specific gap this letter addresses.