From regulation to reality: why football needs more than AML policies
Over the past decade, football has evolved into one of the world's most sophisticated commercial industries. Multi-million-euro player transfers. Cross-border ownership structures. International sponsorship agreements. Increasingly global agency networks. Together, these have transformed the sport into a complex financial ecosystem.
With that evolution comes opportunity. It also brings risk.
A sector that has, until now, sat outside the framework
For many years, anti-money laundering obligations focused almost exclusively on banks, payment institutions and other financial service providers. Football, despite handling significant financial flows and operating across multiple jurisdictions, remained largely outside that regulatory framework.
That is now changing.
The adoption of Regulation (EU) 2024/1624 -- AMLR -- as part of the European Union's new anti-money laundering legislative package represents a watershed moment for the sport. For the first time, professional football clubs and football agents become obliged entities in their own right, named directly under Article 3(3)(n), bringing them within the scope of Europe's AML regime and placing them alongside sectors that have long been expected to identify, assess and mitigate financial crime risk.
The rationale is well established, and it did not emerge with AMLR. Football's international nature, combined with high-value transactions, complex ownership structures and cross-border financial flows, creates vulnerabilities that criminal organisations have sought to exploit for many years. The Financial Action Task Force flagged this specifically as early as 2009, in its dedicated report Money Laundering through the Football Sector. That study, prepared with direct engagement from FIFA, UEFA and the International Olympic Committee and drawing on more than twenty case examples from twenty-five countries, identified three categories of vulnerability: structural factors, such as low barriers to entry and informal connections between business, sport and criminal networks; financing-related factors, reflecting the scale, speed and opacity of money moving through transfers, sponsorship and ownership; and cultural factors, describing an industry that had historically resisted the financial transparency and governance standards expected of comparable commercial sectors. Organisations including UNODC, INTERPOL, Europol and the Council of Europe have consistently echoed that assessment since.
Regulation alone will not solve the problem. The real challenge is implementation.
Why implementation, not policy, is the genuine test
Across financial services compliance more broadly, a consistent pattern has emerged over the past two decades: organisations invest considerable time developing policies that satisfy regulatory expectations on paper, without those policies ever influencing operational decision-making in practice. The documentation exists. The governance framework appears complete. Yet staff continue to make decisions without considering financial crime risk, because compliance has never actually become part of the organisation's own culture.
Football cannot afford to repeat that mistake, and the reason is structural, not merely cautionary. Unlike a bank, a football club operates through a genuine combination of sporting ambition, commercial strategy and community identity. Recruitment departments negotiate international player transfers involving multiple counterparties. Commercial teams secure sponsorship arrangements across jurisdictions with varying levels of AML maturity. Investors may sit behind sophisticated corporate structures spread across several countries. Agents routinely coordinate transactions involving clubs, players, intermediaries and commercial partners operating under different legal systems.
None of that is inherently suspicious. It is simply distinctive -- and that distinctiveness means football requires an AML programme designed around its own operational realities, rather than a framework borrowed wholesale from financial institutions and applied without adjustment.
The starting point: a genuine risk-based approach
A risk-based approach is one of the core principles underpinning both the FATF Recommendations and the wider EU AML framework, and it is the correct starting point for football specifically. Not every sponsorship agreement presents the same level of risk. Not every player transfer requires enhanced due diligence. Not every investor should be treated identically. The objective is not to eliminate risk altogether -- an unrealistic and, in practice, counterproductive goal for any sector -- but to understand it well enough to make genuinely informed decisions, and to direct resources toward where the risk actually concentrates rather than spreading them evenly across activity that does not warrant equal attention.
For some clubs, that will mean strengthening due diligence around beneficial ownership before accepting new investment. For others, the greater exposure may sit in commercial partnerships involving higher-risk jurisdictions, or in unusually complex payment structures within existing sponsorship or agent relationships. The right answer is club-specific, not a template applied uniformly across the sector.
Beneficial ownership: likely to become the defining compliance challenge in football
Clubs have traditionally focused on the sporting and commercial credentials of a potential investor. AML obligations require something considerably deeper: a genuine understanding of who ultimately owns or controls the legal entity actually entering into the relationship.
Layered holding companies, offshore investment vehicles and nominee arrangements are not automatically indicators of criminality. They do, however, require careful, genuine examination if an organisation is to satisfy both its regulatory obligations and its own underlying governance responsibilities -- an assessment that goes well beyond confirming a name on a share register, and directly connects to the ownership-interest and control tests AMLR itself sets out under Chapter IV.
Governance as a shared responsibility, not a departmental function
An effective AML framework cannot sit solely within a compliance department, and treating it that way is one of the more predictable ways an otherwise well-designed policy fails to translate into genuine protection. Boards need to understand their own accountability. Senior executives need to demonstrate clear, visible oversight, not delegate the entire question downward and consider the matter closed. Commercial teams need to genuinely appreciate why due diligence is more than an administrative step inserted into a deal timeline. Recruitment staff need to recognise the risk indicators associated with player transfers specifically. Finance teams need to identify unusual payment patterns before they harden into regulatory issues rather than after.
Compliance succeeds when responsibility is genuinely shared across an organisation. It fails, reliably, when it is delegated entirely to a single function and never asked to influence how the rest of the organisation actually operates.
Agents face a related but genuinely distinct challenge
Football agents encounter an equally important, though structurally different, version of this problem. Their business model is inherently international. They frequently represent multiple clients, facilitate cross-border negotiations, and receive commission payments from different sources across the lifecycle of a single transfer.
Determining who the customer actually is in a given transaction, when enhanced due diligence should apply, how commission structures should be assessed for risk, and when a suspicious activity reporting obligation genuinely arises, requires guidance built around the commercial realities of agency work specifically -- not a theoretical regulatory model imported from a different kind of business entirely. This is precisely the area where practical, sector-specific implementation guidance, rather than generic policy language, will do the most good.
A new relationship: football and the Financial Intelligence Units
Perhaps one of the least discussed, yet most significant, consequences of AMLR is the relationship it creates between football and national Financial Intelligence Units. Historically, these two communities have interacted only occasionally, if at all.
That is about to change.
Clubs and agents will increasingly become contributors to national AML intelligence frameworks through suspicious transaction reporting and other statutory obligations. At the same time, FIUs and national supervisory authorities will need to develop a genuinely deeper understanding of football's own commercial environment if the reporting this generates is to become intelligence-led, rather than a purely procedural box-ticking exercise on either side of the relationship.
This reflects a broader international trend that predates AMLR itself. In Resolution A/RES/79/8, adopted by consensus on 12 November 2024, the UN General Assembly called on Member States to enhance their efforts to prevent and fight corruption and organised crime in sport, and to facilitate the exchange of expertise and information within sports organisations and the sports community more broadly. The resolution sits within a wider, longstanding pattern of UN and Council of Europe attention to sport integrity -- including the Council of Europe's Macolin Convention, addressing the manipulation of sports competitions -- and reflects a shared recognition that safeguarding sport requires coordinated action between governments, regulators, law enforcement, sporting organisations and the private sector, not a single instrument acting alone.
Where success or failure will actually be determined
Financial integrity cannot be achieved through legislation alone, and it cannot be delivered solely through a compliance department acting in isolation from the rest of an organisation. It requires governance, commercial operations, legal advisers, regulators, Financial Intelligence Units and football's own stakeholders to develop a common understanding of risk, and a shared commitment to protecting the integrity of the game -- a genuinely collaborative effort, not a document produced once by one team and handed down to everyone else.
Trust
Supporters expect clubs to be managed responsibly.
Investors seek organisations with mature governance.
Commercial partners increasingly conduct their own due diligence before entering into sponsorship arrangements.
Strong financial integrity frameworks are therefore becoming more than a regulatory expectation to be satisfied and set aside. They are becoming a genuine indicator of institutional credibility -- one that supporters, investors and commercial partners are all, in their own way, already starting to look for.
Football has repeatedly demonstrated its ability to evolve, whether adapting to technological innovation, financial sustainability requirements, or wider governance reform. The move toward stronger AML standards should be viewed in the same light.
Not as another regulatory burden.
But as an opportunity to strengthen governance, reinforce public confidence, and protect the long-term integrity of one of the world's most influential industries.
Where Lagom can help
Lagom Sports Compliance works with football clubs and agents to turn AMLR's requirements into a genuinely operational compliance function -- not a policy binder that never leaves the compliance department. Our AML advisory work for clubs and agents covers the ground this article has set out directly: risk-based programme design calibrated to your club or agency's actual activity, beneficial ownership verification for complex or layered ownership structures, board and senior management training to build the genuine shared accountability effective AML compliance requires, and practical, sector-specific guidance for agents navigating commission structures, multi-party representation and reporting obligations that generic financial services frameworks were never built to address.
If your club or agency wants to move from having an AML policy to having a genuinely operational AML capability, get in touch to discuss what that looks like for your specific circumstances.
A policy that never leaves the compliance department has not protected anyone. Implementation is the whole exercise.
Lagom Sports Compliance is the UK's specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. We help clubs and agents build AML programmes that function in practice, not just on paper.
Frequently asked questions: implementing AML compliance in football
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A recurring pattern across financial services compliance more broadly is organisations investing significant effort in producing policies that satisfy regulatory expectations on paper, without those policies ever influencing day-to-day operational decision-making. Documentation and governance frameworks can appear complete while staff continue to make decisions without considering financial crime risk, because compliance has not genuinely become part of the organisation's own culture. Effective implementation requires shared accountability across an organisation -- board, senior executives, commercial teams, recruitment and finance -- rather than a policy owned solely by a compliance department.
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A risk-based approach, a core principle underpinning both the FATF Recommendations and the EU's AML framework, requires organisations to allocate compliance resources according to where genuine risk actually concentrates, rather than applying uniform scrutiny to every relationship or transaction regardless of its risk profile. For football specifically, this means recognising that not every sponsorship agreement, player transfer or investor relationship carries equivalent risk, and directing enhanced due diligence toward the areas -- often complex ownership structures, higher-risk jurisdictions, or unusually structured payment arrangements -- where it is genuinely warranted.
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Clubs have historically assessed prospective investors primarily on sporting and commercial credentials. AML obligations require a genuinely deeper analysis of who ultimately owns or controls the legal entity entering into the relationship, including through layered holding companies, offshore investment vehicles or nominee arrangements. None of these structures is automatically an indicator of wrongdoing, but each requires careful, substantive examination -- an assessment considerably more demanding than confirming a name on a shareholding register, and central to the ownership-interest and control tests AMLR sets out for beneficial ownership more broadly.
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The Financial Action Task Force's July 2009 report, Money Laundering through the Football Sector, prepared with direct engagement from FIFA, UEFA and the International Olympic Committee, identified three categories of vulnerability specific to the sport: structural factors, including low barriers to entry and informal connections between business, sport and criminal networks; financing-related factors, reflecting the scale, speed and opacity of money moving through transfers, sponsorship and ownership; and cultural factors, describing an industry that had historically resisted the financial transparency and governance standards expected of comparable commercial sectors. The report drew on more than twenty case examples from twenty-five countries.
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Agents face a distinct set of practical questions arising from the inherently international, multi-party nature of their business: determining who the customer actually is in a given transaction, when enhanced due diligence should apply, how commission structures should be assessed for risk, and when a suspicious activity reporting obligation arises. These questions require guidance built around the specific commercial realities of agency work -- multiple clients, cross-border negotiations, commission payments from varying sources across a transfer's lifecycle -- rather than a compliance framework designed for a different kind of business and applied without adjustment.
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Under AMLR, clubs and agents become contributors to national AML intelligence frameworks through suspicious transaction reporting and related statutory obligations, a relationship that has historically been minimal or non-existent between football and national FIUs. For this reporting to be genuinely useful rather than purely procedural, FIUs and supervisory authorities will also need to develop a deeper understanding of football's own commercial environment -- a two-way development this article treats as one of the most significant, if currently underdiscussed, consequences of AMLR's application to the sport.