Transfer-window AML risk: the five control failures we see most often in football clubs

The transfer window concentrates more financial crime risk into a shorter period than almost any other event in professional sport. Hundreds of millions of pounds move in weeks. Intermediaries multiply. Ownership structures that took months to construct are tested in days. And most clubs enter the window with controls that were not designed for it. Here are the five failures we see most consistently, and why each of them matters more than ever as the regulatory environment closes in.

The five AML failures covered in this article are:

1. No beneficial ownership check on the selling club or its holding structure

2. Agent fee payments approved without source-of-funds verification

3. Dual representation treated as an administrative formality

4. Third-party and image-rights vehicles accepted without ownership mapping

5. The window closes and the file disappears

The regulatory backdrop gives each of these failures sharper edges than they carried even two years ago. EU Regulation 2024/1624 brings professional clubs inside the AML perimeter from July 2029, with explicit obligations covering transactions with investors, sponsors, agents and transfer counterparties. The Independent Football Regulator is already operational, with its source-of-wealth test for owners live since May 2026. HMRC's football taskforce recovered more than £384 million in unpaid tax between 2019 and 2024, with £67.5 million in 2023/24 alone. The controls that clubs are failing to run are the same ones that regulators and prosecutors are now specifically looking for.

AML failure 1  - No beneficial ownership check on the selling club or its holding structure

A transfer fee paid to a selling club is, in AML terms, a transaction with a counterparty. The obligation under EU Regulation 2024/1624 is clear: clubs must identify and verify the beneficial ownership of counterparties to transfer transactions. In practice, the vast majority of clubs treat the selling club as a known entity and stop there. They do not look through the holding structure above it.

This is where the risk concentrates. It is not unusual for a professional football club to be owned through three, four or five layers of intermediate holding companies, some of them registered in opaque jurisdictions with minimal public beneficial ownership registers. A buying club that pays a transfer fee to a club whose ultimate beneficial owner is a sanctioned individual, a PEP with undisclosed government connections, or a vehicle connected to proceeds of crime has a problem that does not disappear because it did not look.

The FATF's typologies report on money laundering through the football sector identified manipulation of transfer valuations and the routing of transfer payments through multi-layered corporate structures as among the primary mechanisms by which criminal funds enter football. Spanish authorities uncovered a criminal network in 2020 that used ghost transfers between European clubs to launder EUR 10 million through precisely this mechanism. The risk is not theoretical.

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Watch for

• Selling club's ownership structure has changed in the preceding 12 months
• Intermediate holding companies in jurisdictions with weak beneficial ownership registers
• Transfer fee routed to a third party rather than directly to the selling club
• Unusual urgency to close the financial elements of the deal

AML failure 2 - Agent fee payments approved without source-of-funds verification

Agent fees reached USD 1.37 billion in men's professional football in 2025. That is a sum large enough to attract serious criminal interest, and the payment flows involved are among the most structurally complex in football. An agent fee is not paid to a natural person sitting behind a desk. It is paid to an agency, which may be incorporated in a jurisdiction the buying club has never investigated, operated by beneficial owners who have never been verified, and in some cases structured to route funds through intermediate entities before reaching the individual who actually represented the club.

The failure here is not malice. It is process. Clubs approve agent fee payments as part of the deal workflow, typically after negotiations have concluded and legal documents are being finalised. The compliance question -- who actually owns this agency, where will these funds go, and is the source of this entity's business legitimate -- is rarely asked at the point in the process where the answer is still practically relevant.

HMRC has been explicit about the associated risks. Its investigations into dual representation arrangements, where an agent nominally acts for both clubs in a transaction, have recovered substantial sums, with the taxman treating the club's share of the fee as a disguised payment to the player where genuine dual service cannot be demonstrated. The AML dimension goes further: an agent payment that cannot be verified as flowing to a legitimately owned and operated entity is a payment with an unverified counterparty. That is not a threshold that the regulatory environment of 2029 will tolerate.

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Watch for

• Agency incorporated in the preceding 12 months with minimal trading history
• Payment destination is a jurisdiction with no public beneficial ownership register
• Agent entity is different from the licensed agent named in the contract
• Fee is unusually large relative to the services described
• Requests to split fee across multiple payees or jurisdictions

AML failure 3 - Dual representation treated as an administrative formality

Dual representation, where a single agent acts for both the buying and selling club, or for both club and player, in a single transaction, is disclosed on the paperwork. Clubs sign the dual representation consent. The fee is paid. The file is closed. What most clubs do not do is apply meaningful scrutiny to whether the claimed dual service is genuine, and what the actual flow of the remuneration represents.

This matters for two reasons that compound each other. First, as HMRC has established through years of investigation, dual representation is frequently used to route additional value to players outside of their employment contract -- avoiding income tax, National Insurance and VAT. Second, from an AML perspective, a fee payment that does not correspond to genuine services rendered is a payment whose stated purpose is not its actual purpose. That is one of the defining characteristics of a suspicious transaction.

EU Regulation 2024/1624 requires clubs to monitor transactions, maintain records and file suspicious activity reports where warranted. A dual representation arrangement where the agent's work for the club cannot be documented independently of their work for the player is exactly the kind of transaction that an AML-compliant club needs to interrogate, not countersign on sight.

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Watch for

• Agent has a long-standing relationship with the player but no prior engagement with the buying club
• Services described in the club’s representation agreement are vague or replicate the player’s agreement
• Fee split between club and player representation is unequal without a documented rationale
• Agent resists providing documentation of specific services delivered to the club

AML failure 4 - Third-party and image-rights vehicles accepted without ownership mapping

FIFA banned new third-party ownership of players' economic rights in 2015 under RSTP Article 18bis. The rule is clear. Its enforcement is imperfect, and the vehicles that were structured before the ban, and those that have since been constructed to achieve similar economic outcomes through image-rights companies and commercial arrangements, remain in the market. A buying club that does not ask who sits behind those vehicles is taking a risk it has not measured.

The scenario plays out like this: a transfer is agreed, and buried in the deal structure is a payment obligation to an image-rights company in a Caribbean jurisdiction that holds a percentage of the player's commercial income. The club's legal team reviews the player contract. Nobody maps the beneficial ownership of the image-rights vehicle. Nobody asks where the funds that originally capitalised that structure came from. Nobody checks whether the individuals behind it have connections to sanctioned persons, PEPs or criminal networks.

This is not hypothetical. Portuguese authorities' Operation Red Card in 2019 examined a transfer from Porto to Real Madrid worth EUR 50 million, of which EUR 21.6 million was accounted for by payments to agents and intermediary structures. The investigation turned on precisely the question of who these vehicles were, who owned them, and whether the flows were consistent with legitimate commercial activity. Clubs involved in transfers with similar structures today face the same question from regulators, whether they know it or not.

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Watch for

• Image-rights company incorporated in a jurisdiction with minimal transparency
• Beneficial owner of the image-rights or commercial vehicle is not the player
• Structure was established shortly before the transfer was agreed
• Payment to the vehicle is a condition of completing the player’s transfer
• Club cannot obtain satisfactory documentation of the vehicle’s ownership chain

AML failure 5 - The window closes and the file disappears

The most common AML failure in football transfer activity is not a failure of due diligence at the point of transaction. It is a failure of record-keeping after it. When the window closes and the players are registered, the documents that were gathered during the deal -- ownership information, source-of-funds representations, agent KYC, beneficial ownership certificates -- are filed, archived or simply not retained in any organised form. They are not reviewed. They are not refreshed. When circumstances change -- when a new investor buys into the selling club, when an agent's licence is suspended in another jurisdiction, when sanctions are imposed on an associated party -- nobody checks whether the file is still clean.

EU Regulation 2024/1624 requires ongoing monitoring of business relationships, not point-in-time checks. The AMLR's record-keeping obligations require that due diligence documentation is maintained and kept current. A club that conducted a reasonable owner check at the time of a transfer in 2027 and then filed it away permanently is not compliant by 2029. Compliance is a continuous obligation, not a closing condition.

The practical consequence is that a club faces a regulatory examination and cannot demonstrate that its counterparty relationships remain clean. It has no audit trail showing that its monitoring obligations were met between transactions. It has no way of proving that it would have identified a red flag if one had materialised. In that situation, the absence of evidence is not a defence. It is the problem.

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Watch for

• No central, searchable repository for transfer counterparty due diligence
• Ownership records were gathered but not verified against a live sanctions or PEP screen
• No documented process for refreshing counterparty files when circumstances change
• No one in the club has ownership of the ongoing monitoring obligation post-window

Five failures. One starting point.

If any of the five failures described above is recognisable from your club's current process, or if you are not certain whether it is, that is the answer you need. Lagom Sports Compliance works with clubs of all sizes to design transfer-window AML controls that are proportionate, football-native and defensible under EU Regulation 2024/1624, the IFR framework and the scrutiny of banks, auditors and regulators.

The starting point is the free compliance checker: a rapid read on where your club stands against the most material AML requirements, including transfer-window controls. No obligation, no cost.

For clubs ready to build, our Readiness Assessment delivers a football-specific gap analysis and prioritised remediation roadmap, credited in full against any subsequent framework implementation. Whether you need a Readiness Assessment or not, we can also support clubs by building them a fully compliant and defensible AML Framework.

The transfer window opens on a schedule. The compliance clock does not pause while it does.

Frequently asked questions: AML risk in football transfer windows

• What are the main AML risks in football transfers?

  The main AML risks in football transfers cluster around five areas: failure to verify the beneficial ownership of the selling club and its holding structure; agent fee payments to entities whose ownership has not been verified; dual representation arrangements that may obscure the true nature of payments; third-party and image-rights vehicles accepted without ownership mapping; and inadequate record-keeping after the window closes. EU Regulation 2024/1624, which applies to football clubs from July 2029, explicitly covers transactions with investors, sponsors, football agents and transfer counterparties as the four categories triggering AML obligations.

• Do football clubs have to check the beneficial ownership of the clubs they buy players from?

  Under EU Regulation 2024/1624, yes. Article 3 defines transactions for the purpose of a player transfer as one of the four transaction types that bring professional football clubs within the AML perimeter. Clubs must identify and verify the beneficial ownership of counterparties to those transactions, including the selling club and any holding structure above it. Simply treating the selling club as a known entity without looking through its ownership chain is not sufficient where any element of the structure raises a risk flag.

• What is the AML risk with agent fees in football transfers?

  Agent fees represent a significant financial flow, USD 1.37 billion in men's professional football in 2025, routed through agencies that are frequently incorporated in opaque jurisdictions and whose beneficial ownership is rarely verified by paying clubs. The AML risk arises when payment is made to an entity whose true beneficial ownership has not been established, whose stated purpose does not match its actual economic function, or where the fee is structured in a way inconsistent with the services described. Dual representation arrangements, where an agent acts for both clubs in a transaction, carry additional risk of obscuring the true nature and destination of payments.

• Is dual representation in football a money laundering risk?

  Dual representation is a significant AML risk indicator in the context of football transfers. HMRC has established through enforcement action that dual representation fees are frequently used to route additional value to players outside their employment contracts. From an AML perspective, a fee payment that does not correspond to genuine services rendered is a transaction whose stated purpose does not reflect its actual purpose, a core suspicious transaction indicator. EU Regulation 2024/1624 requires clubs to monitor transactions and file suspicious activity reports. Dual representation arrangements that cannot be supported by independent documentation of genuine services to the club warrant heightened scrutiny.

• What AML controls should a football club have for transfer window transactions?

  A proportionate AML control framework for transfer window transactions should include: a beneficial ownership identification and verification process for all counterparties to transfers, covering the selling club's holding structure; a source-of-funds and source-of-wealth check on agent entities before fee payments are approved; a due diligence process for third-party vehicles, image-rights companies and other intermediary structures that receive value as part of a deal; sanctions and PEP screening against all material counterparties; a record-keeping system that maintains due diligence documentation and supports ongoing monitoring post-window; and a designated senior person with responsibility for the AML sign-off on each transfer.

• How long do football clubs need to keep AML records from transfer transactions?

  EU Regulation 2024/1624 requires obliged entities to retain customer due diligence records and transaction documentation for a minimum of five years from the end of the business relationship or the date of the transaction. Ongoing monitoring obligations also require that records are kept current, a file that was accurate at the time of a 2027 transfer needs to reflect any subsequent material changes in the counterparty's ownership or risk profile. Clubs should maintain a central repository for transfer counterparty due diligence with clear ownership of the ongoing monitoring obligation.

• What are the consequences for a football club that fails its AML obligations on a transfer?

  From July 2029, failure to meet AML obligations under EU Regulation 2024/1624 exposes football clubs to regulatory sanctions from national competent authorities, coordinated by AMLA. These can include financial penalties, administrative sanctions and, in serious cases, referral for criminal investigation. In practice, the near-term consequences for many clubs are more immediate: banks and payment service providers increasingly apply enhanced due diligence to football clients, and a club that cannot demonstrate clean counterparty documentation may find transfers delayed or financing withdrawn. Reputational damage from association with a counterparty later found to have criminal connections is also a material risk, regardless of the regulatory timeline.