AML Proportionality for Smaller Football Clubs | EU 2024/1624

Proportionality is the word smaller clubs are quietly hoping will let them off the hook. It will not. EU Regulation 2024/1624 does build in a genuine, legally grounded principle of proportionate compliance, but most clubs do not know what that principle actually requires of them, do not have the in-house capability to apply it, and are running out of time to find out. This article explains what proportionality really means, what it really demands, and what a right-sized compliance framework looks like in practice.

Foundational reading: If you are new to EU Regulation 2024/1624 and its application to football, start with our overview article EU AML 2024/1624: What professional football clubs need to know before 2029 before reading on.

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The three things most smaller clubs do not know

In conversations across the professional football landscape, a pattern repeats with striking consistency. Ask a CEO or CFO at a League One club, a second-tier Bundesliga side or a Portuguese second-division club whether they are aware that EU Regulation 2024/1624 applies to them and you will typically encounter one of three responses.

The first is straightforward ignorance: the regulation has not crossed their desk. They may have seen a headline. They have not read the legislation or sought advice. They are operating on the assumption that AML is something banks do, not football clubs.

The second is qualified dismissal: they have heard about the regulation but assume it applies to 'the big clubs', the Champions League participants, the Premier League giants, and that smaller clubs will be exempted or excused. This is the most dangerous misconception of the three, because it contains a grain of truth that obscures the larger reality.

The third is awareness without capacity: they know the regulation applies, they accept in principle that something needs to be done, but they have no one in-house qualified to do it, no budget allocated for it and no clear idea of where to start.

All three of these clubs are in the same position: behind the curve, with less time to recover than they think. And all three of them are making a fundamental error about what 'proportionality' actually means.

Where proportionality actually comes from in the regulation

Proportionality in EU Regulation 2024/1624 is not a vague political aspiration. It is a legally grounded principle that appears repeatedly and explicitly throughout the regulation's text, recitals and the regulatory technical standards that AMLA is currently developing.

Recital 24 of the regulation states that clubs should put in place 'robust anti-money laundering measures', including due diligence on investors, sponsors and counterparties. It also notes, specifically, that to 'avoid any disproportionate burden on smaller clubs that are less exposed to risks of criminal misuse, Member States should be able to exempt certain professional football clubs from the requirements of this Regulation, whether in full or in part.' Recital 25 adds nuance: even lower-division clubs 'can also be exposed to significant risks of money laundering', and exemptions for them require a proven low-risk finding, not an assumed one.

The April 2026 AMLA guidelines consultation on business-wide risk assessment is equally clear: minimum expectations apply to all obliged entities, across both financial and non-financial sectors, while explicitly 'allowing for proportionality based on the entity's size, business model and risk profile.' The March 2026 AMLA consultation on customer due diligence regulatory technical standards explicitly sought 'special focus on ensuring that the non-financial sector's views are captured', a signal that the regulator is actively calibrating these standards for entities like football clubs.

The critical point is this: proportionality under EU 2024/1624 does not mean 'smaller clubs do less'. It means 'smaller clubs do what is appropriate to their actual risk profile, properly assessed and documented.' That is a meaningfully different thing. It is not a lighter obligation. It is a differently shaped one.

Exemption Warning Box

The exemption is not yours to grant yourself

The most common misreading of the regulation among smaller clubs is treating the Article 5 exemption as if it is a default. It is not. Under Article 5, Member States may exempt certain clubs -- but only on the basis of a formal national risk assessment demonstrating proven low risk. The exemption is granted by a supervisory authority following that process. It is not claimed by the club on its own initiative.

A club that assumes it is exempt, without having engaged with the national supervisory authority and without having been formally notified of an exemption decision, is not exempt. It is non-compliant.

What proportionality requires in practice: the risk-based approach

The mechanism that makes proportionality work in the AMLR is the risk-based approach. Rather than prescribing identical controls for every obliged entity regardless of size, the regulation requires each entity to assess its own risk profile and calibrate its controls to match that profile. Controls that are too light for the actual risk level are non-compliant. Controls that are disproportionately heavy for a genuinely lower-risk entity are not required, but that lower risk still needs to be demonstrated, not assumed.

For a smaller football club, a risk-based approach means working through a structured set of questions:

Risk Factors

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Higher risk factors that increase obligations

Foreign or opaque ownership structures
Investors based in high-risk jurisdictions
Active international transfer market
Cross-border sponsorship or commercial deals
Agent commission flows through offshore vehicles
PEP-connected investors or board members
Club under financial pressure (susceptibility risk)

▼

Lower risk factors that may support a simplified approach

Domestic ownership, fully transparent structure
No international transfers in prior two seasons
Sponsor relationships with established UK/EU corporates
No agent fee flows above nominal amounts
Turnover entirely from domestic gate and broadcasting
No third-party investment interest
Formally assessed and documented by a qualified adviser

The critical word in that second column is 'documented'. Simplified due diligence, the lighter-touch approach the AMLR permits for genuinely lower-risk relationships, is not a free pass. Article 33 of the regulation permits simplified measures only where a low risk has been identified under harmonised criteria. Those criteria need to be applied, assessed and recorded. The assessment needs to be revisited when circumstances change. A club that benefits from a simplified approach in 2029 but then brings in a new investor from a high-risk jurisdiction in 2030 must update its assessment and escalate its controls accordingly.

A brief worked example: what this looks like for a League One club

Consider a League One club in England, call it a mid-sized club with an average gate of around 7,000, domestic ownership through a straightforward limited company, a playing budget funded by the EFL's solidarity payments and modest gate income, and no international transfer activity in the past two seasons. They do have one live situation: a local businessman has approached the chairman about a minority investment of £500,000.

Under EU Regulation 2024/1624, and bearing in mind that the UK's own framework is tightening alongside it, this club needs to do the following in respect of that investor transaction:

Identify the investor and verify their identity. Name, date of birth, address and identity document. Standard, but it needs to be done and recorded.
Identify the beneficial owner. Who ultimately owns or controls the investor? If the investor is an individual investing personally, this is straightforward. If there is a company or structure involved, the beneficial ownership chain needs to be traced to the natural person in control.
Screen for sanctions and PEP status. Is the investor, or any person behind the ownership structure, subject to sanctions or a politically exposed person? This requires a screening check against current lists, with the result documented.
Assess the source of funds and source of wealth. Where is the £500,000 coming from? And where did the investor's wealth originate? For a straightforward domestic business owner, this may require asking a few structured questions and retaining supporting documentation. It does not require a forensic investigation, but it does require something on file.
Make a documented decision. Based on the above, the club records whether the investor is acceptable, at what risk level, and what ongoing monitoring is appropriate. If anything is unclear, the question goes to the designated senior person responsible for AML, which, at a smaller club, needs to be someone.

None of those five steps requires a bank-sized compliance team. The investor in this example is likely straightforward, the risk low, and the documentation process relatively brief. But all five steps need to happen, they need to be recorded, and the person doing them needs to know what they are doing. That is the difference between proportionate compliance and no compliance at all.

The capability and capacity problem most clubs are not admitting

The uncomfortable truth that sits behind the three scenarios described at the start of this article is that proportionate compliance, even at its lightest, requires something most smaller clubs currently do not have: a person who is qualified to make AML judgements, time allocated for that person to apply them, and a documented process that holds up when the regulator, a bank or a counterparty asks to see it.

This is not a criticism. It reflects the reality of how most football clubs below the top flight are structured. Finance functions are lean. Legal resource is typically external and episodic. There is no head of compliance, no MLRO equivalent, no one who has sat inside an AML framework before. The regulation is asking these organisations to build, from scratch, a capability that financial institutions have been developing and refining for thirty years.

The three failure modes play out predictably in this context. The club that does not know it is affected will do nothing and face supervisory action when the 2029 deadline passes. The club that believes it will be exempt will do nothing, find that the exemption is not available or has not been granted, and scramble in 2028 among a market of scarce qualified advisers at premium prices. The club that knows it needs to act but lacks in-house capacity will delay until the task feels urgent enough to justify the cost, by which point the cost will be higher and the time shorter.

The answer to a capability and capacity problem is not to hire a full-time AML director. For most clubs below the top flight, that is not proportionate and it is not necessary. The answer is to access the right expertise externally, in a format sized to the club's actual risk and budget. That is precisely what a proportionality-based advisory model is designed to deliver.

What AMLA is building and why smaller clubs need to watch it closely

AMLA is not a distant institutional body producing documents that will never affect a League One club. It is actively shaping, right now, the practical standards that will govern how all obliged entities, including smaller football clubs, are supervised from 2029 onwards.

In March 2026, AMLA published its consultation on draft regulatory technical standards for customer due diligence, explicitly seeking non-financial sector input to ensure the standards are workable for entities like football clubs. In April 2026, it published draft guidelines on business-wide risk assessment, setting minimum expectations for how obliged entities identify and document their risk profiles, with proportionality for smaller entities explicitly built in. Around 40 regulatory products in total are expected from AMLA, with approximately half already issued and the remainder due by July 2027.

These standards will define, in concrete terms, what a proportionate AML framework looks like for a non-financial obliged entity of a given size and risk profile. Clubs that have begun their readiness work will be able to align with those standards as they are published. Clubs that have not started will find themselves trying to implement a framework against a fully formed regulatory standard, under time pressure, without institutional familiarity with the language and requirements involved.

Proportionate. Practical. Built for football.

Lagom Sports Compliance exists precisely because of the gap this article describes. The firm's name is the point: lagom is Swedish for 'not too much, not too little, just right'. The Lagom model delivers football-native AML compliance sized to the actual risk of the club, not a bank framework transplanted into a football context, and not nothing.

The starting point for any club uncertain about its position is the free compliance checker. It takes minutes, requires no commitment, and tells you where you stand against EU AML 2024/1624 expectations right now.

For clubs ready to move beyond the self-assessment, our Readiness Assessment delivers a fixed-scope diagnostic: a football-specific risk mapping, gap analysis against the regulation, and a prioritised remediation roadmap that tells you exactly what a proportionate framework for your club looks like. The fee is credited in full against any subsequent implementation work.

Clubs that need a full AML framework built can explore Lagom Sports Compliance’s AML Framework Development support. For clubs that need ongoing AML support without the cost of an in-house hire, our AML Outsourcing and Resourcing Support provides a fully outsourced AML function, the answer to a capacity problem that does not require a full-time appointment.

Proportionality is not an exemption. It is a standard. And it starts with knowing where you actually stand.

Frequently asked questions: proportionality and smaller clubs under EU AML 2024/1624

Yes. EU Regulation 2024/1624 applies to all professional football clubs in respect of four specific transaction types: transactions with investors, sponsors, football agents or other intermediaries, and transactions for the purpose of a player transfer. There is no automatic exemption for smaller clubs. The Article 5 exemption is available only where a national supervisory authority has formally assessed a club as lower risk. It is not a default position that a club can assume for itself.
Proportionality means that the intensity of AML controls should reflect the actual risk profile of the entity applying them. A smaller club with a simple ownership structure, domestic operations and limited transfer activity does not need to operate the same framework as a Champions League club with complex multi-layer ownership and EUR 200 million in annual transfer spend. However, proportionality requires a documented, risk-assessed basis for applying lighter controls. It does not mean doing nothing. A club applying simplified due diligence must be able to demonstrate that a lower risk was properly assessed and recorded.
Simplified due diligence (SDD) is a lighter-touch set of customer due diligence measures permitted under Article 33 of EU Regulation 2024/1624 where a business relationship or transaction presents a genuinely low degree of risk. For a football club, SDD might apply to a straightforward transaction with a well-established domestic sponsor with fully transparent ownership and a long commercial history. It requires that the lower risk be identified under harmonised criteria, documented, and reassessed when circumstances change. SDD is not available simply because a club is small or because a transaction is low in value.
Article 5 of EU Regulation 2024/1624 allows Member States to exempt certain clubs from the regulation's requirements, in full or in part. For top-division clubs, an exemption requires annual turnover below EUR 5 million for each of the two preceding years and a formal national risk assessment confirming low risk. Lower-division clubs may also be exempt on the basis of a proven low-risk assessment. The exemption must be granted by the relevant national supervisory authority following that assessment, a club cannot self-certify its own exemption. Most clubs competing at a meaningful professional level will not qualify.
A smaller club demonstrates its risk profile through a documented business-wide risk assessment, as required under the AMLR and specified in AMLA's April 2026 draft guidelines. The assessment should identify the club's specific money laundering and terrorist financing risks, taking into account factors such as ownership structure, investor and sponsor relationships, transfer activity, geographic exposure and financial profile. AMLA has explicitly designed minimum expectations to allow for proportionality based on entity size and business model.
The regulation requires a designated person with responsibility for AML compliance at every obliged entity. For smaller clubs, this does not have to be a dedicated full-time hire. It can be an existing senior person, a CFO or CEO, designated as responsible for AML, supported by external specialist advice. Alternatively, the function can be outsourced to a specialist firm. What is not permissible is having no one responsible at all. The absence of a designated AML function is itself a compliance failure.
The cost depends on the club's risk profile and what framework it already has in place. For most smaller clubs building from scratch, an initial AML readiness assessment to understand the gap typically costs in the region of £15,000. A full AML framework implementation typically ranges from £60,000 to £75,000 as a one-off project. Ongoing outsourced AML support, covering counterparty due diligence, transfer oversight, screening and MLRO support, is available from around £250,000 per year for clubs requiring a comprehensive outsourced function, with modular options at lower cost for clubs with more limited needs. The cost of non-compliance, supervisory sanctions, banking de-risking, reputational damage and disrupted transfers, is materially higher.
In principle, yes. In practice, the combination of regulatory complexity, the specific risk judgements required for football transactions and the absence of in-house AML expertise at most smaller clubs makes self-build difficult to do well. The more common and more reliable route is to use an external specialist adviser with football-specific knowledge to design the framework and train whoever within the club will operate it, delivering proportionate, defensible compliance without requiring a full in-house capability that most smaller clubs cannot justify on cost grounds.

What does 'proportionality' actually mean under EU 2024/1624 and why it matters for smaller clubs