Insights, analysis and events

from Lagom Sports Compliance

Tracking the practical implications of EU 2024/1624, football governance developments, enforcement trends and the compliance issues that matter to clubs, agents and their counterparties.

Filter
English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

The Football Club Corporate Governance Code: what regulated clubs must now apply, explain and evidence

The Football Club Corporate Governance Code is not a generic governance handbook. It is the framework regulated clubs must apply and explain through their corporate governance statement. Boards now need to evidence purpose, strategy, risk oversight, board accountability, EDI and stakeholder engagement in a way that is proportionate and credible.

Read More
English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

IFR Licensing Rules: the procedural obligations behind the operating licence regime

The IFR Licensing Rules are short, but clubs should not underestimate them. They turn guidance, templates, approvals and submission windows into binding procedural requirements. Failure to comply may constitute a relevant infringement and lead to investigation or enforcement action.

Read More
English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

IFR Licensing Guidance: what ongoing licence compliance now means for regulated clubs

The IFR Licensing Guidance is the document that turns a provisional licence into an ongoing compliance relationship. Clubs must submit financial plans, governance statements, fan consultation reports and annual declarations, then keep those submissions accurate as their circumstances change.

Read More
English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

IFR provisional licence application guidance: what regulated clubs must submit before the 2027/28 season

Every club in the top five divisions needs an IFR provisional licence to compete from the 2027/28 season. The application is not a formality. It requires a strategic business plan, financial forecasts, a personnel statement and an authorised declaration, signed by a club director or individual with appropriate authority, confirming that the information is accurate and complete.

Read More
UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

Agent fees, amortisation and the 70% trap: how transfer window decisions drive UEFA financial sustainability risk

Clubs spent a record USD 1.37 billion on agent fees in 2025. Every pound of that sum sits in the numerator of UEFA's Squad Cost Rule. Combined with wages and transfer amortisation -- the other two numerator components -- agent fees mean that a single active summer transfer window can move a club's squad cost ratio by several percentage points in the space of six weeks. This article explains precisely how that happens, why it matters, and what a compliance-aware transfer window strategy looks like.

Read More
UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

UEFA's escalating consequence model in practice: examining the Aston Villa June 2026 decision

Aston Villa's outcome from the UEFA CFCB monitoring cycle of 30 June 2026 is the most instructive single data point in European football's regulatory landscape this summer. It is the only English club to receive a significant breach finding under the Squad Cost Rule, the only English club to face a List A registration restriction for a UEFA competition, and -- at €22.5 million -- the largest conditional fine imposed on any English club in the current enforcement cycle. Used correctly, the Villa decision is a precise illustration of how UEFA's escalating consequence model actually functions. This article explains it.

Read More
UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

How UEFA financial sustainability rules interact with the IFR licensing regime: what English clubs in both frameworks need to know

English football clubs are the only clubs in the world simultaneously subject to UEFA's Club Financial Control Body monitoring and the Independent Football Regulator's operating licence regime. Two regulators, two financial sustainability frameworks, two sets of information requirements, two sets of deadlines -- with some objectives that reinforce each other and others that pull in different directions. This article maps the intersections, the tensions and the compliance implications of operating in both simultaneously.

Read More
UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

The UEFA CFCB settlement agreement: what it is, what it commits you to and why it is not a get-out

When Newcastle United and Juventus entered settlement agreements with UEFA's Club Financial Control Body in June 2026, some coverage framed the outcome as a deal struck, a fine agreed and a matter resolved. That framing misunderstands what a settlement agreement is. It is not a resolved matter. It is the beginning of a three-year compliance programme, with annual targets, public reporting obligations and escalating consequences, up to and including exclusion from UEFA competition, if those targets are not met.

Read More
UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

The UEFA Football Earnings Rule: what replaced FFP, how the three-year test works and why Newcastle fell foul of it

UEFA's Financial Fair Play rules are gone. In their place sits a more sophisticated, more demanding framework: the Football Earnings Rule, which assesses a club's financial sustainability across a rolling three-year period and permits aggregate losses of up to €60 million before triggering a significant breach. Newcastle United became the first English club to be sanctioned under the FER in the June 2026 enforcement cycle. This article explains what the rule requires, how it differs from FFP, and what clubs need to understand about managing their position across a three-year horizon.

Read More
UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

The UEFA Squad Cost Rule explained: what the 70% cap means, how it is calculated and why clubs breach it

Four Premier League clubs breached the UEFA Squad Cost Rule in the 2025 calendar year. The rule itself, a 70% cap on aggregate squad costs relative to relevant revenues, is deceptively simple in concept and genuinely complex in application. This guide explains precisely what it requires, how the ratio is calculated, what counts in the numerator and what does not, and what the consequences of a breach look like in practice.

Read More
UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

UEFA financial sustainability regulations 2025: what the June 2026 enforcement round means for English football

On 30 June 2026, UEFA's Club Financial Control Body published the outcomes of its club monitoring process for the 2025/26 season. Fourteen clubs across European football were sanctioned. Four were from the Premier League. This is what happened, what it means and what clubs need to understand about the framework that produced these outcomes.

Read More
AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein

EU AML 2024/1624 and football agents: the definitive guide to what applies to you from July 2029

Article 3(3)(n) of EU Regulation 2024/1624 is unambiguous. Every natural or legal person who, for remuneration, provides intermediary services by representing or acting on behalf of natural or legal persons in the negotiation or conclusion of transactions involving the transfer of a football player is an obliged entity under EU AML law from 10 July 2029. That definition applies equally to the largest multi-national agency and the solo operator representing two players in the third division. This guide explains, in precise and practical terms, what that means for you.

Read More
AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein

Can a football club outsource its AML and compliance function? Yes, and here is how

EU Regulation 2024/1624 requires professional football clubs to have a functioning AML compliance framework from July 2029. It does not require them to build or staff it internally. Outsourcing the compliance function is expressly permissible, and for most clubs, the more practical option. But outsourcing does not transfer legal responsibility. The club remains the obliged entity. The club remains accountable to its regulator. What outsourcing transfers is the operational delivery of the compliance function, not the obligation itself.

Read More
AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein

How banks are changing the rules for football clubs: enhanced due diligence, de-risking and what it means for your banking relationships

Some clubs have been asked to provide documentation they have never been asked for before. Some have had facilities reviewed or restricted. A few have lost banking relationships entirely. In almost every case, the club's finance team did not see it coming, and had no framework for responding to it. This article explains what is happening, why it is happening now, and what a football club CFO or finance director needs to understand to protect their banking relationships going forward.

Read More
AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein

How criminals launder money through football: the mechanics, the cases and why regulators finally acted

Football moved USD 8.59 billion in international transfer fees in 2024 and a record USD 1.37 billion in agent commissions in 2025, flowing through ownership structures, image-rights vehicles and cross-border payment chains that span virtually every jurisdiction on earth. The Financial Action Task Force warned in 2009 that the sport's regulatory framework had not kept pace with its own growth. Sixteen years later, the European Union has finally acted. This article explains, in detail, how the laundering actually works, and why football's structure makes it uniquely exploitable.

Read More
AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein

Europe is closing the AML perimeter: what South and Central American clubs and agents need to know before 2029

EU Regulation 2024/1624 does not apply directly to clubs in Brazil, Argentina, Colombia, Uruguay, Chile, Costa Rica, Mexico or Panama. But if your club sells players to Europe, works with European agents or aspires to attract international investment, European rules already shape the terms on which those transactions can happen. This guide explains why and what you need to do about it.

Read More
AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein AML Compliance, EU AML Regulation 2024/1624 Jonathan Greenstein

Europa cierra el perímetro AML: lo que los clubes y agentes de América Latina necesitan saber antes de 2029

El Reglamento UE 2024/1624 no se aplica directamente a los clubes de Brasil, Argentina, Colombia, Uruguay, Chile, Costa Rica, México ni Panamá. Pero si el club vende jugadores a Europa, trabaja con agentes europeos o aspira a atraer inversores internacionales, las reglas europeas definen ya las condiciones en las que esas transacciones deben llevarse a cabo. Esta guía explica por qué, y qué hay que hacer al respecto.

Read More

What does it mean to be an SMF at a football club? The IFR's ODSE regime explained

If you hold a senior role at a regulated English football club, or are about to, the Independent Football Regulator may have already assessed you. If not, it will. Since 5 May 2026, every person carrying out one of six Senior Management Functions at a regulated club requires the IFR's prior approval. That approval is personal, not delegable, and the consequences of operating without it are enforceable against you individually.

Read More

Fan engagement under IFR licensing: what English football clubs must do now and why getting it right matters

For most of English football's history, how a club engaged with its supporters was a matter of choice. The Football Governance Act 2025 has ended that. Fan engagement is now a mandatory condition of the IFR operating licence every regulated club must hold. This article explains what the requirement demands, what it does not demand, and why the clubs that treat it as a governance opportunity rather than a compliance burden will emerge from the licensing process in the stronger commercial and reputational position.

Read More

Agent fees hit $1.37 billion in 2025: what that means for AML obligations on both sides of the transaction

From 10 July 2029, every football agent who earns a fee for intermediary services becomes an obliged entity under EU Regulation 2024/1624. Every club that pays that fee has been an obliged entity since the same date. The money flowing through agent relationships is now the most scrutinised transaction category in professional football, and the regulatory framework that governs it is almost entirely unbuilt.

Read More