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.

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Football Governance, Operational Resilience Jonathan Greenstein Football Governance, Operational Resilience Jonathan Greenstein

Scenario testing for football clubs: how to stress-test against severe but plausible disruption

A plan that has never been tested against a realistic adverse scenario is a hypothesis, not a capability. That is the principle at the heart of the fourth and final discipline in the operational resilience framework, and it is the one that most decisively separates genuine resilience from a document sitting in a drawer. Football has already experienced the exact category of disruption this article describes -- more than once, and more recently than most boards realise.

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Events Jonathan Greenstein Events Jonathan Greenstein

August 2026 Events with Lagom Sports Compliance

August is a two-session month for us, and both sessions land at a genuinely useful moment in the IFR's own timeline. The final licensing rules have been published, the application window is now weeks away, and the governance standard the Regulator expects is no longer a future obligation to plan around -- it is a present one clubs are being actively assessed against. Below is what we are running this month, why each session earns its place on a busy calendar, and an early look at what September has in store.

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

AMLA and football: the new EU anti-money laundering authority won't regulate your club directly, and that is exactly why it matters

A new EU authority with direct power to supervise, investigate and sanction is being built in Frankfurt right now, and football clubs and agents across Europe will almost certainly never appear on its own supervisory books. That is not a reassurance to skip past. It is the single most important thing to understand about the Anti-Money Laundering Authority, because the way this body actually reaches football is more indirect, more structural, and ultimately more consequential than a simple direct-regulator relationship would be.

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Regulation & Compliance, Regulatory Update Jonathan Greenstein Regulation & Compliance, Regulatory Update Jonathan Greenstein

Horizon Scanning: Our predictions for the future of football regulation

Football regulation is not being built from a blank page. Almost every mechanism now appearing in the IFR's licensing framework and the EU's approach to football-specific AML has a direct precedent somewhere in financial services regulation over the past fifteen years. That is not a coincidence -- it is the natural result of governments and regulators reaching for tools that have already been tested elsewhere, rather than inventing football-specific ones from scratch. Reading that precedent carefully lets us make some genuinely informed predictions about where football regulation goes next. These are our own views, not confirmed policy, and we have graded our confidence in each one accordingly.

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Operational Resilience, Football Governance Jonathan Greenstein Operational Resilience, Football Governance Jonathan Greenstein

Third-party and outsourcing resilience: the supplier failures that can stop a football club cold

Identifying important business services, setting tolerances for their disruption, and mapping who delivers them are three disciplines a club can complete largely through its own effort. The fourth is harder, because it requires the club to hold a third party to a standard the club does not control. Financial services firms have a specific regulatory framework for exactly this problem. Football clubs, for the most part, do not -- and it shows.

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IFR Enforcement, Football Governance Jonathan Greenstein IFR Enforcement, Football Governance Jonathan Greenstein

What is an IFR skilled person and how does a football club avoid ever needing one?

Schedule 9 of the Football Governance Act 2025 gives the Independent Football Regulator the power to require a club to appoint a specialist, nominated by the IFR itself, to help bring an unresolved compliance failure to an end. It is easy to mistake this for a version of the advisory support clubs already engage voluntarily. It is not. The distinction between choosing your own adviser and having one nominated for you by your regulator is the entire point of this article and the most useful thing any club can take from it is exactly what it looks like to never need one.

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Football Governance Jonathan Greenstein Football Governance Jonathan Greenstein

Mapping the chain: the people, systems and third parties every football club actually depends on

A single Premier League matchday can involve well over a thousand people who are not employed by the club at all. Stewarding, catering, cleaning, ticketing technology and much of the infrastructure that makes a fixture happen sits with a small number of specialist operators serving much of the league at once. Mapping exposes exactly how concentrated that dependency really is -- and most clubs, when they do this exercise properly for the first time, are surprised by what they find.

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The IFR's information notice power explained: what section 65 means for football clubs

Section 65 of the Football Governance Act 2025 is the Independent Football Regulator's most fundamental information-gathering power, and it is also the one most likely to arrive at a club without any warning that an investigation is under way. Unlike the expert reporter power under section 66, which involves the IFR commissioning an independent third party, section 65 is the IFR's own direct power to require any person to hand over, generate or even collect information it does not currently hold. Understanding exactly what a notice under this section can require, and what happens if a club gets its response wrong, matters to every regulated club, not only those already facing a live enquiry.

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AML Compliance Jonathan Greenstein AML Compliance Jonathan Greenstein

When football meets crypto: sponsorship, investment and the AML risks clubs are still not measuring

The FCA's June 2026 warning to Premier League clubs addressed one crypto-linked risk in football: unauthorised firms buying legitimacy through sponsorship. It is the most visible risk, but it is not the only one. Crypto-denominated investment in club ownership, crypto-settled transfer payments, and the commercial arrangements sitting behind fan tokens and NFT schemes all carry AML exposure that most clubs have not yet formally assessed and the regulatory frameworks that will eventually govern all of it are already taking shape.

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IFR Licensing, Football Governance Jonathan Greenstein IFR Licensing, Football Governance Jonathan Greenstein

What happens when an IFR licence application is rejected or appealed? A practical guide to the decision-making process

Most of the published guidance on the Independent Football Regulator's licensing regime, including Lagom Sports Compliance’s own, explains how to apply, what the Threshold Requirements ask for, and what a club's evidence pack needs to contain. Almost none of it explains what actually happens if the application does not succeed. Given that the consequence of an unresolved refusal is a club being unable to operate a team in a specified competition, that is a significant gap. This article closes it.

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IFR Licensing Jonathan Greenstein IFR Licensing Jonathan Greenstein

What IFR licensing means for institutional investors and private equity holding English football clubs

English football has acquired something institutional capital has not previously had to underwrite: a statutory financial regulator with the power to approve or refuse who owns a club, and the power to license or delicense the asset itself. For funds already holding English club stakes, and for those evaluating the sector for the first time, the Independent Football Regulator is not a compliance footnote. It is a new, permanent variable in deal timelines, ownership structuring, financing terms and portfolio-level regulatory risk and it is here to stay.

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Regulatory Update Jonathan Greenstein Regulatory Update Jonathan Greenstein

CJEU rules on agent regulations: the key findings in Case C-209/23 and what they mean for AML

On 16 July 2026 the Court of Justice of the European Union handed down its judgment in Case C-209/23 (RRC Sports). The headline is narrower than the immediate commentary suggests. The Court left the referring court to apply its guidance to most of the contested rules. Two points were expressed more strongly than the rest: the approach rule appears, in any event, to be incompatible with the prohibition on cartels, while the GDPR conclusion on disclosure and publication is unqualified. The latter may have consequences for how agents are diligenced under EU Regulation 2024/1624 from 10 July 2029.

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IFR Licensing, IFR Enforcement, ODSE, go Jonathan Greenstein IFR Licensing, IFR Enforcement, ODSE, go Jonathan Greenstein

What section 34 means for football club owners

Almost everything written about the IFR's owner suitability regime concerns getting through it: the fitness criteria, the source of wealth test, the application process, the timeline. Almost nothing addresses what happens once an owner has cleared that hurdle. The answer, under section 34 of the Football Governance Act 2025, is that an affirmative determination is not a certificate that sits in a drawer. It is a live status the IFR can revisit at any time and every existing club owner, whether newly approved or in position for decades, needs to understand exactly how.

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Operational Resilience, Football Governance Jonathan Greenstein Operational Resilience, Football Governance Jonathan Greenstein

Setting impact tolerances: how long can a football club survive disruption before real harm occurs?

Ask a club how quickly it would recover from a serious system failure and the honest answer is usually "as fast as possible." That is not an impact tolerance. It is a hope. The discipline that financial services firms were forced to adopt under the FCA's operational resilience framework requires something much harder: a specific, defensible, board-approved limit for how much disruption each critical service can absorb before the harm becomes unacceptable. This article explains how a football club sets one properly, using the club's own most time-critical services as the test case.

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The IFR's expert reporter power explained: what section 66 means for football clubs

Section 66 of the Football Governance Act 2025 gives the Independent Football Regulator a power that has attracted almost no dedicated commentary: the ability to appoint an independent expert reporter to prepare a report on a specific matter at a regulated club, with the possibility that costs or expenses may be made payable by the club under IFR rules. It is frequently confused with the IFR's separate power to appoint a skilled person. The two are not the same tool, they are not triggered at the same point, and understanding the difference matters to any club that wants to know what a genuine IFR enquiry actually looks like.

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Operational Resilience, Football Governance Jonathan Greenstein Operational Resilience, Football Governance Jonathan Greenstein

What are a football club's "important business services"? Identifying the operations that cannot be allowed to fail

Ask a club's leadership team what the business actually does and the answer, understandably, will be some version of football. Ask which specific services genuinely cannot be allowed to fail, and most boards have never been asked to answer with any precision. The exercise is narrower and more revealing than it first appears, and doing it properly is the essential first step of any genuine operational resilience programme.

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Operational Resilience, Football Governance Jonathan Greenstein Operational Resilience, Football Governance Jonathan Greenstein

Beyond the business continuity plan: what operational resilience really means for a football club

Most football clubs have a business continuity plan. Very few have thought about operational resilience, and the distinction is not semantic. A continuity plan tells you what to do after something breaks. Operational resilience asks a harder question: can the club keep delivering the services that matter, throughout the disruption, not just after it. Financial services firms were forced to make this shift five years ago. Football clubs are about to discover why it matters to them too.

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Regulatory Update Jonathan Greenstein Regulatory Update Jonathan Greenstein

CJEU ROGON judgment: why football agent regulation is moving in one direction

The Court of Justice of the European Union has handed down a judgment that matters well beyond German football.

In Case C-428/23, ROGON and Others, the Court considered whether the German Football Association’s rules on player agents may fall within an exception to the EU prohibition on cartels. The press release headline is deliberately careful. The DFB rules may fall within the exception. The Court has not finally decided that the rules are lawful. That question now goes back to the German Federal Court of Justice.

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