Bespoke support,
Every time.
No two clubs or agents face exactly the same risks, operate under the same ownership structures, or conduct business in the same way. Every engagement begins with a thorough understanding of your specific position before we recommend anything.
Each service below is designed to work as a standalone engagement or as a natural step toward the next. Regardless of where you enter, the standard of output and accountability is the same.
For English clubs in the top five tiers, the Football Governance Act 2025 has created a new and permanent regulatory baseline. The following services are designed to help clubs meet that baseline, maintain it, and use it as a foundation for sound governance.
IFR and Governance, Risk and Compliance Services
IFR Operating Licence Support
Every regulated club in the top five tiers of English men's professional football must hold an IFR operating licence to compete from the 2027/28 season. We support clubs through the full licensing process: pre-application readiness assessment, documentation preparation, submission management and regulatory liaison. We identify gaps before the IFR does, and we build the evidence base required to satisfy each licensing criterion across financial resilience, governance, ownership integrity, fan engagement and ground infrastructure.
Governance Framework Design
The IFR expects clubs to operate within a clearly defined governance architecture. We design and implement the full framework: board and committee structures, terms of reference, delegation of authority matrices, conflicts of interest policies, reporting lines and information flows. The output is a governance framework that satisfies IFR licensing criteria and withstands regulatory scrutiny, while operating practically within the constraints of a professional football club.
ODSE Compliance and Approval Support
The IFR's Owners, Directors and Senior Executives regime has been live since 5 May 2026. Every owner, director and senior executive at a regulated club must be approved by the IFR before taking up or continuing in their role. We support individuals and clubs through the full ODSE process: eligibility assessment, disclosure preparation, evidence collation, submission drafting and regulatory engagement. We also advise on the ongoing compliance obligations that apply to approved individuals after initial approval is granted.
Risk Management Framework
Effective risk management is a core IFR licensing expectation. We design and implement a risk management framework tailored to the specific risk profile of your club: operational, financial, regulatory, reputational and strategic. The framework covers risk appetite articulation, risk register design and maintenance, escalation procedures, board risk reporting and integration with the club's existing governance and financial oversight structures.
Board and Committee Effectiveness Review
The IFR's governance expectations go beyond the existence of a board and committee structure. They extend to how those structures actually function: decision-making quality, information flows, challenge culture and the independence of key committees. We conduct structured effectiveness reviews of your board and principal committees, benchmarking against IFR expectations and best-practice governance standards, and produce a findings report with prioritised recommendations. Reviews can be conducted on a standalone basis or as part of a broader governance framework design engagement.
Fan Engagement Compliance
The Football Governance Act 2025 introduces formal fan engagement requirements as part of the IFR licensing framework. Clubs must demonstrate structured, meaningful and documented engagement with their supporter base. We advise on the design of fan engagement programmes that satisfy IFR expectations, help draft the necessary policies and governance documents, and support clubs in building the evidence trail required for licensing and ongoing compliance purposes.
Ongoing Monitoring and Assurance
The IFR regulatory environment is not static. Licensing conditions will evolve, new guidance will be issued, and the regulator's expectations will develop as the framework matures. We provide an ongoing regulatory monitoring service that tracks IFR, Football Governance Act and related regulatory developments, assesses their implications for your club, and keeps your compliance position current between formal review cycles. Delivered as a monthly briefing and advisory retainer, with escalation support for material regulatory changes.
Ongoing Compliance Outsourcing
For clubs that require a managed compliance function rather than a project-based engagement, we provide a fully outsourced regulatory compliance service. This covers day-to-day governance support, regulatory correspondence management, ODSE ongoing compliance monitoring, board and committee secretariat support, IFR liaison, and annual independent review of your compliance framework. The service is led by a named senior consultant and operates as an extension of your internal team.
The following services address the anti-financial crime obligations that apply to professional football clubs and agents under EU Regulation 2024/1624, UEFA Club Licensing 2025, and the banking and commercial pressures that operate independently of any regulatory deadline.
Anti-Financial Crime Services
Readiness Assessment
Know exactly where you stand against the EU AML standard.
A fixed-scope diagnostic that maps your club or agency against EU Regulation 2024/1624 expectations, UEFA club-licensing requirements and correspondent-bank standards. We assess your current position across every material control area, produce a risk heat map showing your exposure relative to regulatory expectations, and deliver a prioritised remediation roadmap with clear sequencing. The assessment output is designed to be presentable to your board, your bank and a regulatory counterparty.
Framework Development
A complete AML framework built for how football clubs and agents actually operate.
Full AML framework design and implementation, built for how football clubs and agents actually operate rather than adapted from generic banking templates. The framework covers board-approved AML policy and risk appetite statement, customer due diligence and KYB processes for owners, investors, directors, agents and transfer counterparties, ultimate beneficial ownership identification for complex structures, sanctions and PEP screening configuration and ongoing monitoring, transfer transaction controls and payment-flow validation, source-of-wealth analysis methodology for high-risk relationships, suspicious-activity reporting procedures and a named MLRO escalation chain, and a staff training programme using football-specific scenarios.
Outsourcing & Resourcing Support
Your AML function, run by the specialists who built it.
A fully outsourced AML function. We run your compliance operation on an ongoing basis, covering counterparty due diligence across your full active universe, transfer-window oversight and payment-flow validation, MLRO support and suspicious-activity escalation, sanctions and adverse-media monitoring with documented alert handling, board-level quarterly reporting and annual independent review of the control environment. Supported by partner screening technology and delivered with a named senior consultant as your primary point of accountability.
Ad hoc and modular anti-financial crime services
Transfer Transaction Oversight
Individual transfer transactions carry layered financial-crime risk, from the structure of the deal through to payment flows, intermediary arrangements and agent commission routing. We review each transaction against AML requirements before commitment and validate payment flows before release, producing a documented decision trail for every deal. Available per transaction, per transfer window or as a full-year oversight retainer.
Sanctions and Ownership Exposure Review
A focused review of your current ownership structure, investor relationships and sponsor arrangements against global sanctions lists, PEP databases and adverse-media sources. We assess jurisdictional risk, identify exposure you may not know you have, and produce a documented findings report that is presentable to your board, your bank or a regulatory counterparty.
Football Counterparty Onboarding Design
The processes by which clubs and agencies onboard agents, sponsors, investors and transfer counterparties are among the most scrutinised under EU Regulation 2024/1624. We design the full onboarding infrastructure: KYC and KYB workflows, ultimate beneficial ownership identification processes, risk-rating methodology and source-of-wealth questionnaires. Everything is built for how football counterparty relationships actually work.
Transfer Governance and Controls Review
A structured review of your existing transfer process against best-practice AML controls. We map your current procedures from target identification through to payment completion, assess your payment approval controls, review how agent commission payments are currently handled, and identify where the process leaves you exposed. The output is a clear gap analysis and a set of prioritised recommendations for strengthening your transfer control environment.
AML Training Programme
Effective AML compliance depends on staff at every level understanding their obligations and recognising risk when they see it. We deliver bespoke training covering board-level AML awareness, finance team operational procedures, transfer team risk identification and agent sanctions awareness. Sessions use scenario-based exercises drawn from real football transactions rather than generic financial-sector examples. Available as virtual delivery or in-person workshops.
Annual AML Independent Review
Once a compliance framework is in place, it needs to be tested. Our annual independent review assesses whether your AML controls are operating effectively, whether your policies remain current against evolving regulation, and whether any weaknesses identified in previous reviews have been remediated. The output satisfies the independent testing requirements of EU Regulation 2024/1624 and the due diligence expectations of correspondent banks and UEFA licensing.
Regulatory and Banking Support
When a regulator initiates a review, a bank requests AML documentation, or a commercial counterparty requires written confirmation of your compliance framework, the quality of your response matters as much as the underlying controls. We prepare submissions, draft responses, attend meetings and support you through the process from first contact to resolution.
Ongoing Counterparty Due Diligence retainer
A monthly retainer providing continuous KYB, sanctions and PEP screening, adverse-media monitoring and UBO verification across your active counterparty universe, including sponsors, agents, investors and ownership relationships. Supported by partner screening technology and delivered with documented alert handling and escalation.
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Common questions about football & agent AML compliance services
If you have questions that are not answered here, contact us and we will be happy to help.
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Professional football clubs require a range of anti-money laundering (AML) compliance services calibrated to the sport's specific financial-crime risk profile. At a minimum, an in-scope club needs an AML readiness assessment to establish its current position, a full framework implementation covering policies, governance, KYC and KYB processes, beneficial ownership identification, sanctions and PEP screening, transfer controls and staff training, and ongoing maintenance through annual independent review and counterparty monitoring.
Clubs approaching EU Regulation 2024/1624's 10 July 2029 application date should begin with a diagnostic assessment in 2026 or 2027 to allow adequate time for a complete build.
The precise scope depends on the club's risk profile. Ownership complexity, transfer volume, agent relationships, UEFA exposure and jurisdictional footprint all influence what is proportionate and necessary.
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AML compliance for professional football is fundamentally different from other sectors because football's financial flows do not resemble those of a bank, a law firm or a real estate agent.
Football-specific risks include complex transfer transactions with deferred payments, contingent fees and sell-on clauses; agent commission structures that may route through image-rights vehicles across multiple jurisdictions; ownership chains commonly featuring offshore holding companies, trusts and multi-layer investment vehicles; and sponsorship arrangements from counterparties in higher-risk territories.
A generic AML framework transplanted from a banking template will be either disproportionate, operationally unworkable, or incomplete when applied to a football club or agent.
Effective football AML compliance requires advisers with working knowledge of the Transfer Matching System (TMS), FIFA's Regulations on the Status and Transfer of Players (RSTP), agent agreement structures, club ownership architecture, and how correspondent banks and UEFA licensing functions assess financial-crime risk in the sport.
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EU Regulation 2024/1624 applies to professional football clubs operating in EU member states from 10 July 2029. The regulation designates in-scope clubs as obliged entities, meaning they face the same AML requirements as banks and other regulated financial institutions.
Member states have limited discretion to exempt genuinely lower-risk smaller clubs, but professional clubs with significant transfer activity, foreign ownership, UEFA competition exposure or complex sponsorship arrangements are very likely to be in scope.
Clubs in the Premier League and English Football League are not directly subject to EU Regulation 2024/1624 but face parallel obligations under the Football Governance Act 2025, the Independent Football Regulator and bank de-risking pressure that effectively requires an equivalent level of AML documentation.
Clubs in non-EU European markets face UEFA club-licensing and financial sustainability obligations that are increasingly AML-adjacent.
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A compliant AML framework for a professional football club must include seven core components.
First, a board-approved AML policy and risk appetite statement. Second, customer due diligence (CDD) processes covering owners, investors, directors, agents and transfer counterparties, including ultimate beneficial ownership (UBO) identification for complex structures. Third, sanctions and politically exposed person (PEP) screening with ongoing monitoring and adverse media review. Fourth, transaction monitoring covering transfer payments, agent commissions, sponsorship flows and third-party payments.
Fifth, source-of-wealth and source-of-funds analysis for high-risk relationships and high-value transactions. Sixth, suspicious activity reporting procedures and a documented escalation chain to the Money Laundering Reporting Officer (MLRO). Seventh, an annual independent review of the control environment.
EU Regulation 2024/1624 explicitly endorses a proportionality principle: the framework must be calibrated to the club's actual risk profile, not applied at maximum intensity regardless of the club's size and complexity.
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This will very from engagement to engagement but typically, a complete AML framework implementation for a professional football club, covering policy, governance, KYC workflows, transfer controls, sanctions screening configuration and staff training, typically takes two to six months.
The timeline depends on the complexity of the club's ownership structure, the volume and cross-border nature of its transfer activity, the number of active agent relationships and the club's starting position. Clubs with complex offshore ownership structures, multiple investor jurisdictions or high transfer volumes should allow the longer end of this range.
We recommend clubs begin their readiness and scoping process in 2026 or 2027 to ensure adequate time before EU Regulation 2024/1624's 10 July 2029 application date. Starting in 2028 creates a compressed and high-risk implementation timeline, with limited qualified advisers available and no margin for remediation.
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English football clubs in the top five tiers of the men's professional game face a comprehensive new regulatory framework under the Football Governance Act 2025. At a minimum, a regulated club needs to understand its obligations under the IFR's Owners, Directors and Senior Executives regime, which has been live since May 2026, prepare for and obtain an IFR operating licence ahead of the 2027/28 season, and establish the governance structures, risk management frameworks and fan engagement processes that the licensing framework requires.
Beyond the licensing baseline, clubs benefit from ongoing regulatory monitoring as the IFR framework matures, periodic governance effectiveness reviews, and a managed compliance function that keeps pace with regulatory developments without placing unsustainable demands on internal resource.
The precise scope depends on the club's tier, ownership complexity, governance maturity and the specific conditions the IFR attaches to its operating licence.
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For English clubs competing in UEFA competitions or conducting cross-border transfer activity, both frameworks apply simultaneously. The Football Governance Act 2025 and the IFR licensing regime govern governance, ownership integrity and fan engagement at the club level. EU Regulation 2024/1624, which takes effect from 10 July 2029, governs financial-crime controls at the transaction level.
The two frameworks are complementary rather than duplicative. A club that builds a sound governance framework under IFR expectations is better positioned to meet EU AML requirements, because both frameworks demand documented processes, board-level accountability, clear ownership transparency and robust due diligence on counterparties.
We advise English clubs on both simultaneously, ensuring that the governance and compliance work undertaken for IFR purposes is structured to support EU AML readiness at the same time.
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Yes. EU Regulation 2024/1624 explicitly designates professional football agents as obliged entities from 10 July 2029, the same designation as banks and other regulated financial firms. Agents must operate customer due diligence on their clients, document commission flows, conduct sanctions and PEP screening, monitor transactions and maintain a governance framework.
Beyond the formal 2029 deadline, many football agencies are already facing practical AML requirements from their banking partners. Banks are applying de-risking pressure to agencies that cannot produce documented compliance frameworks, resulting in account restrictions and service withdrawals.
Agents with cross-border client relationships, commission structures routing through image-rights vehicles, or activity in multiple EU jurisdictions face the highest exposure and should treat AML readiness as an immediate priority rather than a concern for 2029.
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These three services correspond to three stages of a club or agency's compliance journey.
An AML readiness assessment is a diagnostic. It tells you where you currently stand against the EU AML standard, identifies the gaps in your current control environment and produces a prioritised remediation roadmap. It builds no controls itself, only a clear picture of what needs to be built and in what order.
An AML framework implementation, such as the Lagom Foundation engagement, is the build phase. It takes the readiness roadmap and constructs the complete compliance environment: policy, governance, KYC workflows, screening configuration, transfer controls and training.
An outsourced AML function, such as Lagom Outsourced, is the operational phase. It runs the framework on an ongoing basis, providing counterparty due diligence, transfer-window oversight, MLRO support, annual independent review and board reporting as a managed service.
Most clubs progress through these stages in sequence, though each can also be accessed independently.
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Yes. All of Lagom's modular services can be commissioned independently, without a readiness assessment or full framework build. This includes transfer transaction oversight, sanctions and ownership exposure reviews, counterparty onboarding design, AML training programmes, annual independent reviews and regulatory and banking support.
Modular commissioning suits clubs or agencies that already have a partial compliance framework in place and need specific gaps filled. It also suits those facing an immediate and time-sensitive need, such as a banking review, an ownership change or an imminent transfer window, before a full implementation is appropriate.
Every modular engagement is scoped individually, delivered to the same standards as headline packages, and documented with a formal engagement letter, agreed deliverables and a clear decision trail.
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Bank de-risking pressure is a live and growing threat for clubs and agents that cannot demonstrate adequate AML controls. It occurs when correspondent banks restrict services or close accounts for football clients they consider too high-risk to manage under their own AML obligations.
Our banking support service covers preparation and submission of bank AML questionnaires and due diligence requests, review and strengthening of existing compliance documentation before submission, attendance at bank AML review meetings, and structured support for remediation and re-engagement where a club has already experienced service restriction.
The most effective intervention is proactive. A club with a documented and independently tested AML framework is materially better positioned in banking relationships than one responding reactively to a bank's demands. We recommend all clubs and agencies treat banking-counterparty readiness as a priority alongside regulatory deadline preparation.
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Yes. While EU Regulation 2024/1624 and the Football Governance Act 2025 create the primary formal regulatory drivers for our UK and EU clients, we serve clients across a broader geography.
In South America, particularly Brazil and Argentina, demand is driven by European buyer clubs, sponsors and banks requiring bank-grade due diligence on transfer chains, agency commission structures and ownership structures before transacting. In Central America, Concacaf club-licensing requirements and counterparty-driven due diligence demands from sponsors and investors create a parallel compliance market.
We deliver South and Central American work through established channel partnerships with local law firms and forensic specialists, applying consistent standards and methodology across all markets.
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The IFR's Owners, Directors and Senior Executives regime requires every individual who owns, directs or holds a senior executive role at a regulated club to obtain IFR approval before taking up or continuing in that role. The regime has been live since 5 May 2026 and applies to clubs in the top five tiers of English men's professional football.
The IFR assesses each individual against criteria covering financial standing, integrity, competence and disqualification history. Approval is not automatic and the process requires structured disclosure and evidence submission.
We support both individuals and clubs through the full ODSE process, from initial eligibility assessment through to submission and regulatory liaison.