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 understanding your specific position before we recommend anything.
Regardless as to which service you engage us at, each stage is designed to work standalone, or as a natural step toward the next.
Our 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 and delivers a clear, prioritised path to compliance.
Framework Development
A complete AML framework built for how football clubs and agents actually operate.
From policy suite and governance to KYC workflows, agent onboarding playbooks, sanctions screening and training, our complete AML frameworks are designed for professional football clubs and agents.
Outsourcing & Resourcing Support
Your AML function, run by the specialists who built it.
A fully outsourced AML operation covering ongoing counterparty due diligence, transfer-window oversight, MLRO support and board-level reporting.
Ad hoc and modular services
Transfer Transaction Oversight
Individual transfer transactions carry layered financial-crime risk, from the structure of the deal itself 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, not adapted from generic templates.
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 is a formal review report that 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. We also provide ongoing advisory for clubs and agencies managing active regulatory or banking relationships where AML questions arise regularly.
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, it ensures your counterparty risk picture stays current between formal review cycles rather than only being tested when a specific transaction arises.
Speak to us today
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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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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.