A Red Card for Dirty Money: EU Targets Football Clubs with AML Rules – Is the UK Falling Behind?

The beautiful game is facing a regulatory reality check. In a landmark move, the European Union has formally extended its anti-money laundering (AML) regime to include professional football clubs and agents, recognising the sport’s vulnerability to financial crime. The UK, meanwhile, is still deliberating its next steps—raising questions about whether it’s lagging in protecting its most lucrative sporting sector.

EU’s AMLR: Football Clubs Now “Obliged Entities”

On April 18, 2024, the European Parliament adopted the Anti-Money Laundering Regulation (AMLR), which, for the first time, brings football clubs and agents within the scope of AML laws.

These entities will be required to:

• Conduct customer due diligence on investors, sponsors, and agents.
• Monitor and report suspicious transactions, especially around player transfers.
• Maintain internal AML controls and appoint compliance officers.
• Identify and verify beneficial ownership, especially in complex ownership structures. [twobirds.com]

The regulation is set to take full effect by July 2029, with guidelines from the new EU Anti-Money Laundering Authority (AMLA) expected by 2026. [neo.law]

Why football? The EU cites the sport’s global popularity, high-value transactions, and opaque ownership structures as key risk factors. From oligarchs to offshore sponsors, football has long been a magnet for illicit finance. [hoganlovells.com]

UK: Still on the Sidelines?

Despite being home to the Premier League, the world’s richest football competition, the UK has yet to follow the EU’s lead. While the government’s National Risk Assessment flags football as a high-risk sector for money laundering, no formal AML obligations currently apply to clubs. [pinsentmasons.com]

Instead, the UK is exploring the creation of an Independent Football Regulator (IFR) to oversee financial viability and transparency of ownership. The Economic Crime and Corporate Transparency Act 2023 also strengthens powers against corporate crime, potentially impacting clubs in the future. [zigram.tech]

However, critics argue that voluntary reforms and piecemeal oversight are insufficient. With over half of Premier League clubs linked to offshore entities, and multi-million-pound transfers often involving third-party intermediaries, the risk of abuse remains high. [hcrlaw.com]

What’s Next?

The EU’s move sets a precedent that could reshape global sports compliance. As AML regulations expand into sectors like art and luxury goods, football’s inclusion signals a broader shift in how regulators view high-risk industries.

For the UK, the question is no longer if football should be regulated under AML laws—but when. With billions at stake and reputational risks mounting, the time for action may be now.

SOURCES

• https://www.twobirds.com/en/insights/2024/global/new-european-anti-money-laundering-rules-bring-football-clubs-and-football-agents-into-the-scope
• https://neo.law/2024/06/28/eu-implements-aml-regulations-for-football-agents-and-professional-football-clubs/
• https://www.hoganlovells.com/en/publications/football-agents-and-professional-football-clubs-subject-to-the-new-eu-anti-money-laundering-regulation
• https://www.zigram.tech/articles/uks-football-and-money-laundering/