Belgium’s anti-money laundering law: How does it impact football clubs?

The Belgian federal prosecutor launched the biggest criminal procedure in Belgian football of its history in late 2018^[1]. Under operation zero more than forty warrants were issued with Belgium’s largest clubs involved. Investigations were conducted into agents, referees, football coaches and others. Operation zero evolves around two blocks: matchfixing and financial fraud. The latter specifically entails money laundering and private corruption.

In the aftermath of this (still ongoing) procedure, there was a push in the Belgian federal parliament to submit Belgian professional football (i.e., all football clubs in membership of the Belgian Pro League) clubs to the preventive anti-money laundering system^[2]. The intended effect of this submission is, in short, that professional football clubs are required to initiate a mandatory due diligence of the persons/corporations with whom they do business. Should clubs identify instances of money-laundering and/or the financing of terrorism, they have to notify the CFI (i.e., the Belgian administrative authority supervising suspicious financial transactions) of this situation.

Consequently, since 10 July 2021, Belgian professional clubs are subject to the law of 18 September 2017 on the prevention of money laundering and financing of terrorism^[3], abbreviated the 'Anti-Money Laundering Law' (“AMLL”) (which is on his turn (partially) an implementation of EU directives^[4]). A summary of the most relevant obligations shall be granted underneath.

This article contains a summary and discusses the key features of the Belgian AMLL in practice. The recently adopted EU AML Package and its practical implications that will apply mid-2027, fall outside the scope of this article.