A football club’s guide – dealing with information requests from the IFR and key risks for clubs, individuals and related parties
The new Independent Football Regulator (IFR), modelled on UK financial services supervision, has extensive information-gathering and information-sharing powers under the Football Governance Act 2025[1] (the Act). Therefore, clubs should look (ever closer) at the horizon:
- What happens if the IFR deems it necessary to gather information for supervision and potential enforcement of the new regime?
- How can parties prepare and react, as well as manage the requirements of other supervisory bodies that may be engaged in any investigation?
This article highlights the most significant risks for clubs, related individuals and third parties, as well as practical steps that can be proactively taken to mitigate those risks.
Article outline:
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Written by
Zeena Saleh
Zeena is a partner in Dentons' Global Compliance & Investigations practice. She has extensive experience advising financial institutions, regulators, listed companies, regulated investment exchanges and senior executives in respect of contentious regulatory and criminal enforcement action brought by authorities such as the Prudential Regulation Authority, the Financial Conduct Authority, the Serious Fraud Office and HMRC. Her experience extends to supporting clients through a crisis and she often conducts internal investigations with an international focus involving alleged breaches of corporate governance controls, regulatory breaches, market abuse, insider dealing, corporate crime (including fraud, money laundering, and bribery and corruption) and non-financial misconduct. Where changes to a client's compliance controls are recommended following the outcome of an investigation, Zeena will support her clients in taking all necessary steps to enhance their controls and is increasingly interested in the use of AI to help clients meet their compliance goals.
Joanna M Dimmock
Jo leads the Corporate Crime practice at Dentons and is a member of the UK Regulatory & Investigations team and the UKIME Compliance & Investigations group. She is a seasoned litigator with 20 years of experience in the full spectrum of white collar crime, with extensive experience in handling high-profile, cross-border and sensitive matters requiring press or reputational management.
During her 20-year career, Jo has been involved in many of the most significant white collar crime investigations and prosecutions brought by UK authorities. Her involvement in recent high profile investigations include retail companies, oil and gas consultancies, security companies, natural resource companies, transport companies, global business and investment companies and global logistics and shipping companies. She also regularly assists in multi-jurisdictional investigations involving agencies worldwide. These matters predominately relate to financial services fraud, multi-jurisdictional white collar crime allegations, bribery and corruption, tax fraud, competition/cartel allegations and insider trading.
Bethany Gregory
Bethany is an Associate at Dentons.
