How does the new EU Anti-Money Laundering Regulation impact football clubs & agents

Professional football clubs and agencies will be subject to the new EU Anti-Money Laundering Regulation (AMLR)^[1]. The AMLR places strict compliance requirements on these newly classified ‘obliged entities’, which will be an entirely new field for many of them. Football-related money transactions as part of sponsorship deals, player transfers, and club investments will fall under much greater scrutiny.

Football moves enormous sums across borders at speed, often through opaque ownership structures, what are obvious channels for criminals seeking to launder illicit funds. The greatest exposure lies in transactions with investors and sponsors and in the transfer of players.

The AMLR applies from 10 July 2027, and will be in force for the football sector from 10 July 2029. Given the amount of preparatory work required in setting up a compliance function, football stakeholders should start early.

The EU’s central Anti-Money Laundering Authority (AMLA) has already launched consultations and will hold public hearings, which give football stakeholders opportunities to engage in the implementation of the AMLR and to provide feedback^[2].

This legal update outlines the key risk areas, the new obligations, and proactive measures that impacted clubs and agencies should take.

Key Takeaways

• New EU Anti-Money Laundering Regulation aims to enhance transparency and prevent the misuse of football transactions for financial crimes.
• New regulatory obligations on clubs and agencies, as they must develop robust compliance management systems (CMS) to implement new policies and controls. They must run customer due diligence (CDD) on their business partners, and monitor and report suspicious activities effectively.
• Sponsorship Deals, Agency Payments, Player Transfers come under scrutiny.
• Proactive measures advisable to assess and build CMS, install new compliance functions, and to exchange best practices with other stakeholders.
• Keep informed & be heard through participation in consultations and by assessing guidelines of the EU Anti-Money Laundering Authority (AMLA).