On 10 July 2029, the EU's AML Regulation starts to apply to football agents and professional football clubs, two years after it reaches banks and the other obliged entities. Agents are covered in full. For clubs the Regulation covers four kinds of transaction: with investors, with sponsors, with agents or other intermediaries, and for player transfers. A member state can exempt a top division club whose turnover stayed under EUR 5,000,000 in each of the two previous calendar years, on proven low risk. Recital 24 says clubs and agents should carry out customer due diligence on investors, sponsors (advertisers included) and other partners and counterparties. Each football method below sits in one of the three stages of money laundering methods and typologies: placement, layering and integration.
How is money laundered through football?
Football is a sport with its own FATF report and its own clauses in the EU AML Regulation. Criminals use it to place, move and settle dirty money where large, irregular payments are normal. In 2009 the FATF's report Money Laundering through the Football Sector found the problem deeper and more complex than previously understood and traced the flows to club and player ownership, the transfer market, betting, image rights, and sponsorship or advertising deals. The techniques ran from basic to complex. The cases used cash, transfers across borders, tax havens, front companies, non financial professionals and PEPs.
Placement can happen at the turnstile. In 2009 the FATF reported clubs that earned much of their revenue from tickets taking nearly all of it in cash. Layering runs through transfer fees and agent fees paid abroad, and integration ends in ownership, where the money becomes a club.
Why is football vulnerable to money laundering?
The FATF's 2009 reasons start with structure. Entry barriers are low or absent, and opaque networks of stakeholders depend on each other. Player prices can look irrational and are hard to control. Clubs in debt are exposed: "There is a risk that clubs that are in debt will not ask many questions when a new investor appears." Part of the return is social. In the FATF's reading, a criminal who puts money into a club buys entry to a social circle along with it.
The EU restated the case in 2024. Recital 24 of the AML Regulation cites football's global popularity, the large sums and cash flows, frequent transactions across borders and sometimes opaque ownership, and names investors, sponsors and player transfers as key risk areas.
Where does the money move? Ownership, transfers, agents, image rights
The 2009 report gathered more than twenty cases; one per channel shows what a bank sees.
Ownership. A club in financial difficulty needed several million euros to avoid bankruptcy, in a case Belgium reported after a bank's disclosure to its FIU. A financial group from South America offered the money and withdrew once the bank asked where the funds came from. A second offer came from a European investor through a tax haven company: someone new to sport, known to the police and the FIU for fraud. For the second, the next question is who stands behind the tax haven company, and KYB and UBO verification answers it by tracing the owners, one layer at a time, up to the natural persons who ultimately own or control it.
Transfers. The FATF found two weak points: little transparency about how some transfers are funded, and fees paid offshore into accounts whose beneficial owners face limited disclosure. The FATF likened paying too much for a player to over invoicing goods in trade based money laundering: the excess carries the money inside a price that is hard to call wrong.
Agents. In a case France reported, banks filed suspicious transaction reports on a company that advised sports people. The FIU found the company and the individual running it working as a players' agent without the required FIFA license, with many incoming wires from a licensed agent abroad closely linked to organized crime. The file went to the public prosecutor. Under FIFA's current Football Agent Regulations, the edition in force since 1 January 2025, only a licensed football agent may provide agent services (article 11).
Image rights and sponsorship. In a UK case, a foreign player had moved the image rights to a company in a known tax haven, and the club paid for rights it never used. Advice after two years found the image had no commercial value, yet the club later raised both the playing and the image payments. The club conceded the deal was part of the employment terms and paid £938,688 in additional duties, with £404,480 more due over the contract's life. The FATF's conclusion was that image rights disguise what a payment really is, and it put sponsorship and advertising deals in the same risk area.
What did Julius Baer do in the FIFA case?
From about February 2013 to May 2015, Bank Julius Baer, a bank under Swiss AML law, conspired through one of its relationship managers to launder at least $36 million in bribes paid to soccer officials in exchange for broadcasting rights to matches. The relationship manager moved about $25 million of the bribes agreed for one senior FIFA official into a sub account at the bank. It sat there for that official. On 27 May 2021 the bank admitted in federal court in Brooklyn that it had conspired to launder the bribes through the United States, the Justice Department announced. It entered a three year deferred prosecution agreement and agreed to pay more than $79 million: a fine of $43,320,000 and forfeiture of $36,368,400. The relationship manager had pleaded guilty in June 2017 and was sentenced in November 2020.
Had supervisors or compliance staff meaningfully reviewed the relationship manager's due diligence and alert responses, the release says, they would have found "multiple, significant red flags." Among them were facially false contracts, payments to third parties at the direction of a FIFA official, and services said to come from shell companies. The bank knew the accounts were tied to international soccer, generally understood to carry high corruption risk. An executive still directed that the accounts be opened on a fast track.
Banks can use this at onboarding. Accounts of sports marketing firms and of federation officials call for enhanced due diligence on the account's purpose, its counterparties and the contracts behind the payments, with corruption as the predicate offense to test for.
Who checks a football club owner's money?
Chelsea FC shows what happens when an owner is sanctioned. The UK sanctioned Roman Abramovich in 2022, after Russia's invasion of Ukraine, and the proceeds of the club's sale that year have sat frozen in a UK bank account since. On 17 December 2025 the government issued an OFSI license that permits more than £2.5 billion to go to humanitarian causes in Ukraine, on terms under which the funds cannot benefit Roman Abramovich or other sanctioned individuals. As of November 2026, gov.uk has published no later step.
Three checks now reach an owner's money.
The bank. A bank holding a club's or an owner's account screens the owner, investors, sponsors and agents when the relationship opens and for as long as it runs. complead, formerly Sanction Scanner, runs that check through client screening and ongoing monitoring. 3,500+ sanctions, PEP and watchlists from 220+ jurisdictions, refreshed every 15 minutes, stand behind each name it screens.
The regulator for English football. Since 5 May 2026, when section 28 of the Football Governance Act 2025 came fully into force, nobody may become an owner of a club the Independent Football Regulator regulates until the regulator finds that person suitable. The application must state how the club's costs will be funded and from what source. An individual passes only with the ownership fitness criteria met (honesty and integrity, financial soundness), enough financial resources, and a regulator that "does not have grounds to suspect that the applicant has any source of wealth which is connected to serious criminal conduct". That last condition writes a source of funds and source of wealth test into statute.
The FIFA Clearing House. The Clearing House is a payment institution established in France, licensed there and supervised by the French Prudential Supervision and Resolution Authority. It handles training reward payments between clubs (the solidarity mechanism and training compensation). Before it accepts a club as a client, it runs a compliance assessment. Article 15.3 of its January 2026 Regulations lets it ask about corporate and organizational structure, beneficial ownership, source of funding and source of wealth. Its determination is final and binding.
How does one transfer move, and where are the checks?
| Stage | Input | Output | Who decides | What a compliance team checks |
|---|---|---|---|---|
| Agreement between clubs | Fee, installments, agent mandates | Signed transfer agreement | Both clubs | Fee against the player's record and comparable deals; prices can look irrational (FATF, 2009) |
| Registration in FIFA's Transfer Matching System (TMS) | Transfer data | Transfer recorded with FIFA | Each club uploads it within 14 days (FIFA agent rules, art. 18(1)(f)) | The agent and the amounts in TMS match the payments |
| Transfer fee payment | Fee or installment | Bank to bank transfer | Paying club and its bank | Who owns the destination account, and in which country |
| Agent service fee | Representation agreement, invoice | Payment to the agent, outside the Clearing House | Club and agent | FIFA license confirmed before signing (art. 18(1)(c)); payee is the agent, not a consulting company |
| Training rewards | Electronic Player Passport, Allocation Statement issued by FIFA | Payment to training clubs through the Clearing House | FIFA Clearing House | Compliance assessment: ownership, source of funding, source of wealth; final |
| Owner or investor funding | Equity or loans to the buying club | Money for the fee | Owner, club; for an English club, the regulator for a new owner | Source of funding and source of wealth; tax haven vehicles |
Table 1. One international transfer, stage by stage (as of November 2026)
Two rows carry most of the risk. The transfer fee row is where an inflated price moves money, so the check is the destination account: its beneficial owner and its country, the weak point the FATF named in 2009. The funding row is where criminal money enters the club. For an English club it is now the one row with a statutory test, the source of funding in the owner's application and the regulator's source of wealth question.
When do EU football clubs fall under the AML Regulation?
EU football agents and professional football clubs fall under the AML Regulation from 10 July 2029, as Regulation (EU) 2024/1624 stands in November 2026. The rest of the Regulation applies from 10 July 2027. Football waits two more years (article 90). Agents and clubs join the Regulation's non financial obliged entities, the group the FATF calls designated non financial businesses and professions.
A football agent is any natural or legal person who, for a fee, represents players or clubs in negotiations (article 2(1)(53)). A professional football club is a legal person that is, owns or manages a licensed club in a national league with paid, contracted players and staff (article 2(1)(52)). For clubs the duties cover four kinds of transaction: "with an investor", "with a sponsor", "with football agents or other intermediaries" and "for the purpose of a football player's transfer" (article 3(3)(o)). Each matches a flow the FATF traced in 2009.
Top divisions get the stricter treatment. Recital 25 says top tier clubs do larger transfer and sponsorship deals, may have several layers of ownership and deal across borders more often.
Which clubs can be exempted?
A member state may exempt, in full or in part, a top division club with total annual turnover under EUR 5,000,000 in each of the previous 2 calendar years, on proven low risk (article 5). Lower division clubs need proven low risk only. The member state must first assess the clubs' risk, then monitor that exemptions are not abused.
What red flags should a bank watch on a club account?
Each flag traces to a FATF case, the Julius Baer release or a rule, grouped by the four transaction types the AML Regulation names. A flag is a reason to ask, and the analyst decides what the answer is worth.
Investors
- A new investor with no football background, through a tax haven company. In the Belgian case, the investor turned out to be known for fraud; trace the ultimate beneficial owner before the money arrives.
- A sanctioned or PEP owner, investor or sponsor. PEPs were among the FATF's techniques in 2009, and the Chelsea sale proceeds have stayed frozen since 2022.
Sponsors and commercial deals
- Image rights or sponsorship paid to an offshore company and never used. The UK case paid a tax haven company for an image the club never exploited.
Agents and intermediaries
- An agent paid through a consulting company, or without a license. The French case had both; FIFA allows only licensed agents to provide agent services.
- Payments to third parties on an official's instruction, false contracts, services from shell companies. These are the red flags the Justice Department listed in the Julius Baer case.
Transfers
- A fee far above comparable deals. Overvaluing a player moves money the way over invoicing moves it in trade.
- A fee or installment sent to a third country account, or to an account the selling club does not own. The FATF's 2009 weak point: offshore destinations with limited beneficial ownership disclosure.
On the account itself
- Cash takings out of line with attendance. In 2009 the FATF saw clubs that relied on ticket sales take nearly all their revenue in cash.
What changed in 2026
Football's owner and payment checks changed on three dates.
- December 2025 (lead in). The ownership fitness criteria of section 26 of the Football Governance Act came fully into force on 12 December 2025 (S.I. 2025/1286). On 17 December 2025 the FIFA Council approved new Clearing House Regulations and the UK issued the Chelsea license.
- 1 January 2026. The January 2026 edition of the Clearing House Regulations came into force, with the compliance assessment of article 15.
- 5 May 2026. S.I. 2026/477 brought section 28's owner test fully into force, together with the duty to notify the regulator of a prospective new owner (section 27) and the incumbent owner rules (section 34).
One question stays open. How did bribes paid for broadcasting rights become clean money, and what could a bank see before anyone called them bribes?
