Partner Ian Hargreaves and Associate James Philippsohn explore the impact of the EU’s new Anti-Money Laundering Regulation on football clubs

Partner Ian Hargreaves and Associate James Philippsohn examine the EU’s new Anti-Money Laundering Regulation and what it means for professional football clubs and agents, as the sport prepares for a significant new compliance regime.

Ian and James’ article was published in Thomson Reuters Regulatory Intelligence, 9 July 2026.

For decades, professional football has operated largely outside the financial compliance perimeter that governs banks and other gatekeepers. That era is ending.

Under the EU’s Anti-Money Laundering Regulation (AMLR), formally Regulation (EU) 2024/1624, professional football clubs and football agents will become obliged entities for the first time. The Regulation applies generally from 10 July 2027, but the legislature, recognising the practical challenges of applying AML obligations to professional sport, carved out a further two-year transition specifically for football: the obligations on clubs and agents bite from 10 July 2029.

For a sector the European Commission, Europol and the Financial Action Task Force have repeatedly identified as vulnerable to financial crime, this is no longer merely guidance or best practice. It is law.

A scoped obligation, not a blanket one

It is worth being precise here, because the temptation to over-read this Regulation is real.

“Obliged entity” status does not bring a club’s entire business under AML supervision. The Regulation brings professional football clubs within scope only in relation to four categories of transaction: dealings with investors; dealings with sponsors and advertisers; dealings with football agents or other intermediaries; and transactions connected with a player transfer.

The club’s ordinary operational activities, such as ticketing, merchandising, broadcasting revenue and payroll, are generally not themselves regulated activities under the AMLR.

Football agents fare worse. Brought within the AML regime in respect of their professional football-agent activities, they do not benefit from the same transactional carve-outs afforded to clubs.

The sensible first move for any compliance team is not to commission an AML programme for the whole club – it is to work out precisely which of the club’s activities fall within the four scoped categories. Where they do, the obligations are extensive: enterprise-wide risk assessment, clear board-level accountability for AML compliance, risk-sensitive due diligence on investors, sponsors, agents and transfer counterparties, beneficial ownership verification, ongoing monitoring, and suspicious activity reporting to the national Financial Intelligence Unit.

It is also worthy of note that clubs and agents will not be directly supervised by the new EU Anti-Money Laundering Authority (AMLA). Frankfurt will not be sending inspectors to the training ground – that job stays with national competent authorities.

AMLA’s role is methodological: it issues technical standards and guidance, coordinates peer reviews, and convenes supervisory colleges where a club sits within a cross-border group. In practice, compliance teams will deal with their domestic AML supervisor, operating to standards AMLA has set rather than enforced directly.

Where the risk concentrates

As has been the case for some time, the transfer market remains the obvious flashpoint for AML risk.

FATF has long pointed to player overvaluation, opaque third-party payments and offshore settlement as recurring typologies. Compliance functions would do well to prioritise enhanced due diligence on transfer-related payments now: verifying the source of funds, scrutinising the standing of agents involved, and challenging unusual payment structures or transactions involving high-risk jurisdictions.

Beneficial ownership transparency may prove one of the most challenging obligations in practice. Multi-club ownership structures and complex economic arrangements surrounding player rights and transfer proceeds can obscure ultimate beneficial ownership and complicate the transparency the regulation seeks to achieve.

As of mid-2023, roughly one in three top-division clubs in Europe were backed by private equity, venture capital, sovereign wealth or consortium capital, frequently behind several layers of holding company. Auditing those ownership charts properly takes time. Clubs should start now, not in 2028.

Exemptions exist, but nobody should bank on one

The Regulation allows Member States to exempt clubs presenting a “proven low level of risk”, although the threshold is likely to be higher than many clubs expect.

Top-division clubs qualify only if turnover has stayed below €5 million for two consecutive financial years and the low-risk finding is properly documented; lower-division clubs face no turnover threshold but still need a documented assessment behind them.

Any national exemption must be notified to the European Commission, which has two months to object, and exempted clubs remain subject to ongoing monitoring in case their risk profile changes. An exemption, in other words, is a privilege that can be withdrawn, not a permanent exit from the system.

The UK position

Notably, English clubs sit outside the AMLR’s direct reach with the Premier League frequently cited as the clearest example of a major league the Regulation simply does not touch.

That said, nobody in English football should mistake this for a free pass.

The Premier League has run its own Owners’ and Directors’ Test since 2004, barring anyone with an unspent conviction for fraud, tax evasion, bribery or money laundering from owning a club.

That self-regulatory mechanism now sits alongside a parallel statutory regime. The Independent Football Regulator, created under the Football Governance Act 2025, operates its own “Owners, Directors and Senior Executives” suitability test, modelled closely on the Financial Conduct Authority’s Senior Managers and Certification Regime, with the two bodies having signed a memorandum of understanding to coordinate.

The application window for provisional licences opens on 1 November 2026 and closes the following February, with each of the 116 clubs across the top five tiers of English football requiring a licence to compete from the 2027-28 season.

It remains to be seen whether, in addition to the licensing issue, the Independent Football Regulator will look to impose similar AML rules in relation to the English leagues. Further, as we have seen with the recent introduction of the Squad Cost Ratio (“SCR”) and its predecessor controls on spending, if an English club is playing in a European competition a level playing field may be expected requiring English clubs to have the same AML controls in place. Already, English clubs competing in Europe are looking to apply a 70% SCR as opposed to the more favourable 85% ratio being adhered to by other English clubs only playing domestically.

Compliance as a deal-breaker, not a footnote

A club’s compliance capability is fast becoming a material factor in acquisition due diligence, not a box to tick after the fact.

Ownership rules diverge sharply across leagues. Germany’s 50+1 rule restricts external control, while private equity already holds stakes in roughly half of Ligue 1 clubs. The resulting patchwork means some jurisdictions might be more attractive than others for investment and increases the importance of understanding not only who owns a club, but how ownership structures are organised and financed.

Prudent investors should treat those regulatory differences as a risk worth pricing in.

What to do now

Three years is a relatively short implementation period once governance, ownership mapping and transaction monitoring frameworks need to be designed and embedded.

As such, clubs and agents would be well advised, over the next twelve to eighteen months, to confirm which of their activities fall within the four scoped transaction categories, document their exemption position rather than assume one, audit beneficial ownership records across investor, sponsor and agent relationships, allocate clear board-level responsibility for AML compliance.

Further regulatory guidance will also be closely watched. The Regulation leaves a number of practical questions unresolved, including how concepts such as “customer” and “business relationship” should apply in a football context, that national supervisors have yet to resolve.

Clubs that begin preparing now will be in considerably better shape come 2029. And, in the meantime, early preparation should reduce regulatory risk, improve transaction readiness and strengthen governance long before the legal obligations formally apply.