{"id":9575,"date":"2026-04-08T12:41:09","date_gmt":"2026-04-08T10:41:09","guid":{"rendered":"https:\/\/eulawenforcement.com\/?p=9575"},"modified":"2026-04-08T12:45:30","modified_gmt":"2026-04-08T10:45:30","slug":"kicking-out-corruption-how-will-amla-tackle-money-laundering-in-football-clubs","status":"publish","type":"post","link":"https:\/\/eulawenforcement.com\/?p=9575","title":{"rendered":"[DRAFT] Kicking out corruption: how will AMLA tackle money laundering in football clubs?"},"content":{"rendered":"\n

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By Ella, Mafalda, Daria, Melanie and Samantha<\/p>\n\n\n\n

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Source: Pixabay<\/figcaption><\/figure>\n\n\n\n

The 2026 World Cup is not the only thing FIFA (F\u00e9d\u00e9ration Internationale de Football Association) must keep an eye on. Behind the dynamic and thrilling world of football, lies a concealed truth. Through the exorbitant transfer fees and the hidden ownership structures, football clubs became the ideal target for money laundering. This is why this area will be regulated by the Anti-Money Laundering Agency (AMLA), an EU (European Union) agency which aims to investigate and prevent money laundering. Since May 2024, football clubs have been included in the anti-money laundering framework by the Regulation 2024\/1624<\/a> on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (AMLR), and, therefore, need to streamline their corporate structure, prepare information and documents for upcoming transactions, and ensure operation of a solid compliance function by July 2029. However, as of 2026, no guidelines or standards that target football clubs have been issued, leaving football clubs in the dark about how to interpret the new requirements. The decision to include football clubs in the AML regulation has been surprising and somewhat counterintuitive, because football clubs do not even qualify as financial entities.   So why is money laundering so prolific in football clubs that it needs to be regulated by AMLR? What is the role of the newly established AMLA when it comes to the regulation and supervision of football clubs?<\/p>\n

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  1. Why can football clubs attract dirty money? <\/strong><\/li>\n<\/ol>\n

    Money laundering works by making illicit funds appear legitimate, often by moving them through ordinary businesses and transactions<\/a>. Football clubs are especially attractive for that purpose because it combines<\/a> high financial volume, cross-border transactions and often opaque ownership structures. As AMLA itself explains, money laundering often disguises the criminal origin of funds by routing them through legitimate businesses<\/a> and football clubs can offer exactly that kind of cover. <\/p>\n

    The football sector has a number of characteristics that make it vulnerable. The Financial Action Task Force (FATF) has long warned that football has become a global industry with rapidly growing investment, whilst its regulatory frameworks have not always kept pace with the risks associated with that growth<\/a>. This sector involves substantial financial flows that are sometimes difficult to assess, including transfer fees, sponsorship deals, payments to intermediaries and cross-border investments<\/a>. This creates a lot of opportunities for criminals to funnel dirty money into seemingly normal business activities. <\/p>\n

    Scholars<\/a> argue that the football industry has become increasingly vulnerable to illicit financial activities due to its complex organisation, large financial flows and opaque ownership structures. These characteristics are significant because they facilitate<\/a> the concealment of the true origin of funds, the disguising of beneficial ownership and the justification of unusual payments as part of standard football business practice. In other words, the problem is not football itself, but the way its financial ecosystem can be exploited. <\/p>\n\n\n\n

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    Figure 1: How a football transfer can be exploited for money laundering.<\/figcaption><\/figure>\n\n\n\n

    The point is not that football clubs are inherently criminal. The problem is that its financial ecosystem can convert suspicious funds into transactions<\/a> that look commercially and socially legitimate. These structural vulnerabilities become especially visible in the transfer market, where large sums, cross-border deals and multiple intermediaries create clear opportunities for money laundering. <\/p>\n

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    1. How can money be laundered through player transfers?<\/strong><\/li>\n<\/ol>\n

      One of the money laundering tactics used in the football sector to disguise the illicit funds is through the over-evaluation of players in transfers. Since the Bosman <\/em>ruling in 1995 international player transfers have rapidly increased. In 2022 FIFA reported that international transfers had surpassed 20,000 players. In 2023 FIFA reported transfer fees reached up to 9,63 billion dollars, which shows a staggering 48.1% increase<\/a> from 2022. The report also showed a record in cross-border transfers of 74,836 dollars.<\/p>\n

      The difficulty of assessing the value of a player, makes it easy to artificially inflate the price and move money<\/a>. In football players are often transferred prior to their contracts ending, thereby the high transfer fee comes from the compensation of the new employer to the previous employer. In order to attract players, clubs and managers, benefits such as housing, cars or family arrangements may be included in deals, which increases the number of financial transactions and further obscures the transfer prices<\/a>.<\/p>\n

      Football agents are under the microscope of Regulation 2024\/1624 (AMLR) alongside football clubs as football agents often negotiate contracts in player transfers. In 2019, Portuguese authorities’ Operation Red Card<\/em><\/a> investigation uncovered a player transfer from Porto to Real Madrid worth 50 million euros of which 9 million was paid to two agents. According to the financial reports, Porto earned<\/a> 28,4 million euros from the transfer. The remaining sum of 21,6 million euros was split between three parties: two of whom were football agents.<\/p>\n

      In 2020, Spanish authorities uncovered a criminal network of several European football clubs which made fake player transfers to launder profits. The investigation uncovered<\/a> 10 million euros laundered through ghost transfers through a Cypriot football club. To conceal the origins of the dirty money it was invested into Spanish luxury assets such as yachts and real estate.<\/p>\n

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      1. What do the new AML obligations for football clubs entail?<\/strong><\/li>\n<\/ol>\n

        The logic is straightforward. The same features that make football economically successful also make it vulnerable to financial crime. <\/p>\n

        European authorities have seen how standard football deals can be inflated artificially and these risks are now considered structural to the industry. With that logic in mind, AMLR aims to close the regulatory gap and ensure consistent supervision across Member States.<\/p>\n

        Football clubs and agents are now classified as \u201cobliged entities\u201d among some other non-financial actors, who must implement customer due diligence (CDD) to prevent financial crime under the AMLR. <\/p>\n

        In practice, this means that football clubs need to<\/a>:<\/p>\n