Football under AML scrutiny — clubs, transfers and agents

New EU rules will generally bring professional football clubs and football agents within the anti-money laundering (AML) framework. This follows from the adoption of the EU legislative package, including Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (OJ L, 2024/1624, 19 June 2024), commonly referred to as the Anti-Money Laundering Regulation (AMLR).

Until now, these requirements have mainly been associated with banks. However, substantial cross-border financial flows, complex ownership structures and the risk of artificially inflated player valuations have led the European Union to identify the football market as a sector exposed to money laundering risks.

When will the new obligations apply?

While the new rules will apply from 10 July 2027 to most entities covered by the AMLR, such as banks and tax advisers, the football sector has been granted a longer transitional period.

From 10 July 2029, professional football clubs and football agents will generally become subject to AMLR obligations.

Clubs must use this time to implement compliance systems and verification procedures proportionate to the size and risk profile of their operations. Failure to meet these obligations may result in substantial financial penalties and criminal liability for individuals in management positions.

Which clubs and activities are covered?

Under the EU definition, the rules concern licensed football clubs participating in national football leagues in Member States whose staff and players are contractually employed and remunerated.

AMLR obligations will not cover every aspect of a football club’s activities, such as selling tickets or scarves. Instead, they will apply to four specific categories of transactions:

  • player transfers between clubs;
  • transactions with football agents and other intermediaries;
  • transactions with investors, including changes to the club’s ownership structure;
  • transactions with sponsors, including sponsorship agreements and image rights agreements insofar as they constitute transactions with a sponsor.

How will the new rules affect player transfers?

Football transfers will become subject to anti-money laundering procedures. Clubs and agents will have to identify their customers under Know Your Customer (KYC) procedures and apply Customer Due Diligence (CDD) measures appropriate to the level of risk. In practice, this means:

  • examining the source of funds: the selling club will have to obtain information about the source of the money financing the transfer where required by the rules and the circumstances of the transaction. A connection with a high-risk jurisdiction or an opaque company requires appropriate analysis and may lead to additional verification, refusal to proceed with the transaction or the reporting of suspected money laundering. The fact that funds originate from a particular country does not automatically mean that they must be blocked.
  • identifying the ultimate beneficial owner (UBO): clubs will have to establish who ultimately owns or controls their counterparty, including a club or management agency that is their customer. Under the AMLR, the ownership threshold is generally 25% or more of the shares, voting rights or other ownership interests. Control exercised through other means must also be examined. For example, an individual may have the right to appoint a majority of the management board or hold preferential shares under the company’s articles of association that confer voting rights exceeding their capital holding and allow them to determine the company’s most important decisions.
  • putting an end to “creative accounting” in transfers: artificially inflated transfer values will come under scrutiny, including barter transactions and cashless player swaps recorded at inflated amounts to improve financial statements. An unusual transaction, or one whose value departs significantly from market realities, requires analysis. A report must be submitted to the competent Financial Intelligence Unit — in Poland, the General Inspector of Financial Information (GIIF) — where a club knows, suspects or has reasonable grounds to suspect that the money financing a transfer originates from crime or that the transaction is connected with criminal activity or terrorist financing (Article 69 AMLR). This obligation applies regardless of the transaction amount; proof that a crime has been committed is not required. However, an unusual valuation does not automatically require a report in every case.
  • the role of agents: football agents will become obliged entities in their own right. They must verify their customers, assess risks, document their actions and report suspicious transactions. The AMLR does not require every commission payment to be reported. Greater transparency in remuneration makes it more difficult to conceal unexplained payments. The rules governing football agents, including FIFA regulations and those of the relevant national association, also determine when an agent may represent both sides of a transfer and whether receiving commission from both parties is permitted.

Even before 2029, contracts in the sports sector may include AML clauses, as well as morality and preventive clauses. Sponsors want to protect their brands in the event that a club becomes linked to a money laundering investigation. A breach of procedures may entitle a sponsor to terminate a contract where this follows from its terms and the applicable law. The AMLR itself does not create an automatic right to terminate every agreement without compensation.

What sanctions may clubs and agents face?

Failure to comply with obligations under the AMLR and national anti-money laundering legislation may result in severe sanctions.

As football clubs and football agents become obliged entities, procedural failures, inadequate verification of counterparties or disregard of suspicious transactions may lead to administrative measures and financial penalties. Reputational consequences may also follow and, where the elements of a criminal offence are established, individuals may incur criminal liability.

Administrative financial penalties

Financial penalties imposed by national supervisory authorities can be substantial. Their amount depends on the seriousness and scale of the breach. Directive (EU) 2024/1640 establishes the following framework.

For serious, repeated or systematic breaches, the maximum penalty available under national law must be at least EUR 1,000,000 or twice the benefit derived from the breach, whichever is higher (Article 55(2) of Directive (EU) 2024/1640). This is not a minimum penalty for every breach. It is the minimum level at which the statutory maximum must be set. Member States may provide for higher maximum penalties.

Organisational and operational measures

For a football club, these measures may be more disruptive than financial penalties because they can affect its ongoing sporting and business activities.

An order to cease infringements — the authority may order a club to stop unlawful practices. Suspending a transfer or blocking funds requires a separate legal basis and the appropriate procedure; neither is an automatic penalty for every procedural omission.

Licences and authorisations — Article 56(2)(f) of Directive (EU) 2024/1640 provides for the withdrawal or suspension of an authorisation where an obliged entity is subject to an authorisation requirement. This does not mean that an AML breach automatically results in the withdrawal of a Polish Football Association (PZPN) licence to participate in competitions. Any licensing consequences must be assessed under the relevant rules.

A ban on exercising managerial functions — this may apply to individuals responsible for breaches within management bodies or to other responsible individuals. The scope and duration of a ban depend on the applicable provisions and the relevant decision.

Reputational sanctions

Publication of information about a penalty — the rules provide for the publication of certain sanction decisions, subject to exceptions concerning, among other matters, the proportionality of disclosing personal data or the protection of proceedings. For a club, this may have serious reputational consequences, including the withdrawal of sponsors, depending on the circumstances and contractual provisions, or difficulties obtaining financing, depending on a bank’s risk assessment.

Penalties do not require proof that a club participated in money laundering. Breaches may also consist of organisational shortcomings, such as:

  • failure to implement an internal AML procedure tailored to the club’s activities;
  • failure to train employees in the transfer and accounting departments;
  • failure to designate a person at management board level directly responsible for compliance;
  • failure to identify the ultimate beneficial owner, for example when entering into a transfer agreement with a club or agency whose true owner behind an offshore structure has not been established.

Criminal liability

Alongside administrative penalties imposed on a club, individuals — including presidents, management board members and designated compliance staff — may incur personal criminal liability where the elements of a particular offence are established. Under current Polish law:

Intentional failure to notify the GIIF, as well as providing it with false information or concealing true information, is punishable by imprisonment for between three months and five years under Article 156(1) of the Polish Anti-Money Laundering Act. Unauthorised disclosure of information may carry the same penalty. Obstructing an inspection is punishable by a fine under Article 157.

This does not amount to general criminal liability for every error in a KYC form. Negligent failure to notify the GIIF and negligent commission of an offence under Article 156(2) are punishable by a fine under Article 156(3).

Where it is established that a club’s managers knowingly participated in money laundering — for example, by using a transfer to disguise the movement of funds belonging to an organised criminal group — separate liability may arise under Article 299 of the Polish Criminal Code, carrying a prison sentence of up to ten years.

What specific obligations must a club fulfil to avoid these penalties?

Management must ensure that two key functions are in place: a person at management body level responsible for implementing the rules and an operational AML compliance officer. These functions may be combined where justified by the nature, size and risk profile of the business.

During a transfer window, the relevant tasks include:

  • Verifying the identity of counterparties (KYC): before carrying out a transaction, the club must identify and verify its customers and the persons acting on their behalf. This may include the buying or selling club, an agent or a player, depending on who is the customer of the entity concerned and the activity being performed.
  • Establishing the ultimate beneficial owner (UBO): the club must identify the individuals who ultimately own or control the customer — generally through ownership of 25% or more of the shares or voting rights, or through other means of control. If the ownership structure cannot be clarified and the required verification cannot be completed, the transaction should generally not proceed. Registration of a company in Delaware or Cyprus does not, by itself, justify refusal.
  • Examining the source of wealth and funds: to the extent required by the rules and the risk assessment, the club must examine the source of the funds and, in specified circumstances, the source of wealth. Connections with sanctioned persons or entities must be assessed separately. Russian or Belarusian capital does not automatically mean that every transaction is prohibited.
  • Identifying Politically Exposed Persons (PEPs): the club must check whether the customer or its beneficial owner is a politically exposed person and apply the required enhanced measures. The presence of a politician in a counterparty’s management does not automatically mean that the relationship falls within the PEP regime.
  • Suspicious Activity Reporting (SAR): if a club knows, suspects or has reasonable grounds to suspect that funds or activities are connected with crime or terrorist financing under Article 69 AMLR, it must promptly submit a report to the competent Financial Intelligence Unit — in Poland, the GIIF — without unlawfully informing the parties. A sudden change of payment account to a bank in a high-risk jurisdiction is a warning sign requiring analysis, rather than an automatic basis for a report. Article 71 governs refraining from carrying out transactions, while Article 73 prohibits tipping off.

How will inspections work, and how can clubs protect themselves?

Inspections by the competent authorities may be scheduled or triggered by identified risks and suspicions. The detailed powers, inspection procedures applicable to clubs and the involvement of the GIIF and other authorities will be determined by the relevant national legislation. Mandatory participation by customs and tax authorities should not be assumed in every inspection.

The inspection process: inspectors may request documentation and access to information within the limits of their powers, including transfer agreements, agent payment records and internal registers. They will examine whether the club genuinely assessed the risks or merely “rubber-stamped” the agreement. AML documentation is generally retained for five years after the end of a business relationship or an occasional transaction. This is not a universal time limit for every inspection.

How can clubs protect themselves against penalties during inspections?

Audits and updated risk assessment procedures: a club must have a written, regularly updated risk assessment procedure tailored specifically to the sports market rather than copied from a bank.

Staff training: individuals whose duties are relevant to AML obligations should receive appropriate training, and its completion should be documented. The Regulation does not impose a general requirement for every employee in scouting or sporting departments to complete externally certified training.

Process automation and AML systems: clubs must provide tools and resources appropriate to the size and risk profile of their operations. Specialist software can assist with sanctions screening, PEP checks and ownership analysis, but the AMLR does not require every club to purchase a particular system. Software alone does not demonstrate that due diligence has been performed.

The paper trail principle: every decision to approve a transfer, including one taken under time pressure in the final minutes of transfer deadline day, must be reflected in the documentation. If the AML compliance officer concludes that a transaction is safe, the system must contain a written explanation of the basis for that assessment.

Exceptions and exemptions for smaller clubs

The AMLR provides for specific exceptions and exemptions, recognising that imposing full and costly compliance obligations on smaller local clubs could place an excessive financial and organisational burden on them.

Exemptions are governed by Article 5 AMLR. Member States may decide to grant full or partial exemptions, distinguishing between two groups of clubs.

Clubs in the highest national division, such as Poland’s Ekstraklasa

A club competing in the highest national division may be exempted from AML obligations only if two conditions are met jointly.

Financial threshold: its total annual turnover must have been below EUR 5,000,000, or the equivalent in national currency, in each of the two preceding calendar years. Most Ekstraklasa clubs significantly exceed this threshold.

Low risk: the relevant Member State’s risk assessment must establish that the nature and scale of the club’s activities present a low risk of money laundering, associated predicate offences or terrorist financing.

Clubs in lower divisions, such as Poland’s I Liga and below

For clubs competing below the highest national division, national ministries or supervisory authorities may also apply an exemption.

The fixed EUR 5 million financial threshold does not apply to lower-division clubs.

The key criterion remains a demonstrated low level of risk. Playing in a lower division does not automatically mean an absence of large transactions or international financial flows. Such clubs may also face significant risks.

EU rules allow Member States to introduce exemptions but do not require them to do so. Some countries may decide not to introduce any exemptions and to bring all professional clubs, both men’s and women’s, within the AML framework.

European Commission approval: a proposed exemption must be notified to the Commission together with a justification based on a risk assessment. The Commission has two months to confirm that the exemption may be granted or to issue a reasoned refusal. It may request additional information. Following confirmation, the Member State may grant the exemption under Article 7 AMLR.

No exemption for agents under Article 5: this provision applies to clubs, not football agents. A low level of agency turnover does not, by itself, provide an equivalent exemption. The rules cover football agents within the meaning of the AMLR, rather than all sports intermediaries.

Limited scope of obligations for large clubs: even the largest clubs, such as Real Madrid or Legia Warsaw, are subject to obligations in their capacity as clubs in four areas: player transfers and transactions with agents and other intermediaries, sponsors and investors. Ticket sales and traditional merchandising do not, on that basis, become separate categories of transactions covered by the AMLR.

Legal basis

Legal position reviewed as at 21 October 2026. The specific national arrangements applicable to clubs in 2029 must be assessed in light of the legislation in force at that time.