Tackling Financial Crime in Football

Tackling Financial Crime in Football

The evolving risk landscape

With professional football now a global sports and entertainment powerhouse, football clubs and industry participants face exponentially higher financial crime risks. 

The legal and regulatory environment in the UK is now stricter than ever. This is due in large part to the proliferation of new legislation targeting economic crimes in recent years and the establishment of the Independent Football Regulator (IFR). In the EU, the 6th Anti-Money Laundering Directive will bring football clubs, including certain player transfers, and football agents within the scope of the EU anti-money laundering regime from 2029.  

Against this backdrop, top-tier clubs are at the greatest risk given their economic and cultural profile. Those competing in the Premier League and major European competitions are significant commercial enterprises generating substantial revenues from broadcasting, sponsorship, matchday tickets, merchandise and player sales. Clubs are also increasingly diversifying their revenue streams, such as hosting year-round stadium events. Financial crime risks in the sector are attracting closer scrutiny from policymakers. Notably, the most recent UK National Risk Assessment of Money Laundering and Terrorist Financing (NRA) observed that professional football has become "an attractive target for criminals, kleptocrats and other malign actors seeking to launder their criminal funds or generate further illicit gains." ¹

For clubs that fail to manage these risks, the likelihood of detection by the authorities is significantly higher than at any time in the past. Whistleblowers, both inside and outside of clubs, are more emboldened to come forward, and investigative journalists, driven by public appetite for increased transparency, are exposing financial irregularities and weak governance. Regulated firms such as banks who provide financing to clubs have mandatory obligations to identify and report suspicious activity under the Proceeds of Crime Act 2002. Most recently, the IFR itself has been granted broad powers of investigation, including the ability to enter and search business premises.  

All of this underscores the need for clubs to assess financial risks across their business activities and implement effective controls to mitigate the potential consequences including financial penalties, enforcement against senior managers, and reputational damage.  

What are the key areas of compliance risk? 

Anti-money laundering

A number of factors increase the risk of football clubs being used to launder money or as a vehicle for the investment of illicit funds. Beneficial ownership of clubs is often opaque. The NRA warns that "ownership structures using layered front and shell companies, often based overseas or in jurisdictions with low transparency, could obscure the ultimate beneficiaries of clubs and other major stakeholders, such as sponsorship arrangements."² Research by the University of Manchester found that, of the clubs in the Premier League for the 2023/24 season, 12 had at least 10% of their holdings which could not be formally traced back to their beneficial owners - primarily due to convoluted corporate structures and entities based in so-called "secrecy jurisdictions."³  

Football clubs are particularly cash-hungry businesses, but many clubs are struggling to remain sufficiently capitalised and are therefore susceptible as targets for placing illicit funds into a legitimate business. A recent report by Fair Game found that 43 of the 92 clubs in the Premier League and English Football League have less than one month's cash reserves to cover operating costs. ⁴ Bruna Szego, Chair of the EU's new Anti-Money Laundering Authority (AMLA) recently observed, "the more financially fragile a club is, the more exposed it becomes to the risk of an acquisition or investment involving non-transparent money, simply because the pressure to accept any funding can make it harder to ask the right questions." ⁵

Clubs routinely engage in high-risk transactions from a money laundering perspective. The most common example is player transfers which typically involve high but ultimately subjective valuations, frequently take place across borders, and are usually facilitated by agents and intermediaries relying on personal relationships and informal networks. As fans of "transfer deadline day" will attest, these transfers are often agreed at the last minute meaning that parties do not have time to conduct any meaningful assessment of the money laundering or compliance risks posed by the transaction.

Fraud

Fraud is the most commonly experienced crime in the UK; accounting for 40% of all crimes. The introduction of the failure to prevent fraud offence in September 2025 means larger clubs are now at risk of criminal liability where fraud is committed for their benefit.⁶ The range of fraud within scope of the offence is broad and includes false accounting under the Theft Act 1968. This is notable given the level of scrutiny of accounting practices at football clubs in recent years.

The IFR's stated objective of promoting the financial soundness of clubs is likely to bring further attention to the accuracy and completeness of financial records. Clubs that have historically operated with limited internal finance and compliance controls may find themselves particularly exposed.

Bribery and corruption

Transfer kickbacks, secret commissions and undisclosed payments to influence commercial deals have long been a risk in professional sports. Player transfers are particularly vulnerable to bribery resulting from a failure to manage conflicts of interest: for example, where an agent acts for both the buying and selling club, or for both the player and a club. 

In many cases, agents and intermediaries will be performing services for and on behalf of clubs as "associated persons" - a key concept under the Bribery Act 2010. Clubs will be strictly liable for a criminal offence if an associated person bribes another person to gain a business advantage for the club. The only defence is if the club can demonstrate that it had adequate prevention procedures in place.

A further risk is the increasing level of engagement with public or quasi-public officials, including at governing bodies and sovereign wealth funds. These interactions are generally perceived as higher risk from a bribery perspective given the prominent public positions held by such individuals and their ability to influence decision making.

Stadium development is an emerging area of bribery risk as clubs have embarked on ambitious construction projects: large budgets, multiple contractors and extensive supply chains are all factors which increase the inherent risk of financial crime. In a recent example of this, Italian prosecutors conducted dawn raids as part of an investigation into the sale of Milan's San Siro Stadium. 

Supply chain and modern slavery risks

Authorities globally have increased scrutiny of business and human rights risks, particularly arising from forced labour and poor working conditions in supply chains. Most top-tier clubs in the UK will now be within scope of the mandatory obligation under section 54 of the Modern Slavery Act 2015 to publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains. 

Key sectoral risks include the manufacturing of replica kits and merchandise which often involves multi-tiered supply chains extending to jurisdictions where forced labour is prevalent. The recruitment of youth players, particularly from overseas, has also been flagged as a high-risk practice by the Financial Action Task Force, a leading inter-governmental organisation responsible for setting global standards in relation to anti-money laundering. ⁷ Clubs should proactively assess the risk of coercive or deceptive recruitment practices and take steps to ensure that procurement processes include risk-based checks on direct suppliers and downstream business relationships. 

What practical steps can clubs take to mitigate the risks? 

1. Assess the compliance risks

Clubs should conduct a targeted risk assessment that identifies the specific compliance risks relevant to their operations. This should take into account the nature, scale and complexity of the club's activities and its relationships with third parties. Each identified risk should be assessed by reference to both the likelihood of the risk occurring and its potential impact, including legal, financial, regulatory and reputational consequences. The risk assessment should be documented, reviewed regularly and updated to reflect changes in the club's activities and the regulatory environment. 

2. Risk-based controls

The next step is to design and implement controls proportionate to the identified risks. A risk-based approach means that the most significant risks are subject to the most robust controls, while lower-rated risks are managed through lighter-touch measures. This may include enhanced due diligence for high-risk transactions as well as anti-fraud controls such as segregation of duties and approval thresholds for expenses. 

For supply chain risks, proportionate controls might involve requiring key suppliers to provide evidence of compliance with labour standards and including modern slavery clauses in procurement contracts. Controls should be tailored to the club's specific risks rather than adopting a generic, off-the-shelf compliance programme. 

3. Establish governance and compliance oversight

Effective governance is essential to ensure appropriate oversight of the compliance programme at the highest levels of the club. The Football Governance Act introduces prescribed senior management functions for regulated clubs with individual accountability. ⁸ Clubs should consider establishing a dedicated compliance function, or at a minimum, designating a senior individual with responsibility for overseeing compliance matters. The board or executive committee should receive regular updates on key compliance risks, the effectiveness of controls, and any incidents or near-misses.

Clubs should also ensure they have effective channels for reporting concerns, including a whistleblowing channel that provides confidentiality and protection against retaliation. These arrangements should be communicated to all staff and third parties, such as agents and contractors. Governance structures should be reviewed periodically to ensure they remain fit for purpose as the club's risk profile evolves. 

4. Raise awareness and develop a compliance culture

The effectiveness of any compliance programme will ultimately depend on the culture of the club. Policies and procedures are of limited value if they are not understood and applied across all operations. Senior management should champion compliance as a core value rather than a nice-to-have. Clubs should roll out training to raise awareness of risks and responsibilities, with targeted sessions for staff involved in commercial negotiations, player transfers and procurement, so they can identify and escalate red flags.

The club's compliance expectations should be communicated to third parties, including agents, intermediaries and suppliers. As AMLA Chair Szego put it in her recent message to the football sector: "We are counting on you. Your sector matters, and it matters that football is a clean and transparent market. Start preparing now."⁹

Authors: Neil Donovan (Partner), Tom Stroud (Senior Associate), Mark Donnelly (Associate) and Isabella Lynn (Trainee)