Football's compliance clock is ticking toward 2029 AML deadline

Carlo Boffa, EU Correspondent for AML Intelligence, reports on the anti-money laundering rules set to reshape football from 2029 - and the growing warnings from compliance professionals that the industry is unprepared.

Football is about to join the ranks of regulated industries, but compliance professionals warn the sport is nowhere near ready for the anti-money laundering rules that will apply to EU clubs and agents from July 2029.

‘If there were an inspection of every football club today, it is likely that very few will be close to being ready’, said Jeffrey Greenbaum, a partner at law firm Hogan Lovells Cadwalader. 

Football clubs lack the compliance culture that other regulated sectors have built up over decades. More troubling for the officials who will oversee the sector is how little engagement clubs and agents have shown so far.

‘I conducted a roadshow across all EU Member States’, Bruna Szego, Chair of the EU's Anti-Money Laundering Authority, said in an interview. ‘In some cases, there were also representatives from the football sector, but that was more the exception than the rule. This gave the impression that the football sector may not yet have fully understood that it needs to be ready by 2029’, she added.

AMLA is the EU agency tasked with supervising implementation of the new Anti-Money Laundering Regulation across the bloc. It has no direct supervisory powers over football clubs and agents, but it will coordinate national supervisors and set the standards that regulated entities must follow.

Clubs counter that they have already started preparing. The European Football Clubs association has begun organising workshops, attended also by European Commission officials, to familiarise the sector with the new rules.

But it remains unclear whether AML checks designed for banks and applied equally to financial and non-financial firms under the EU regime are fit for a sector that operates so differently.

‘Applying rules mainly designed for banking and financial flows to the football industry, which operates completely differently, is quite challenging’, said Elisabetta Zeppieri, counsel at Hogan Lovells Cadwalader. ‘It's a totally different business - and above all, the people who currently run this business have no sensitivity to this area’, she said.

A sport that attracts dirty money

International organisations have long argued that football's vast money flows and global reach make it attractive to oligarchs and tycoons seeking respectability, and to criminals seeking to launder illicit funds. Europol has singled out football as the sport most targeted and manipulated by organised crime groups, citing its popularity, financial scale and large betting market.

Law enforcement investigations into these flows have reached the top of the sport's governance and dented its reputation. Belgium became the first EU country to impose AML rules on the sector in 2020, after ‘Operation Zero’ engulfed some of its biggest clubs in a scheme involving match-fixing, financial fraud, tax evasion, and money laundering two years earlier. Belgium also pushed for professional clubs and agents to be brought into the EU's new AML framework.

EU legislators sparred for over three years between 2021 and 2024, with the European Parliament's position ultimately prevailing: clubs and agents with a turnover of at least EUR 5 million will be subject to the rules, with a two-year derogation from the 2027 start date that applies to other sectors.

‘The governance of football is extremely relevant at the moment. People love the sport, but they also think it is corrupt, and they have thought so for a very long time’, said Justin de Swardt, a director at Synarch, a firm that designs governance, security, and compliance systems.

‘I do not believe AML regulations will transform the sector, but the case for them is strong from a high-level political perspective.’

Money troubles could slow compliance

For all the money flowing through the game, most clubs' finances are far from healthy, and that could be one of the biggest obstacles to compliance, according to Greenbaum, who advises Italian football clubs on their new obligations.

Italian clubs peaked in the 1990s, when local tycoons bought up the best players in the world. Since then, they have lurched from crisis to crisis and fallen behind Spanish and English rivals that modernised faster and now draw far bigger audiences. With little money to spare, compliance spending is unlikely to be high on their list of priorities.

‘Italy is no longer the top destination for star players like it used to be for a variety of reasons. If clubs have to bear more AML compliance costs before the French and Spanish do, that's a problem’, Greenbaum said. ‘There will be a competitive dimension to this too - we can't spend this money if our competitors aren't spending it’.

The problem goes beyond cost, according to de Swardt: clubs will be asked to police the transactions that make up their entire business, not just flag unusual ones.

‘Due diligence obligations attach to their relationships with sponsors, investors and advertisers. Those are not incidental transactions, they are the whole business model’, he said.

Clubs have pushed for carve-outs, arguing that their business model sets them apart from other regulated entities. But their reluctance to engage has made it difficult for authorities to open a direct dialogue, leaving the sector unprepared with the deadline now three years away.

De Swardt argues that clubs are squandering their best chance to influence how the rules will apply to them.

‘There seems to be a view that 2029 is very far off’, he said. ‘That is a mistake. Right now, clubs and agents have the best opportunity they will ever have to shape how they are regulated, and to build compliance programmes that actually enhance the way they do business’, he explained.

About Carlo Boffa

EU Correspondent for AML intelligence

 

Carlo is a Frankfurt-based freelance journalist. He is the EU Correspondent for AML Intelligence, covering the EU's Anti-Money Laundering Authority and AML/CFT regulation across the continent. He began his career in Poland with Thomson Reuters before joining Politico, where he reported on the European Central Bank and the broader European economy.

Carlo holds a bachelor’s degree in Journalism from the University of Kent and one in Economics and Finance from the University of London.