Glossary Professional Football Clubs – EU AML Obligations

Professional Football Clubs – EU AML Obligations

Under the current Dutch anti-money laundering legislation (Wwft), professional football clubs are not classified as obliged entities. However, the upcoming EU Anti-Money Laundering Regulation (AMLR) will change this. Certain financial transactions conducted by professional clubs will soon trigger AML obligations.

The EU introduces anti-money laundering obligations for professional football clubs. Starting in 2029, professional football clubs will be considered obliged entities under European AML (anti-money laundering) rules, such as the AMLR (Anti-Money Laundering Regulation).

These obligations will apply to (intended) transactions with investors, sponsors, football agents, or other intermediaries, as well as to transactions related to player transfers.

Why do professional football clubs fall within the scope of the EU AML package?

There have been multiple cases where football clubs were used for laundering money, for example through inflated transfer fees or opaque sponsorship agreements. This is because player transfers, sponsorship deals, and club ownership structures often involve large sums and complex financial arrangements. In some cases, it is also difficult to identify the beneficial owner of a club.

Therefore, professional football clubs are considered a high-risk sector for money laundering and other financial economic crimes.

AML obligations for professional football clubs

Professional clubs must:

  • Conduct customer due diligence (CDD) for player transfers and sponsorship agreements,
  • Monitor transactions for signals of suspicious activity,
  • Report suspicious transactions to the Financial Intelligence Unit (FIU),
  • Identify and verify the identity of counterparties, including beneficial owners,
  • Understand the ownership and control structure of parties involved in transactions,
  • Assess the purpose, nature, and source of funds for each transaction,
  • Perform sanctions screening,
  • Assess and document all risks related to money laundering and terrorist financing.

Additionally, football clubs must establish a formal AML framework anti-money laundering policy, including:

  • Risk assessments,
  • Policies and procedures, 
  • Staff training,
  • Internal controls and compliance oversight.

Clubs should be prepared for supervision by regulatory authorities and for mandatory data reporting. 

When do the rules apply to professional football clubs?

The EU AML rules will largely take full effect in mid-2027. However, professional football clubs will not be subject to its obligations until 2029, giving them additional time to implement necessary changes. 

In the meantime, AMLA will play a central role in developing technical standards and guidelines that will further specify the obligations for football clubs. 

Consequences of non-compliance with the AML rules 

Failing to timely meet AML obligations may result in:

  • Significant fines imposed by supervisory authorities,
  • Binding enforcement measures,
  • Reputational damage and loss of trust from investors or other stakeholders, 
  • Financial losses.

Are there any exemptions?

Yes, but these are limited and conditional. EU Member States may exempt certain football clubs if their Yes, but these are limited and conditional. EU Member States may exempt certain clubs if their activities demonstrably pose a low risk of money laundering or terrorist financing. National authorities must conduct a risk assessment based on:

  • The size and nature of transactions,
  • Payment methods,
  • Geographic exposure.

Possible exemptions may apply to:

  • Top-division clubs with annual turnover below €5 million (in each of the past two years),
  • Lower-division clubs.

It should be noted however that even exempted clubs must remain transparent and subject to oversight. Misuse of an exemption can still lead to enforcement actions by the regulators. 

Curious how the AMLR affects other non-financial sectors?

Read more on how it impacts luxury goods dealers, football agents, and crowdfunding platforms.

Need help navigating AML obligations as professional football club?

Our compliance experts can help you assess your risks, implement the right controls, and prepare for regulatory supervision.

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