Professional football is coming into the scope of AML obliged entities. This is not a best-practice recommendation or a sporting integrity code: it is the same obligation that applies to a bank, adapted to a club. This page explains which clubs are in scope, from when, which transactions are monitored and what a club needs to set up to be ready in time.
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The answer is not the same for every club. Regulation (EU) 2024/1624 brings professional football within scope, but it allows Member States to exclude certain clubs where they demonstrate a lower risk, and it sets a financial threshold for doing so. Before you set anything up, you should know which side of that line your club is on.
A professional football club is an AML obliged entity when it falls within the scope set by Regulation (EU) 2024/1624 and the Member State has not exempted it.
Being one means taking on the full package: due diligence on counterparties, identification of beneficial ownership, record keeping, suspicious transaction reporting, internal control and training.
Member States may exempt, in full or in part, certain clubs where they demonstrate a lower risk. For top-division clubs, this exemption is envisaged where turnover in each of the two previous years was below €5 million.
In lower divisions, the exemption depends on demonstrating low risk. Spain has not yet settled how it will exercise this option.
A football club is not a financial institution, but it moves money through channels that a supervisor immediately recognizes as risk vectors: capital inflows of unclear origin, international payments to intermediaries, contracts with corporate structures spanning several jurisdictions and valuations that only the football market considers normal.
| Transaction | Where the risk lies | What will need to be documented |
|---|---|---|
| Player signings and transfers | Prices with no market benchmark, split payments to third parties and intermediate jurisdictions with no substance. | Source of funds of the buying club, identity and beneficial ownership of every receiving party, and the economic rationale for the transaction. |
| Commissions to intermediaries | Amounts out of proportion to the transaction and recipients other than the agent who negotiated it. | Representation agreement, agent’s license, actual provision of the service and a match between who negotiates and who gets paid. |
| New shareholders coming in | Purchases of shares with funds of unproven origin or through opaque corporate chains. | Beneficial ownership down to the natural person, source and origin of the funds, and no interposed persons or entities. |
| Shareholder loans and guarantees | Financing of the club by its owner without market terms or traceability. | Agreement, actual bank flows and consistency with the lender’s declared financial position. |
| Sponsorships | Sponsors with no verifiable business, disproportionate amounts or links to the club’s own shareholders. | Identification of the sponsor, its beneficial ownership and the economic reasonableness of the agreement. |
| Image rights | Assignment to interposed companies in low-tax jurisdictions. | Structure of the assignment, ownership of the receiving companies and substance of the transaction. |
| Ticket and season-ticket sales | Cash payments above the limits and bulk purchases by third parties. | Amount controls, identification above a threshold and traceability of payment methods. |
| Transactions with related clubs | Transfers between clubs in the same group or under common ownership at prices of convenience. | Map of multi-club ownership and price justification for related-party transactions. |
List drawn up from the risk-based approach of Regulation (EU) 2024/1624 and supervisory practice in comparable sectors. Each club’s risk self-assessment will need to specify which of these vectors are relevant to its own situation.
A club starting from scratch has to build in three years what a financial institution has spent fifteen years perfecting. The good news is that the starting point is well defined and the timeline is comfortable if you start early.
The founding document of the system: identifying and assessing the club’s own risks by transaction, counterparty, channel and jurisdiction. Everything else is calibrated on this analysis, and without it the other pieces do not hold up.
A manual tailored to how a club actually operates, not a template from another sector: signings, commissions, sponsorships, shareholders and ticketing. It includes the counterparty acceptance policy and the decision procedure when an alert is raised.
The specific procedure for the transaction that concentrates the most risk: what is requested from the counterparty, how the source of funds is verified and what is kept on file.
Identification of the beneficial owners of the club and of its counterparties, and analysis of transactions involving new capital and multi-club ownership.
Design of the control structure, appointment of the representative before the authority and definition of reporting lines within the club.
Training is not for the legal department: it is for the people who negotiate signings, sign sponsorships and deal with intermediaries. That is where alerts are spotted.
Being an obliged entity does not mean monitoring fans: it means knowing the counterparties the club does business with and being able to prove that their origin was checked before signing. These are the six obligations that structure the system.
| Obligation | What it means for a club |
|---|---|
| Due diligence | Identifying and verifying who the counterparty is—selling club, agent, sponsor, investor—before establishing the relationship and on an ongoing basis for as long as it lasts. |
| Beneficial ownership | Getting to the natural person behind every company the club contracts with, including indirect ownership chains. |
| Source of funds | Being able to explain where the money coming into the club comes from, especially in capital increases, shareholder loans and large sponsorships. |
| Record keeping | Filing the documentation and analysis of each transaction for the legal retention period, in a way that can be retrieved years later. |
| Reporting | Detecting suspicious transactions and reporting them to the authority, with an internal procedure that sets out who analyzes and who decides. |
| Internal control and training | Manual, control body, representative before the authority and documented training for the staff who negotiate. |
How the general framework of Regulation (EU) 2024/1624 applies to football. The details of each obligation and the specific thresholds must be checked against the articles of the Regulation and the Spanish implementing law.
Five milestones, from the adoption of the EU package to the first day a club can be inspected.
Regulation (EU) 2024/1624 adds professional football clubs and football agents to the list of obliged entities, alongside other new sectors such as crypto-assets and high-value goods.
The Council of Ministers approves, at first reading, the comprehensive reform of the AML framework, which creates the ANIFI and brings in the new obliged entities. This is the text in which Spain will decide how it exercises the exemption option for clubs.
Window open for submitting comments. It is especially relevant for football: this is where it is decided whether the threshold and the division criterion leave part of the sector out or not.
The other obliged entities start applying the new framework. Clubs do not yet, but it is worth watching how the first practical questions are resolved: the approach that settles then will be the one applied later.
The date from which professional football clubs and football agents are fully subject to the rules. By then the system has to be up and running, not under construction.
The consequence of not preparing is not just a penalty. In a sector where the license to compete depends on financial controls and where reputation is a financial asset, an AML breach has effects that go well beyond the administrative proceedings.
Financial penalties: the AML penalty regime is severe and is calibrated to the seriousness and repetition of the breach. For a club with a tight budget and external financial control, a significant penalty jeopardizes sporting planning for the season.
Transactions blocked at the worst moment: a signing that cannot close because the source of the counterparty’s funds cannot be proven falls through in the last week of the transfer window. Due diligence is not a formality after the negotiation: it determines who you can negotiate with.
Directors’ liability: the AML system is the responsibility of the management body. The lack of an effective system is not solved by pointing at an employee, and the people who sign the transactions are exposed.
Any incident at a professional club is national news. The reputational damage affects sponsors, season-ticket holders and the club’s own ability to attract investment, and it is far greater than for an equivalent breach in another sector.
Clubs with robust systems will start requiring of their counterparties what is required of them. A club without a system will gradually be left out of deals with the big clubs.
Regulatory compliance intersects with the sector’s own financial control and licensing systems. A regulatory problem rarely stays within a single proceeding.
We analyze your club’s position under the new framework, tell you whether you are in scope or covered by the exemption, and deliver the adaptation plan with its timeline and cost.
REGULATORY CONTROL CENTER · PROFESSIONAL FOOTBALL
A top-tier club with a corporate structure, a newly promoted club and a foreign-owned club face the same framework with different problems. This panel shows where to concentrate the work in each case.
Indicative benchmark for prioritizing the work and sizing the project team.
None of them is a legal mistake. They are all planning mistakes, and in this sector you also pay for them with the transfer-window calendar.
Building a robust risk self-assessment, a club-specific manual, a counterparty acceptance procedure and a track record of files takes more than one season. Clubs that start in 2028 will face their first inspection with a brand-new system.
A financial institution’s manual adapted with find-and-replace does not describe how a club operates. There are no customers: there are counterparties, agents, sponsors and investors, and the risk vectors are different.
The people who spot an alert are the ones who negotiate the signing, sign the sponsorship and deal with the intermediary. If sporting management is not trained and has no clear procedure, the system does not work, however well drafted it is.
The sector’s own financial control systems look at the club’s financial sustainability. AML looks at the origin of the money and the identity of the counterparty. They are different controls, with different documentation.
Before the obligation kicks in, you should know who the club works with: which agents, clubs, sponsors and companies. That map is half the work, and doing it in good time avoids discovering a problem in the middle of the transfer window.
The public consultation on the Spanish draft bill is still open, and it is where Spain defines how it exercises the exemption option. For clubs close to the threshold, that decision changes everything.
Three principles that separate a system that works from a folder of documents nobody uses.
A useful AML system starts from how the club really works: who negotiates, who signs, how transactions are approved and where the documentation is kept. A manual that describes a different organization protects no one.
Checking the counterparty once the transaction is closed is no use. The procedure has to kick in at the start, while there is still room to walk away.
Every decision to accept a counterparty or to go ahead with a transaction leaves a retrievable file: what was checked, with which documents and who decided. It is the only thing that exists when someone asks three years later.
If you would like a preliminary assessment of your club’s position, see our AML services or request a free consultation.
Terms that will come up in every adaptation meeting. Sporting management, the legal team and the board should use them with the same meaning from the start.
A natural or legal person on which the law imposes due diligence, record keeping, reporting and internal control. From 2029, this includes professional football clubs.
A club has no customers in the classic sense: it has selling and buying clubs, agents, sponsors, investors and suppliers. Due diligence applies to them.
The set of checks on identity, beneficial ownership, business activity and source of funds that must be carried out before establishing the relationship and maintained for as long as it lasts.
Whoever actually owns or controls a company, directly or through a chain of holdings. They are identified both in the club itself and in each counterparty.
The document that identifies and assesses the risks specific to the club’s activity, and on which the intensity of all controls is calibrated.
The body that approves procedures, analyzes alerts and decides on reports. At a club it can be small, but it must exist and work.
The person formally appointed as the point of contact with the supervisor, responsible for reporting suspicious transactions.
The turnover figure that the recitals of the Regulation use to allow top-division clubs to be exempted, applied to each of the two previous years.
The body envisaged in the Spanish draft bill that will bring together AML supervision, inspection and sanctioning.
From July 10, 2029. Regulation (EU) 2024/1624 generally applies from July 10, 2027, but for professional football clubs and football agents it provides an additional two-year period.
That extra time is not free time: it is the time allowed to build an AML system from scratch, something no club has today.
The Regulation refers to professional football and allows Member States to exempt certain clubs where they demonstrate a lower risk. For top-division clubs, the exemption is envisaged where turnover in each of the two previous years was below €5 million; in lower divisions, the exemption depends on demonstrating low risk.
How Spain exercises that option is precisely what is being decided now, as the draft bill goes through the legislative process.
The same six as any obliged entity, applied to its situation: due diligence on counterparties, identification of beneficial ownership, verification of the source of funds, record keeping, suspicious transaction reporting, and internal control with training.
In practice, that means a club-specific manual, a risk self-assessment, a control body, a representative before the authority and a file for each significant transaction.
No. The focus is on the counterparties the club does business with—clubs, agents, sponsors, investors—and on significant transactions, not on the ordinary relationship with season-ticket holders.
There are implications for ticket sales when tickets are paid for in cash above certain limits, but this is a minor piece compared with signings, commissions and shareholders.
A signing involving an intermediary. It combines several risk factors at once: high amounts with no clear market benchmark, international payments, commissions to third parties and the frequent presence of interposed companies in several jurisdictions.
We cover it in detail on our page on due diligence in signings and transfers.
In Spain, the authority envisaged is the ANIFI, the body created by the draft bill approved in July 2026, which absorbs SEPBLAC and also brings together supervision, inspection and sanctioning powers.
It is a supervisor with more resources than the current one and with powers of direct intervention. We explain it on our page on the ANIFI.
They are obliged entities in their own right, not as an appendage of the club. This means that a single transaction may involve two obliged entities carrying out due diligence on each other, each with its own documentation and reporting obligations.
We cover this on our page on football agents and AML.
It helps, but it is no substitute. The sector’s financial control systems look at the club’s financial sustainability: whether it can pay for what it spends. AML looks at something else: where the money comes from and who is really behind the counterparty.
Much of the information can be reused, but the analysis, documentation and record keeping are different.
It depends on the club’s size and starting point. A club with an in-house legal team and a simple shareholder structure mainly needs procedures and training. A club with foreign ownership, a complex corporate structure and an international volume of transfers has a considerably larger project ahead.
The most underestimated cost is not the consultancy: it is the internal time of sporting management and the commercial team.
Three things that do not depend on the final text. First, determine whether the club is in scope or covered by the exemption. Second, map regular counterparties: agents, clubs, sponsors and investors. Third, follow the draft bill’s progress, because it decides the threshold that separates obliged clubs from exempted ones.
All that work can be fully reused later, whatever the final terms of the law.
Everything stated on this page comes from the EU legislative package or from official Spanish documents still in the legislative process. These are the primary links to check it.
Entry for the EU anti-money laundering regulation in the Spanish Official State Gazette (BOE), with access to the PDF of the original publication. It is the regulation that brings football into the scope of obliged entities.
boe.es · DOUE-L-2024-80912 BOEMechanisms that Member States must put in place: supervision, registers and cooperation. This is the piece Spain has to transpose.
boe.es · DOUE-L-2024-80913 BOEEstablishes the EU Anti-Money Laundering Authority, with which the Spanish supervisor will coordinate.
boe.es · DOUE-L-2024-80910 Ministry of EconomyOfficial page of the public hearing and information procedure for the Spanish reform that creates the ANIFI and brings in the new obliged entities. Submissions until September 30, 2026.
portal.mineco.gob.es · public consultation La MoncloaOfficial summary of the agreement approving, at first reading, the draft bill for the comprehensive reform of the AML framework.
lamoncloa.gob.es · Council of Ministers BOEConsolidated text of the Spanish law still in force, which the reform now in progress is set to replace.
boe.es · BOE-A-2010-6737Regulatory content ages quickly, and an outdated guide wastes the time of anyone who follows it. That is why we publish who maintains it and how.
Tell us which division your club plays in, its business volume and how its shareholding is structured, and we will tell you whether you are in scope and what you would need to set up.
Professional football’s place on the list of obliged entities was not improvised. International bodies have been pointing at the sector for more than a decade: very high-value transactions with no objective market benchmark, intermediaries collecting commissions that are hard to justify, club ownership through opaque corporate chains and a constant international flow of money between jurisdictions. Regulation (EU) 2024/1624 turned that diagnosis into an obligation.
The Regulation brings professional football clubs and football agents into the scope of obliged entities, with their own timeline: while the other sectors apply the framework from July 10, 2027, football has until July 10, 2029. In exchange for that extra time, the Regulation allows Member States to exempt certain clubs where they demonstrate a lower risk, and uses a threshold of €5 million in turnover in each of the two previous years for top-division clubs.
It is not at the box office. It is in signings involving intermediaries, where high amounts, international payments, commissions to third parties and interposed companies come together. It is in the arrival of new shareholders, where the ownership chain can run through several jurisdictions before reaching a natural person. And it is in sponsorship agreements with counterparties whose real business is not always obvious. A club that wants to get ahead would do well to start there, not with the most visible part.
The same as any obliged entity, but from scratch: a risk self-assessment that identifies the risk vectors specific to its activity, a manual that describes how the club actually operates, a counterparty acceptance policy, an internal control body, a representative before the authority, a reporting procedure and a training plan backed by evidence. The most underestimated element is none of those documents: it is the record keeping. Being able to reconstruct, three years later, what was checked before a transfer was signed is what separates a real system from a folder.
2029 seems far away. It is not. Building a robust self-assessment means mapping counterparties that nobody has inventoried today; drafting a club-specific manual means understanding how transactions are really approved within the club; and training sporting management takes several seasons before the procedure sinks in. Clubs that start in 2028 will face their first inspection with a brand-new system and no track record to show. Meanwhile, the public consultation on the Spanish draft bill is still open, and it will decide something that changes everything for many clubs: exactly where the exemption line falls.
Key legislation, linked to the official text:
Legislation and links reviewed in .