Checking at signing rather than during negotiation
Due diligence done at the closing stage does not let you decide: it only lets you discover. The procedure has to kick in when interest first arises, with room to walk away.
AML due diligence in football transfers
A player transfer is the transaction that concentrates the most risk for a club: large amounts with no clear market benchmark, international payments, commissions to intermediaries and interposed companies in several jurisdictions. This page explains what must be checked, when, with which documents and what is kept on file once the club is an obliged entity.
A review of your procedure
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Starting point
Due diligence comes before, not after
The underlying mistake in almost every procedure we review is one of timing: the counterparty is checked once the deal is already closed, at the signing stage. By then the check no longer helps you decide; it only uncovers a problem when there is no way out.
Definition · Due diligence in a transfer
It is the set of checks a club must carry out on every party involved in the transaction—the other club, agents, payee companies and beneficial owners—before making a commitment and for as long as the relationship lasts.
It is not a document review at closing: it is a procedure that starts with the initial interest and can lead you to walk away.
Definition · What is kept on file
The transaction file brings together the identification of each party, the verification of its beneficial ownership, the analysis of the source of funds, the economic rationale for the transaction and the decision taken, who took it and when.
It must be possible to reconstruct it years later. If it is not on file, it did not happen.
Detection
Red flags in a transfer
They are not evidence of a crime or reasons not to do the deal: they are circumstances that call for a closer look and better documentation before going ahead. A useful procedure has them written down, staff trained on them and someone responsible for deciding.
| Red flag | Where it appears | What it requires |
|---|---|---|
| Price with no reasonable benchmark | The transfer fee clearly departs from the player’s market valuation, whether upward or downward. | A written economic rationale and approval at a level above the person negotiating. |
| Disproportionate commission | The intermediary’s fee bears no relation to the value or the complexity of the transaction. | Proof that the service was actually provided and that the work matches the amount. |
| The payee is not the negotiator | The payment is directed to a company other than the agent who was involved. | Due diligence on the payee company, its beneficial ownership and its connection to the service. |
| Unconnected jurisdiction | An account or company is located in a country with no link to the parties or to the player. | Enhanced measures, a written explanation of why that jurisdiction is used and an assessment of whether to refrain from the transaction. |
| Newly incorporated company | The vehicle involved was set up shortly before and has no business activity. | Document why it is involved and verify who controls it. |
| Split or triangulated payments | The amount comes from several accounts or passes through financial intermediaries. | Reconstruct the full payment route, leg by leg. |
| Late change of payee | The recipient is changed after the transaction has been signed. | Reopen due diligence on the new recipient before making the payment. |
| Rush before the window closes | Pressure to sign without completing the checks. | Stick to the procedure: the sporting calendar is not provided for as an exception. |
| Related clubs | The transaction takes place between clubs under common or coordinated ownership. | A price rationale for a related-party transaction and a map of the ownership structure. |
List drawn up from the risk-based approach of Regulation (EU) 2024/1624 and supervisory practice in comparable sectors. Each club must set out its own list in its risk self-assessment.
How we work
Six workstreams around a player transfer
The aim is not to hold up the transfer market: it is for the club to operate safely and close quickly when the time comes. A well-designed procedure speeds up clean deals and only stops the ones that need stopping.
Procedure
Due diligence protocol for transfers
Design of the full procedure: what is checked at each stage of the transaction, what documents are requested from the counterparty, who signs off and when you can go ahead. Built for the real transfer calendar, not an ideal one.
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ProtocolStagesSign-offDeadlines
Counterparties
Verification of clubs and companies
Identification of each entity involved, tracing of the corporate chain to the natural person, and a check that the paying account belongs to the party liable for the payment.
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KYBCorporate chainPaying accountRegisters
Funds
Source of funds for the transaction
Analysis and documentation of the origin of the money used to pay the transfer fee, especially when the financing comes from shareholders or from third parties outside the club.
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OriginTraceability
Intermediaries
Control of agents and commissions
Review of who is involved, under what mandate and how the service provided matches the amount collected. This is where most alerts arise.
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AgentsCommissions
Intensity
Enhanced measures
Definition of the situations that trigger enhanced due diligence and of the specific scope of the additional checks in each case.
Learn more →
EnhancedTriggers
Decision
Refraining and reporting
What to do when an alert arises with the deal already under way: who analyzes, who decides, how quickly and how the decision to go ahead or stop is documented.
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RefrainingReporting
Calibration
Not every transaction requires the same
Applying the highest level of checks to every transaction is as dysfunctional as applying none: it uses up resources where they are not needed and ends up hollowing out the procedure. The system must scale the intensity to the risk, and that scaling must be written down in advance.
| Level | When it applies | What it adds |
|---|---|---|
| Simplified | A transaction with a known domestic club, with no intermediaries and direct payment between the clubs. | Identification of the entity, beneficial owner from registers and verification of the payment account. |
| Standard | An ordinary international transaction, with intermediaries and a standard structure. | Full tracing of the corporate chain, a price rationale and a review of every intermediary who gets paid. |
| Enhanced | Complex corporate structures, high-risk jurisdictions, politically exposed persons or very large amounts. | Documentation of the source of funds, senior-level approval and enhanced monitoring of subsequent payments. |
Indicative outline. The situations that require enhanced measures are specifically listed in the legislation and must be built into the club’s procedure as they stand.
Record keeping
What a transfer file must contain
This is the piece that decides whether the system exists. When the authority asks, three years later, why a transaction went ahead, the answer will have to be in a folder that someone can find within hours.
| Area | Documents |
|---|---|
| Parties | Identification of each club, agent and company involved, with supporting documents for its incorporation and representation. |
| Beneficial ownership | Tracing of each company’s ownership chain to the natural person, with the source from which it was obtained. |
| Deal structure | Transfer agreement, representation agreements, commission agreements and any side agreement. |
| Payment flows | Details of each scheduled payment: amount, payee, account, date and purpose, including deferred payments and add-ons. |
| Source of funds | Where applicable, documentation on the origin of the money used to finance the transaction. |
| Economic rationale | The reasoning behind the price and the commissions, with the comparables used. |
| Analysis and decision | Alerts detected, how they were resolved, who authorized going ahead and on what date. |
| Monitoring | Checks carried out at each later due date and any change of payee or account. |
Indicative content based on the due diligence and record-keeping obligations of Regulation (EU) 2024/1624. It is best set as a single template for all of the club’s transactions.
Risks
What is at stake in a poorly documented transaction
The cost of an incomplete file is not paid on signing day. It is paid years later, when someone asks and the only available answer is that it seemed normal at the time.
Being unable to explain the transaction: without a file, the club cannot prove what it checked or why it decided to go ahead. A lack of analysis is not read as a lack of problems: it is read as a lack of control.
Deal blocked at closing: finding out on the last day that the payee company cannot prove its beneficial ownership leaves the club with a signed deal it cannot pay, or a paid deal it cannot justify.
Contagion across the whole portfolio of transactions: a weak procedure does not fail on one transfer: it fails on every transfer that season. A supervisor that spots a pattern reviews the whole series, not the isolated case.
Add-onsFuture payments
Deferred amounts and add-ons are paid years later, often to accounts other than those agreed. Without a monitoring procedure, those payments go out with no checks at all.
Related clubsPrice of convenience
Transfers between clubs under common ownership attract specific attention. Without a documented price rationale, the transaction is exposed from day one.
ReputationPublic impact
In this sector, transactions are public and comparable. A weak file on a well-known transaction carries a reputational cost out of all proportion to the penalty.
Could you explain today a deal closed three seasons ago?
We review your transfer procedure, design a due diligence protocol adapted to the real transfer calendar and leave you with the file template ready for the next window.
REGULATORY CONTROL CENTER · TRANSFER TRANSACTIONS
Control panel: intensity by transaction type
The same club applies different levels depending on the transaction. This panel summarizes where it pays to step up checks and where extra checking only adds friction without reducing risk.
Required intensity by transaction type
Indicative benchmark for prioritizing the work and sizing the project team.
Area
Direct domestic transfer
International transfer with an agent
Transaction with a corporate structure
Identification of parties
LowKnown entities
MediumForeign register
HighFull chain
Source of funds
LowClub-to-club payment
MediumDepends on amount
HighDocuments required
Commission controls
MediumSimple intermediation
HighSeveral payees
HighPayee vehicles
Subsequent monitoring
LowSingle payment
HighAdd-ons and deferred
HighPayee changes
Diagnosis
Six mistakes in the transfer procedure
They all surface in the last week of the window, and they can all be avoided with a decision taken months earlier.
Looking only at the other club
The selling club is usually the easiest party to verify. The risk lies with the agents, the payee companies and the third parties that show up in the commission split.
Closing the file at signing
In football a significant part of the fee is paid in deferred installments and add-ons. Each due date is a payment that must be checked, and a change of account reopens due diligence.
Leaving the level of checks to the negotiator’s judgment
Whoever is closing the deal has an obvious incentive to consider it low risk. The criterion must be set in advance in the self-assessment, not decided on the fly.
Keeping contracts instead of files
Filing the transfer agreement is necessary but not sufficient. What is asked for is the analysis: what was checked, what alerts arose, how they were resolved and who authorized going ahead.
Treating the window deadline as an exception
The urgency of the sporting calendar is not provided for as an exception in the law. A procedure that is suspended in August and January is a procedure that does not exist.
Practical guide
How to design a procedure that does not hold up transfers
Three principles so that due diligence speeds up clean deals instead of slowing them all down equally.
Start with your regular counterparties
Most of a club’s transactions are done with a relatively stable set of clubs and agents. Having their files completed and updated in the off-season turns the August check into a review that takes minutes.
Save the effort for where it matters
Written criteria for each level let you clear ordinary deals quickly and focus the work on the ones that really need it. Without proportionality, the procedure is applied badly to all of them.
Someone has to be able to say no
A procedure with no one empowered to stop a transaction is just paperwork. Defining who decides, with what information and how quickly is the most neglected part and the one that protects you most.
Checklist: 12 points for the transfer procedure
- Define the exact point in the transaction at which the file is opened, and make sure it is before formal negotiations.
- Keep the files on the clubs and agents you regularly deal with complete and up to date.
- Set down in writing the criteria that place a transaction at the simplified, standard or enhanced level.
- Require identification and beneficial ownership for every company that is going to be paid, not just the other club.
- Check that the paying account belongs to the party liable for the payment.
- Document the economic rationale for the price and for each commission, with the benchmarks you used.
- Record the alerts detected and how they were resolved, even if the conclusion was to go ahead.
- Establish who authorizes going ahead at each level and keep a record of that authorization.
- Define the procedure for refraining from a transaction: who decides to stop it and how the counterparty is told.
- Schedule a check of each deferred payment and each add-on when it falls due.
- Reopen due diligence whenever there is any change of payee, account or structure.
- Test retrievability: pick three old transactions at random and time how long it takes you to reconstruct them.
If you want to review your club’s transfer procedure, see our page on AML for football clubs or request a free consultation.
Working glossary
Vocabulary for the transfer file
Terms that sporting management, the legal team and administration should use with the same meaning before the window opens.
Due diligenceDuty
Knowing the counterparty
Checks on the identity, beneficial ownership, business activity and source of funds of each party involved in the transaction.
It starts at the outset, not at signing.
Beneficial ownerOwnership
Natural person in control
Whoever ultimately controls each company involved, directly or through ownership chains.
It must always lead to a natural person.
Interposed companyStructure
Vehicle that sits between the parties
A company that appears as the payee or as a party without being the club or the agent who negotiated. Legitimate, but it requires an explanation.
Its involvement must be justified.
Actual serviceProof
Service actually provided
Documents proving what work justifies a commission. This is the core of the controls on intermediaries.
The contract alone does not prove it.
Enhanced measuresIntensity
Additional checks
A higher level of due diligence that applies in higher-risk situations specified by law or identified by the club.
They are not optional when the situation arises.
Duty to refrainDecision
Not proceeding when there is a suspicion
The obligation not to carry out the transaction where there is a suspicion, except in specified cases. It must be set out in a procedure before it happens.
It clashes with the window deadline: plan for it.
Add-onsPayments
Conditional amounts
Amounts whose payment depends on future sporting milestones. They are paid years later and often with no checks at all.
Each due date is a payment to be checked.
Related partiesGroup
Clubs under common ownership
Transactions between entities under common or coordinated control, which require a specific price rationale.
They attract supervisory attention of their own.
Transaction fileRecords
Complete documentation of the transaction
A retrievable set of identification, verification, analysis and decision. It is the only thing that exists when someone asks years later.
The analysis is filed, not just the contract.
Frequently asked questions
Football transfers and money laundering: frequently asked questions
What exactly must be checked in a transfer?
Four things, on every party involved and not just the other club: who they are (identification), who is behind them (beneficial ownership down to a natural person), where the money comes from (source of funds, where applicable) and why the transaction makes economic sense (rationale for the price and the commissions).
All of this is documented in a single file, together with any alerts that arose and the decision to go ahead.
When must it be done?
At the start, when interest first arises and there is still room to walk away. Due diligence done at the signing stage does not let you decide: it only lets you discover a problem when the deal is already committed.
And it does not end at signing: deferred payments and add-ons are checked when they fall due, which may be years later.
Which part of the transaction carries the most risk?
Intermediary commissions. The fee between the clubs is public, comparable and declared; the commission is set bilaterally, is often paid to companies other than the agent who negotiated, and its link to the work done is not always clear.
This is where most alerts arise. We also cover it from the intermediary’s side on our page on football agents and money laundering.
Should the same level apply to every transaction?
No, and doing so would be counterproductive. The system must scale the intensity to the risk: a direct domestic transfer between known clubs does not require the same as a transaction with a corporate structure spanning several jurisdictions.
What matters is that the criterion is set in advance in the club’s risk self-assessment and not decided on the fly by whoever is negotiating.
What if the alert arises just as the window is about to close?
The law provides for a duty to refrain: where there is a suspicion, the transaction is not carried out, except in specified cases. The urgency of the sporting calendar is not recognized as an exception.
That is why you should decide in advance who analyzes, who has the authority to stop a transaction and how quickly they must decide. Improvising that on August 31 does not work.
What about deferred payments and add-ons?
They are the blind spot of almost every procedure. A significant part of a transfer fee is paid in the future and depends on sporting milestones, often to accounts that may have changed.
Each due date is a payment that must be checked, and any change of payee or account reopens due diligence on the new recipient.
What about transfers between clubs in the same group?
They attract specific attention, because the price is not set in a market between independent parties. The transaction is perfectly lawful, but you need to document why the amount is what it is.
It also helps to have the group’s ownership structure mapped. We cover this on our page on beneficial ownership of a football club.
Won’t this slow down the club’s transfer business?
A badly designed procedure will. A well-designed one does the opposite: it speeds up ordinary deals, because the files on regular counterparties are already done, and it focuses the effort on the few transactions that really need it.
The work is done in the off-season, not in the last week of August.
From when is this mandatory?
Professional football clubs are obliged entities from July 10, 2029, under Regulation (EU) 2024/1624, which applies to all other sectors from July 10, 2027.
We explain the exact scope, the threshold and the exemption option on our page on anti-money laundering for football clubs.
Can we use the documents we already request for financial control?
Partly, but the analysis is different. The sector’s financial control looks at the club’s financial sustainability: whether it can pay for what it spends. Due diligence looks at the origin of the money and the real identity of the counterparty.
Much of the information can be reused, but it needs to be completed and, above all, filed differently.
Sources
Official sources
Everything stated on this page comes from the EU legislative package or from official Spanish documents still in the legislative process.
BOE
Regulation (EU) 2024/1624 (AMLR)
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 BOEDirective (EU) 2024/1640 (AMLD6)
Mechanisms 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 BOERegulation (EU) 2024/1620 (AMLA)
Establishes the EU Anti-Money Laundering Authority, with which the Spanish supervisor will coordinate.
boe.es · DOUE-L-2024-80910 Ministry of EconomyDraft bill on comprehensive AML/CFT measures
Official 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 MoncloaCouncil of Ministers meeting of July 28, 2026
Official 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 BOELaw 10/2010 on the prevention of money laundering
Consolidated text of the Spanish law still in force, which the reform now in progress is set to replace.
boe.es · BOE-A-2010-6737
Transparency
How this page is prepared and updated
Regulatory 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.
Update history
- Initial publication. Content checked against the BOE entry for Regulation (EU) 2024/1624, the Ministry of Economy’s public consultation page and the official summary of the Council of Ministers meeting of July 28, 2026.
- Planned for when the public consultation closes and when specific supervisory guidance for the sector is published.
Contact
Book a call
Tell us how you currently handle a transfer and what documents you request from the counterparty, and we will tell you what is missing and how to fit it in without holding up your transfers.
Due diligence in football transfers: where the risk lies and what to keep on file
Of all the transactions a football club carries out, a transfer involving an intermediary combines the most risk factors at once: very large amounts with no objective market benchmark, international payments, commissions whose rationale is not always clear and the frequent presence of interposed companies in jurisdictions with no apparent connection to the parties. Once the club is an obliged entity, that transaction requires a file.
The timing mistake
The most common failure is not one of legal judgment but of timing. The procedures we review place the check at the signing stage, when the deal is already closed. By then due diligence has lost its purpose: it no longer helps decide whether to do the deal, only to discover a problem with no room to avoid it. A useful procedure starts with the initial interest, when it is still possible to walk away.
What almost nobody checks
The other club is usually the easiest party to verify: it is a known, registered entity with public accounts. The risk is concentrated in the secondary flows—who receives the commission, which account the payment comes from, which company appears in the split—and, above all, in time. In football a significant part of the fee is paid in deferred installments and add-ons, sometimes three or four years later, and those payments often go out without any checks because the file was closed on signing day.
Scale rather than standardize
Applying the highest level of checks to every transaction is as dysfunctional as applying none: it uses up resources where they are not needed, creates friction with clean counterparties and ends up emptying the procedure of substance. What the law requires is risk-based scaling, and what practice demands is that this criterion be set down in writing in advance, in the club’s risk self-assessment, and not decided on the fly by whoever is negotiating the deal.
The file is the system
When the authority asks, years later, why the club went ahead with a particular transaction, the answer will have to fit in a folder that someone can find within hours. The transfer agreement is not enough: you need the identification of each party, the tracing of the corporate chains, the analysis of the source of funds, the economic rationale for the price and the commissions, the alerts that arose, how they were resolved and who authorized going ahead. That set is what separates a real AML system from a well-organized folder of contracts.
Football and money laundering
Due diligence
Official sources
Key legislation, linked to the official text:
- Regulation (EU) 2024/1624 of May 31, 2024 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financingEUR-Lex · Official Journal of the EU
- Directive (EU) 2024/1640 of May 31, 2024 on the mechanisms to be put in place by Member States for the prevention of money launderingEUR-Lex · Official Journal of the EU
- Regulation (EU) 2024/1620 of May 31, 2024 establishing the Authority for Anti-Money Laundering and Countering the Financing of TerrorismEUR-Lex · Official Journal of the EU
Legislation and links reviewed in .