Football agents do not come into scope as an appendage of the clubs: they come in in their own right. This means that a single transaction may involve three obliged entities—buying club, selling club and agent—carrying out due diligence on one another. This page explains what the agent takes on, how it differs from what the sports rules already require, and what a football agency needs to set up.
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This is the difference the sector finds hardest to take on board. An agent does not comply because their club asks them to, and they are not covered by the AML system of the club they are negotiating with: they have their own obligations, their own manual, their own records and their own liability if something goes wrong.
Football agents are among the obliged entities added by Regulation (EU) 2024/1624, from the same date as clubs: July 10, 2029.
They take on the full set of obligations: due diligence on their counterparties, beneficial ownership, source of funds, record keeping, reporting of suspicious activity and internal control.
Having a license, a written contract and your transactions declared to the federation does not amount to compliance with the AML regime. They are different controls with different purposes.
The sports regime oversees the profession and conflicts of interest; the AML regime looks at where the money comes from and the real identity of whoever stands behind each counterparty.
An agent operating today is already regulated: they need a license, a written contract with the person they represent and a declaration of their transactions to the relevant federation. From 2029 a different layer is added on top, with a different logic and a different supervisor.
| Aspect | Sports regime | AML regime |
|---|---|---|
| Purpose | To regulate the profession and prevent conflicts of interest in the transaction. | To prevent the transaction from being used to bring in funds of illicit origin. |
| Who it asks about | The agent and their relationship with the person they represent. | All counterparties: clubs, companies, intermediate payees and beneficial owners. |
| Documentation | License, representation agreement and declaration of the transaction. | Due diligence file for each counterparty, with verification of identity, beneficial ownership and source of funds. |
| Who you answer to | The federation and football’s disciplinary bodies. | The administrative AML authority, with its own penalty regime. |
| What happens if you do not comply | Sporting sanctions and, where applicable, loss of the license. | Administrative sanction proceedings, with fines that do not depend on the size of the transaction. |
| Record keeping | Periods and formats set by the sports rules. | Records that can be retrieved throughout the legal retention period, including the analysis and not just the contract. |
Functional comparison of the two frameworks. The specific sports rules that apply to an agent depend on the federation rules in force at any given time and on how they fit within each jurisdiction, an issue that has been the subject of litigation.
A football agency does not need a club’s compliance machinery, but it does need every piece. Proportionality allows a light structure; it does not allow any piece to be missing.
Analysis of your own risk: which markets you operate in, with which clubs, with what volume of commissions and through which corporate structures you get paid. That analysis sets the intensity of the controls and the rest of the system.
A manual adapted to how an agency really operates: what is checked before accepting a mandate, what is checked before closing a deal and what documentation is kept on file for each engagement.
Verification of the identity and beneficial ownership of every club, intermediate company or payment vehicle that appears in the transaction, including corporate chains.
Traceability of the money coming into the agency: who pays, from which account, for what and how it matches the service actually provided.
Internal procedure to detect, analyze and, where appropriate, report a suspicious transaction. It covers the duty to refrain and what to do when suspicion arises with the transaction already under way.
In small agencies the function can be outsourced or concentrated, but it has to exist, be formally designated and work. We design the minimum viable structure and document it.
The list is the same as for any obliged entity. What changes is how it translates into the day-to-day work of an agency that may have two people and bill several million in a single season.
| Obligation | What it means in practice for the agent |
|---|---|
| Due diligence | Verify the identity and beneficial ownership of every club and every company involved in the transaction, before closing it and not afterwards. |
| Source of funds | Be able to explain where the money used to pay the commission comes from, and verify that the paying account matches the party required to pay. |
| Actual provision of the service | Document the service actually provided: mandate, steps taken, correspondence, and how the amount charged relates to the work done. |
| Record keeping | Keep the complete file for each transaction—not just the contract—in a retrievable form throughout the legal retention period. |
| Refraining and reporting | Do not execute the transaction when there is a suspicion, except in the cases strictly set out in law, and report it to the authority in line with the internal procedure. |
| Internal control | Manual, designated officer, documented training and periodic review, with an intensity that matches the size of the agency. |
| Sub-agents and correspondents | Extend the controls to anyone acting on the agency’s behalf in other markets: responsibility is not handed over along with the assignment. |
Application to agents of the general framework of Regulation (EU) 2024/1624. Thresholds and the details of each obligation should be checked against the articles and against the Spanish implementing law.
They are not evidence of a crime: they are circumstances that require a closer look before going ahead. A useful system has them written down, covered in training and assigned to a person who decides.
| Red flag | Why it matters | What to do |
|---|---|---|
| The payee is not the one who negotiated | The commission is paid to a company other than the agent who took part in the transaction. | Verify the beneficial ownership of the receiving company and that it has a demonstrable relationship with the service provided. |
| Disproportionate amount | The commission bears no relation to the value of the transaction or to market practice. | Document the economic rationale and escalate the decision to whoever holds the compliance function. |
| Split or triangulated payment | The amount is paid from several accounts or passes through jurisdictions with no connection to the parties. | Reconstruct the full payment route and require a written explanation for each leg. |
| Newly created intermediate company | The payment vehicle was set up shortly before the transaction and has no activity. | Enhanced due diligence on the company and on whoever controls it, documenting why it is involved. |
| Unjustified urgency | Pressure to close without completing the checks, citing the closing of the transfer window. | Stick to the procedure: the urgency of the football calendar is not an exception provided for in the law. |
| High-risk jurisdiction | One of the parties or accounts is located in a country with recognized deficiencies. | Apply enhanced measures and consider refraining if sufficient information cannot be obtained. |
| Last-minute change of beneficiary | The payment recipient is changed when the transaction has already been closed. | Reopen due diligence on the new recipient before making the payment. |
We review how you operate, design a system proportionate to your size and hand over the manual, the acceptance policy and the transaction file template, ready to use in the next transfer window.
For an agency, the risk is not just the penalty: it is being shut out of the market. Clubs that have a system in place will start requiring of their intermediaries the same as is required of them.
Shut out of the market: a club with an AML system in place will not be able to close deals with an agent who cannot show that they have their own structure. Due diligence works both ways, and an agent without a file becomes an unacceptable counterparty.
Deals collapsing on the last day: if checking the receiving company is left until the end, the deal gets blocked just when there is no room left. Due diligence determines who you can work with, not just how things are documented afterwards.
Personal liability: in small agencies, the person running the business is also the one answerable for the system. There is no structure over which to spread the responsibility and no department to blame for the failure.
Working in other markets through correspondents does not transfer responsibility: if the sub-agent does not apply controls, the problem comes back to the agency that engaged them.
When suspicion arises, the law requires you not to execute. It is the obligation that fits worst with the transfer calendar, and the one you most need a written procedure for before it happens.
The same conduct can have consequences in both the sporting and the administrative spheres. They are independent proceedings and do not offset each other.
REGULATORY CONTROL CENTER · FOOTBALL AGENCIES
An individual agent, an agency with a structure and an international network with correspondents face the same rules with very different problems. This panel shows where to start in each case.
An indicative guide to prioritize the work and size the project team.
None of them is a legal mistake. They are all organizational, and they all surface in the last week of the transfer window.
A license, a written contract and a federation declaration show that you can take part in the transaction. They say nothing about where the money comes from or who is behind the company receiving payment. They are different systems.
The club will carry out its own due diligence, and one of the counterparties it checks will be you. The club’s review does not exempt the agent from carrying out their own checks or from keeping their own file.
The representation agreement shows that a mandate exists. It does not show what work was done or why the commission is the amount it is. That match is what is asked for when someone starts asking questions.
Invoicing through a corporate vehicle is legitimate, but you must be able to show its beneficial ownership, its activity and its relationship with the service. Without that, the payment structure becomes the problem.
Due diligence carried out once the deal has been signed is no use for making a decision: it only serves to uncover a problem when it can no longer be avoided.
Operating in other markets through third parties is common and perfectly valid, but responsibility stays with whoever engages them. A correspondent without controls is a risk of your own.
Three principles for building something proportionate that really works and does not paralyze day-to-day business.
A small agency can have a simple system, but it cannot do without any of the pieces: risk analysis, manual, acceptance policy, records, designated officer and training. What is scaled is the depth, not whether each piece exists.
Checking counterparties at the start of the negotiation leaves room to walk away. Checking them at the end turns any finding into a collapsed deal.
The core of an agent’s due diligence is being able to explain why that amount, paid by that party, into that account, corresponds to that work. Everything else revolves around that explanation.
If you want to set up your agency’s system, see our AML services or request a free consultation.
Terms that will come up in every transaction from 2029, and that the agency should start using now.
Intermediary that represents players or clubs in transfers and employment deals. Brought into the scope of obliged entities by Regulation (EU) 2024/1624.
Clubs, payment companies, other agents and any party with which the agency enters into a business relationship. Due diligence applies to all of them.
Documentation showing what work was done and why it justifies the amount charged. It is the core of an agent’s file.
Obligation not to carry out the transaction when there is a suspicion, except in the cases strictly set out in law where refraining is impossible or could hinder the investigation.
Whoever ultimately controls the company involved in the transaction, directly or through a chain of holdings.
Intermediary who acts in another market on the agency’s instructions. Their involvement does not shift responsibility away from the lead agency.
Stricter measures that apply where higher-risk circumstances are present: jurisdiction, structure, amount or counterparty profile.
Retrievable record of the identification, verification, analysis and decision for each transaction. It is the only thing that exists when the authority asks questions years later.
The National Financial Integrity Authority (Autoridad Nacional de Integridad Financiera) envisaged in the Spanish draft bill, which will bring together AML supervision, inspection and sanctioning.
Yes. Regulation (EU) 2024/1624 brings football agents into the scope of obliged entities, from the same date as clubs: July 10, 2029.
It is important to stress that they are obliged entities in their own right. This does not depend on whether the club they negotiate with has a system, and they are not covered by the club’s system.
No. The sports regime and the AML regime answer different questions. The license and the contract show that you can take part in the transaction and on what terms; the AML regime asks where the money comes from and who is really behind each counterparty.
A file can be flawless in the eyes of the federation and clearly insufficient in the eyes of the AML authority.
Commissions. The transfer fee between clubs is the most visible flow and almost never the most problematic. Risk is concentrated in who receives the commission, whether the amount is proportionate to the transaction and whether there is an identifiable service behind the payment.
A last-minute change in the payment recipient, or payment through a company other than the agent who negotiated, are the circumstances that call for the most attention.
Yes, as long as you can explain it. Invoicing through a corporate vehicle is perfectly legitimate; what the framework requires is that you can show its beneficial ownership, its activity and its relationship with the service provided.
What does not work is a recently incorporated company with no activity and no obvious connection to the transaction.
The law provides for a duty to refrain: when there is a suspicion, the transaction is not executed, except in the cases strictly set out in law where refraining is impossible or could obstruct the investigation.
It is the obligation that fits worst with the football calendar, and that is precisely why you should have it written down in advance who analyzes, who decides and how quickly.
As far as your own obligation is concerned, yes. Operating in other markets through correspondents is common and valid, but due diligence remains your responsibility: if the collaborator does not apply controls, the problem comes back to the agency that engaged them.
The practical route is to extend the controls by contract, with the right to request documentation and to carry out reviews.
The principle is proportionality. A small agency can have a very simple system, but it cannot do without any of the pieces: risk analysis, manual, acceptance policy, a file for each transaction, designated officer and training.
What is scaled to size is the depth of each piece, not whether it exists.
The club will do its own, and one of the counterparties it checks will be the agency. That does not replace the agent’s obligation to check its own counterparties or to keep its own file.
An intermediated transaction may involve three obliged entities working in parallel, each with its own records. We also cover this from the club’s side on our page on AML for football clubs.
In Spain, the authority envisaged is the ANIFI, which absorbs SEPBLAC and brings together supervision, inspection and sanctioning powers. It is an administrative supervisor, separate from football’s disciplinary bodies.
You can see what it is and what powers it has on our page on the ANIFI.
Start with what does not depend on the final text: review which counterparties you usually work with, how your payments are structured and what documentation you keep today for each transaction.
That inventory is half the work, and it also helps you spot now—with time to spare—the structures that in 2029 you would have to explain in a hurry.
Everything stated on this page comes from the EU legislative package or from official Spanish documents on legislation still going through the approval process.
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. It is the piece Spain must 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 fast, and an outdated guide wastes the time of whoever follows it. That is why we publish who maintains it and how.
Tell us how your agency operates, in which markets and through which structures you get paid, and we will tell you what system you need and its scope.
Of all the changes the EU AML package brings to football, the one that has received the least attention is probably the most disruptive: football agents become obliged entities in their own right. Not as collaborators of the club, not as parties the club must monitor, but as entities with their own obligations, their own records and their own administrative liability.
Because that is where the money that is hard to explain lies. In a transfer, the fee between clubs is public, it is declared and it has comparable benchmarks. The intermediary commission, by contrast, is agreed bilaterally, is often paid to companies other than the agent who negotiated, and its link to the work done is not always obvious from the outside. International bodies have been pointing to this flow for years, and Regulation (EU) 2024/1624 has turned it into a regulated area.
An active agent is already regulated: they need a license, a written contract with the person they represent and a declaration of their transactions to the federation. It is easy to conclude that this is enough, and that is a mistake. The sports regime regulates the profession and polices conflicts of interest; the AML regime asks about the source of the money and the real identity of whoever is behind each counterparty. They are independent controls, with different supervisors and with consequences that do not offset each other.
The core of an agent’s file fits in one sentence: why that amount, paid by that party, into that account, corresponds to that work. Everything else—the risk analysis, the manual, the acceptance policy, the records—exists so that this explanation can be supported years later. Keeping the representation agreement is necessary but clearly insufficient: what is required is the match between the service provided and the money received.
The obligation arrives on July 10, 2029, which seems to leave plenty of time. But one effect will come sooner: clubs that put their own system in place will start requiring of their intermediaries exactly what is required of them, because the agent is one of their counterparties. An agency without files and without a compliance structure will gradually be left out of deals with clubs that do have them, and that will happen well before the first inspection.
Key legislation, linked to the official text:
Legislation and links reviewed in .