New AML Requirements in Football: A Practical Guide for Clubs and Agents
Co-Authored by Alex Harvey, Partner, Sheridans Sports Group, and Jonathan Greenstein, Co-founder and Director, Lagom Sports Compliance
Football has spent the past two years absorbing a wave of new financial regulation - UEFA’s overhauled licensing rules, the Football Governance Act 2025, and the Independent Football Regulator’s operating licence regime. Anti-money laundering compliance has, understandably, received less attention.
That is about to change. EU Regulation 2024/1624, the AMLR, names football clubs and agents specifically as obliged entities for the first time, and while the compliance date sits some years out, the scale of the change ahead means clubs and agents need to understand what is coming now, not when the deadline arrives.
This is a brief, practical guide to what that means, for clubs first, then for agents.
For football clubs
The headline development is Article 3(3)(n) of the AMLR, which brings professional football clubs and agents within the EU’s obliged entity regime for the first time - the same regulatory category that has long applied to banks, lawyers and estate agents.
For clubs, the application date is 10 July 2029. That sounds distant.
In compliance terms, however, it is not: building a genuine AML framework from nothing takes years, not months, and clubs that start now will be far better placed than those that wait.
The obligation itself is familiar in substance, even if new to football. Article 9 of the AMLR requires obliged entities to appoint a designated compliance officer and, separately, a money laundering reporting officer - roles that can, depending on the size and structure of the organisation, sit with the same individual or be split across two. Clubs will also need documented, risk-based customer due diligence processes, ongoing monitoring of higher-risk relationships, and a genuine understanding of who they are actually transacting with, extending to beneficial ownership verification of counterparties in transfers, sponsorship arrangements and investment structures, not merely the entity on the contract.
For UK-based clubs, it is worth being precise about scope. AMLR is an EU regulation, but UK clubs should not assume they are outside of scope: the obligation attaches to entities meeting the AMLR’s own criteria regardless of domicile in some circumstances, and clubs regularly dealing with EU counterparties (e.g. selling clubs, EU-based agents, EU sponsors) are likely to experience AML-driven requirements arriving from the other side of those relationships well before 2029.
There is also a domestic governance dimension worth flagging. The Independent Football Regulator’s operating licence conditions do not duplicate AMLR, but a club building genuine financial governance capability for its IFR licence - including accurate financial reporting, clear ownership structures, credible source-of-wealth evidencing for owners - is, in substance, building much of the same underlying infrastructure AML compliance will eventually require.
Clubs treating these as separate projects are likely to duplicate effort; clubs treating them as one connected governance programme will not.
For agents
Agents face the same Article 3(3)(n) inclusion and the same 10 July 2029 application date, but the practical exposure looks different, because of how agent businesses are structured and how agent income actually moves.
The most immediate point for advisers is that AMLR does not distinguish between a large international agency and a single-operator agent in terms of the obligation: both fall within scope if they meet the criteria, but it does allow for proportionality in how that obligation is discharged.
A framework appropriate for an agency running dozens of high-value transfers a year is likely to look materially different from one appropriate for a sole agent handling a handful of lower-value domestic deals. Getting that proportionality assessment right - neither over-building compliance infrastructure a small practice does not need, nor under-building it for a genuinely higher-risk client base - is one of the more nuanced pieces of early advice agents should be seeking now.
The specific AML exposure in agent work tends to concentrate around a small number of recurring patterns: commission structures with limited transparency over the ultimate recipient, payments routed through intermediary or connected-party structures, and cross-border fee arrangements where the source of funds is difficult to trace.
None of this means agent commissions are inherently suspect, but it does mean that from 2029 agents will need to be able to evidence the due diligence behind those arrangements in a way the market has not historically required.
Agents should also be alert to the fact that clubs, as they build their own AML frameworks in the run-up to 2029, will increasingly expect agents to demonstrate their own compliance as a condition of doing business, well before the regulatory deadline formally requires it. An agent who can demonstrate a credible compliance framework early is likely to find that player transfers and contract renegotiations can progress more smoothly without being held up by AML requirements.
The practical starting point
For both clubs and agents, the sensible first step is the same: an honest, proportionate assessment of current exposure against the AMLR’s actual requirements, rather than either ignoring a deadline that still feels distant or over-engineering a compliance framework disproportionate to genuine risk. 2029 will arrive faster than the football industry currently expects.
Jonathan Greenstein is Co-founder and Director of Lagom Sports Compliance, the UK’s specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. Lagom advises clubs and agents on AML compliance, IFR licensing and UEFA financial sustainability regulation. For more on AML compliance support for football agents, see lagomsportscompliance.com/aml-compliance-for-football-agents, and for clubs, see lagomsportscompliance.com/aml-compliance-for-football-clubs.
Alex Harvey is a Partner in the Sports Group at Sheridans and advises clubs and agents on a range of regulatory matters, including under the new IFR regime.
