Professional football and AML

From 10 July 2029, the new European anti-money laundering framework will extend specific AML obligations to professional football. For clubs and agents, the next three years provide valuable time to define processes, responsibilities and tools suited to the realities of professional football.

Professional football is a complex ecosystem. Clubs, agents and intermediaries, investors, sponsors, connected companies and other counterparties may all be involved in transactions spanning multiple organisations and jurisdictions.

With the application of Regulation (EU) 2024/1624 – the AML Regulation (AMLR) from 10 July 2029, the sector will become directly subject to new anti-money laundering requirements.

For clubs and agents, however, however, the objective is not simply to be compliant by the regulatory deadline. The time available provides an opportunity to build an AML framework that can be effectively embedded into the day-to-day processes of professional football.

From counterparty checks to an AML framework

Knowing a counterparty means more than simply checking a name.

Depending on the level of risk and the nature of the transaction, due diligence may require organisations to identify and verify the counterparty and its beneficial owner, understand their risk profile and identify relevant risk indicators, including potential links to politically exposed persons (PEPs), sanctions or adverse information from open sources.

And the initial check is only one part of the process.

An effective AML framework combines four key capabilities:

VERIFY → ASSESS → MONITOR → DOCUMENT

• Verify the information available.
• Assess risk against defined criteria.
• Monitor relevant changes over time.
• Retain evidence and assessments to provide a clear audit trail for the decisions made.

In other words, screening is a component of an AML framework – it is not the framework itself.

Professional football does not have to start from scratch

In this respect, the sector has an important advantage.

Due diligence, screening, ongoing monitoring and evidence management processes are already well established across regulated sectors. Professional football can therefore build on existing expertise, methodologies, data and technology, adapting them to the specific characteristics of its own activities.

Dataware brings more than twenty years of AML data expertise to professional football, in collecting and processing data and information to support AML controls, together with technology designed to make that intelligence usable within screening and monitoring processes.

The aim is not simply to transfer models developed for other regulated industries into football. It is to use an established foundation to build processes that are proportionate to the risks, counterparties and transactions that characterise the professional football market.

Three years to build the framework

“10 July 2029” is the deadline, not the starting point.

The journey can begin well before then: from mapping relevant transactions and counterparties and defining internal responsibilities and procedures, through to identifying the information and tools needed to perform checks, monitor changes and document decisions.

It is a process that requires vision, the ability to anticipate risk and processes that work in practice.

Vision, anticipation and a game plan that works in practice: familiar principles in football, even if AML is played on a different field.