Prepare for the new EU AML requirements ahead of July 2029
Professional football clubs and football agents will come within the scope of new EU Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) requirements under the EU Anti-Money Laundering Regulation (AMLR).
Understand how the new requirements apply to your organisation, what you will need to put in place and how Complyport can support your preparations.
Under Regulation (EU) 2024/1624 (AMLR), professional football clubs and football agents are brought within the EU AML/CFT framework, introducing new compliance obligations for organisations within scope.
For many organisations in the football sector, this will mean establishing formal AML/CFT arrangements for the first time, including governance, risk assessments, customer and counterparty due diligence, beneficial ownership checks, screening, ongoing monitoring, suspicious transaction reporting, record keeping and staff training.
Preparing early allows clubs and agents to understand how the new requirements apply to their activities, identify gaps and integrate appropriate AML/CFT controls into existing commercial and operational processes.
AMLR brings both professional football agents and professional football clubs within the EU AML/CFT framework, although the scope of their obligations differs.
Professional football agents are brought within the scope of AMLR and will therefore need to comply with the applicable AML/CFT requirements.
AMLR defines a football agent as a natural or legal person who, for a fee, provides intermediary services and represents football players or professional football clubs in negotiations relating to player contracts, or represents professional football clubs in negotiations relating to player transfers.
This includes individuals and legal entities that, for remuneration, negotiate or arrange the conclusion of contracts for the employment of professional football players or the transfer of their registration rights.
Professional football clubs will become obliged entities in respect of specified transactions involving:
For the purposes of AMLR, a professional football club is a legal person that is, owns or manages a football club that has been granted a licence and participates in the national football leagues of an EU Member State and whose players and staff are contractually engaged and remunerated for their services.
Potentially. AMLR allows Member States to exempt certain professional football clubs, in full or in part, where a proven low level of money laundering and terrorist financing risk exists.
For Professional football clubs participating in the highest division of a national football league, an exemption may be granted where total annual turnover is below EUR 5 million in each of the previous two calendar years and the nature and scale of the club’s operations are assessed as presenting a proven low level of risk.
Member States must carry out a risk assessment when considering these exemptions, taking into account relevant money laundering and terrorist financing threats and vulnerabilities, as well as risks associated with the size and cross-border nature of the club’s transactions.
Professional football clubs and football agents within scope will need to establish AML/CFT arrangements appropriate to their activities and risk exposure.
Establish appropriate AML/CFT governance, responsibilities and internal controls, supported by an assessment of the money laundering and terrorist financing risks to which the organisation is exposed.
Establish procedures to identify and verify relevant customers and counterparties, understand the purpose and nature of applicable business relationships and transactions and assess associated risks.
Identify and verify the individuals who ultimately own or control relevant legal entities involved in applicable relationships or transactions and understand potentially complex ownership structures.
Apply enhanced measures where higher levels of money laundering or terrorist financing risk are identified, including, where appropriate, consideration of source of funds and source of wealth.
Implement appropriate screening processes to identify politically exposed persons (PEPs), sanctions exposure and other relevant risk factors.
Monitor relevant business relationships and transactions on a risk-sensitive basis and ensure that due diligence information remains up to date.
Establish procedures for identifying, escalating and reporting suspicious activity to the relevant authorities where required.
Maintain appropriate records and evidence of due diligence, transactions and other AML/CFT measures in accordance with applicable requirements.
Ensure relevant personnel receive appropriate AML/CFT training covering financial crime risks, regulatory responsibilities and internal procedures.
From initial readiness assessment through to implementation and ongoing compliance,
Complyport can support professional football clubs and agents in preparing for the new AMLR requirements.
Assess how AMLR applies to your organisation, review existing arrangements, identify compliance gaps and establish a practical implementation roadmap.
Establish governance, policies, procedures and internal controls aligned with your activities and risk exposure.
Develop and implement due diligence processes, including beneficial ownership identification and enhanced due diligence for higher-risk relationships.
Support the development of appropriate AML/CFT controls for relevant transactions involving player transfers, sponsors, investors, football agents and other intermediaries.
Establish appropriate sanctions and PEP screening, risk-based monitoring, escalation procedures and supporting record-keeping processes.
Provide role-specific training and ongoing support to help relevant teams and decision-makers understand and meet their responsibilities.
Provide independent reviews of AML/CFT frameworks and controls, identify areas for improvement and support remediation and ongoing compliance.
Whether you need to assess how AMLR applies to your organisation, establish an AML/CFT framework for the first time or strengthen existing arrangements, our AML & Financial Crime specialists can support you through the steps required to prepare.
Regulation (EU) 2024/1624 establishes directly applicable AML/CFT requirements across the European Union. It expands the range of sectors and organisations subject to AML/CFT obligations, including professional football clubs and football agents.
Professional football agents are brought within the scope of AMLR as obliged entities.
Professional football clubs are also brought within scope in respect of specified transactions involving investors, sponsors, football agents and other intermediaries, and player transfers.
Certain professional football clubs may potentially be exempted by Member States where the conditions set out in AMLR are met and a proven low level of money laundering and terrorist financing risk exists.
Organisations within scope will need to establish appropriate AML/CFT arrangements, including governance and risk assessment, customer and counterparty due diligence, beneficial ownership identification, enhanced due diligence where appropriate, PEP and sanctions screening, ongoing monitoring, suspicious transaction reporting, record keeping and staff training.
The precise measures required will depend on the organisation’s activities, relationships, transactions and risk exposure.
The relevant AMLR requirements for professional football clubs and football agents will apply from 10 July 2029.
Establishing an effective AML/CFT framework can require changes to governance, policies, risk assessment, due diligence, screening, monitoring, reporting and training.
Early preparation provides time to understand the requirements, identify gaps and embed proportionate controls before the requirements apply.
Get in touch with our AML & Financial Crime specialists to discuss how AMLR applies to your organisation and how we can support your preparations.
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We provide bespoke compliance solutions that are specifically designed to meet the unique needs of your business, ensuring that all regulatory requirements are met efficiently and effectively.
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