The UK's first AML and asset recovery strategy proposes consulting on extending AML rules to football clubs and agents, responding to a gap identified in the 2025 National Risk Assessment.
INTRODUCTION
On 15 September 2026, the Home Office published the UK's first-ever anti-money laundering ("AML") and asset recovery strategy. The strategy sets out how the Government intends to strengthen the UK’s response to money laundering and address regulatory gaps identified in the 2025 National Risk Assessment of Money Laundering and Terrorist Financing (“2025 NRA”). The strategy highlights risks from new technologies, evolving typologies, and vulnerabilities in sectors that currently sit partly or wholly outside the Money Laundering Regulations (“MLR”)1, and identifies football as an area of emerging concern for the first time. The strategy also includes an intention to consult on extending AML regulations to football clubs, players' agents and other presently unregulated sectors.
The financial crime risk in football has come under increased scrutiny around the world as the commercial success and economic importance of the game continues to grow. In the UK, the 2025 NRA found that professional football has become "an attractive target for criminals, kleptocrats and other malign actors seeking to launder their criminal funds or generate further illicit gains".2 This risk goes beyond headline criminality: football clubs may not deal in areas commonly associated with money laundering, such as drug trafficking or fraud. However, where payments to agents, intermediaries or counterparties are connected to opaque or illicit arrangements, those payments can themselves constitute criminal property, exposing clubs and individuals to obligations and potential liability under the Proceeds of Crime Act 2002.3
THE STRATEGY'S PROPOSAL
The proposed consultation is a direct response to the findings of the 2025 NRA, which for the first time included football clubs and agents within its assessment of money laundering risk. The NRA found that football's turnover of more than £6 billion in the 2023-24 season alone makes the sector an attractive target for those seeking to launder money or invest illicit funds, including by providing loans to clubs in financial distress that may be unable to access traditional finance. The NRA also identified a specific gap in regulatory coverage: many agents and in-house "fixers" are employed directly by clubs rather than operating independently "by way of business", meaning they fall outside any AML regulatory supervision. The scale of criminality in football is acknowledged as an "intelligence gap" that is difficult to estimate.4
At this stage, the proposal is only for a consultation to be carried out to assess how illicit finance risks within football might be addressed and to gather evidence which would allow for “gaps in the regulatory perimeter” to be closed in a targeted manner. The strategy indicates that sectors would only be brought within scope of the MLR "where necessary and effective to address a real risk of money laundering or terrorist financing", and the consultation will also consider whether alternative approaches, short of regulation, may be better suited.
The UK is due to undergo its next FATF mutual evaluation in 2027, an assessment that will examine, among other things, whether the UK’s AML regulatory perimeter reflects its actual risk exposure. This adds urgency to the Government’s actions to close identified gaps. It may also result in additional regulation of football, which has attracted significant media and political attention in recent years (e.g., concerns over club ownership in the UK, and FIFA's now-abandoned proposals to channel over US$10 billion in development funding through a new commercial subsidiary, which brought renewed attention to the governance risks inherent in football's financial structures). Taken together, the above suggests that the UK is likely to bring football within the ‘regulatory perimeter’. Any additional measures introduced as a result of the consultation would be in addition to the non-AML-related provisions introduced by the Football Governance Act 2025, which include requiring clubs to provide, and the Independent Football Regulator to consider, information relating to source of funds.
THE WIDER REGULATORY LANDSCAPE
Internationally, the direction of travel is towards regulation. In April 2024, the EU adopted a new AML legislative package comprising the Sixth Anti-Money Laundering Directive, a directly applicable AML Regulation establishing a single rulebook, and a Regulation establishing a new EU Anti-Money Laundering Authority (“AMLA”).5 As a result, for the first time at EU level, from 10 July 2029, professional football clubs and football agents will be brought within the framework as “obliged entities”, and will be required to carry out customer due diligence in the context of player transfers, sponsorship deals, and transactions with investors and intermediaries. Clubs and agents will also be required to identify the beneficial owners of any investors, sponsors and other parties providing funding, and carry out ongoing transaction monitoring and suspicious transaction reporting.
The inclusion of football was not part of the European Commission’s original proposal but was added during the legislative process to reflect Europol's 2021 Serious and Organised Crime Threat Assessment, which found that professional football was "prone to the risks of criminal money and money-laundering transactions", and the Commission's own 2019 risk assessment, which described football as a "global industry with significant economic impact" in which "questionable sums of money with no apparent or explicable financial return or gain are being invested". In a recent interview, AMLA Chair Bruna Szego indicated that football's inclusion in the EU’s AML framework reflects the sector's global reach, the considerable sums and cross-border transactions involved, and concerns about ownership and investment structures that are not always transparent.
WHAT THIS MEANS FOR FOOTBALL-RELATED BUSINESSES
Football clubs, players' agents and others not currently subject to AML obligations should begin considering what future regulation might involve. Although it is not clear at this stage what, if any, additional AML regulatory measures concerning football might be introduced as a result of the consultation, recent developments suggest that those involved in the industry should prepare for at least some additional measures. If the UK follows the EU’s lead, obligations for clubs are likely to include due diligence on counterparties to player transfers, sponsorship deals, and transactions with investors and intermediaries, together with beneficial ownership identification, ongoing transaction monitoring and suspicious activity reporting. Clubs and agents would need compliance infrastructure, trained staff and reporting lines that many may not currently have.
The Government’s strategy commits to consulting in Year 1 (i.e., 2026-27) on whether to expand the regulatory perimeter; although the consultation has not yet launched, potentially affected parties should consider engaging with that process, both to shape the regulatory design and to begin assessing their own readiness.
Footnotes
1. See the strategy, paragraphs 55 and 56. Other gaps identified are: property developers, offshore virtual asset service providers (cryptocurrency businesses operating across borders), antiques and antiquities dealers, donation-based crowdfunding, and changes to the current scope of regulation for letting agents and higher-risk high-value goods dealers.
2. 2025 NRA, Part 5 (Emerging and Cross-Cutting Risks: Football Clubs and Agents), paragraph 6.15.
3. Proceeds of Crime Act 2002, c. 29, Part 7.
4. Paragraph 6.21 of the 2025 NRA.
5. Directive (EU) 2024/1640 of the European Parliament and of the Council of 31 May 2024 (OJ L 2024/1640); Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (OJ L 2024/1624); Regulation (EU) 2024/1620 (OJ L 2024/1620), here.
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