English football’s money laundering challenge

English football is more than a sport; it’s a cultural institution and major economic force.

But with global reach and financial clout comes a darker side: the risk of money laundering and organised crime.

Recent government scrutiny and regulatory reform have put these issues front and centre for clubs, investors and their legal teams. If you’re an in-house lawyer or senior executive in football, understanding these risks and how to address them is now business-critical.

Why football? Understanding the sector’s vulnerabilities

Football’s financial ecosystem is unique. Clubs deal with vast sums, complex ownership structures and international investment. These factors drive success – but also create financial crime risks. Here’s what makes football particularly vulnerable:

• Opaque ownership structures: many clubs are owned through intricate networks of holding companies, often offshore. Over half of Premier League clubs have at least one offshore holding company, making it hard to identify true beneficial owners
• Complex transactions: transfers, sponsorships and image rights deals can be used to inject illicit funds. The use of third-party intermediaries and high-value, cross-border transactions further complicates oversight
• Links to organised crime: Europol and the Financial Action Task Force (FATF) have flagged connections between organised crime and football, including match-fixing, betting corruption and laundering proceeds from other crimes.

Government concerns and the regulatory response

The UK government’s latest National Risk Assessment flags football as a sector at high risk for money laundering. Key concerns include:

• Hidden ownership: complex corporate structures and offshore entities obscure the real source of investment funds
• Financial distress and external funding: many clubs, especially outside the Premier League, operate at a loss and rely on external funding, making them vulnerable to questionable investors
• Weak due diligence: smaller clubs may lack the resources or expertise to vet prospective owners, sponsors and agents
• Sanctions risk: there’s a danger that sanctioned individuals, including those linked to foreign regimes, could use clubs to hide or legitimise illicit wealth.

The Football Governance Act 2025 and the Independent Football Regulator

To tackle these risks, the government has introduced the Football Governance Act 2025, creating an Independent Football Regulator (IFR) with sweeping powers:

• Stricter ownership tests: prospective owners and directors must undergo rigorous due diligence, including source-of-wealth checks and fitness and propriety assessments
• Transparency rules: clubs must publish the identities of beneficial owners, backed by verifiable documentation
• Financial regulation: the IFR will enforce tougher financial sustainability rules, monitor club finances and intervene to prevent collapse or criminal exploitation
• Law enforcement collaboration: the IFR will work with HMRC and the National Crime Agency to share intelligence and enforce compliance
• Fan engagement and heritage protections: new standards will give fans a greater say in club governance, helping to deter rogue ownership.

What this means for in-house legal and executive teams

The regulatory landscape is shifting fast. Clubs must take a proactive, risk-based approach to governance and compliance. For in-house lawyers and executives, this means:

• Reviewing and strengthening due diligence for owners, directors, sponsors and agents
• Ensuring full transparency of ownership and financial transactions
• Engaging with the IFR and law enforcement as part of ongoing compliance
• Embedding governance frameworks that go beyond minimum legal requirements.

Key takeaways: practical steps for better governance

1. Strengthen due diligence: run comprehensive integrity checks on all prospective owners, directors, sponsors and agents, including source-of-wealth and background checks
2. Increase transparency: keep beneficial ownership information accurate, up to date and publicly available, supported by verifiable documentation
3. Enhance financial oversight: regularly review and stress-test club finances and establish clear protocols for monitoring high-value or cross-border transactions
4. Foster a culture of compliance: train staff, engage fans and stakeholders and maintain open lines of communication with regulators and law enforcement.

By taking these steps, clubs can meet new regulatory requirements and protect their reputation, finances and the integrity of the game.