For the first time, clubs and football agents will be designated as obliged entities under European anti-money laundering legislation, meaning mandatory customer due diligence, transaction monitoring and suspicious transaction reporting. As a regulation directly applicable in the Netherlands, the AMLR applies from 10 July 2027; for football clubs and agents specifically, obligations take effect on 10 July 2029.
The implications are far more immediate than they initially appear. Consider routine scenarios of every football club: a new investor joins, a sponsor signing a major contract, a player is bought or sold. Each of these moments now brings pressing questions that clubs must address under the upcoming AML-regime. Who is the ultimate beneficial owner (UBO) behind the investor, and is the ownership structure fully understood? Is the sponsor's fee in line with market standards, and are payments being routed through intermediaries or foreign entities? Who is funding the player transfer, and what happens if the transfer deadline approaches while due diligence is still incomplete? The AMLR turns these questions from ‘nice to know’ into ‘need to know.’ Here are the 5 things you need to know about the upcoming AMLR.
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#1 Football clubs will be designated as obliged entities under the AMLR
Professional football clubs are designated as obliged entities under the AMLR specifically with respect to transactions with:
- An investor,
- A sponsor,
- A football agent or another intermediary, and
- Transactions for the purpose of transferring a football player.
Not every club will automatically fall within scope. Only clubs that can convincingly demonstrate a low risk profile may qualify for an exemption, but this process is rigorous. Member States must conduct comprehensive risk assessments and put strict controls in place to prevent misuse. For top division clubs, the exemption is only granted if their total annual turnover is less than EUR 5,000,000 for each of the two preceding calendar years.
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#2 Clubs must establish robust AML compliance policies and appoint officers.
Being designated as an obliged entity is not a formality, it introduces significant governance and organisational responsibilities. Clubs must establish robust internal policies and procedures covering risk assessment and management, compliance with sanctions, customer due diligence, reporting of suspicious transactions, staff training, and regular audits. These frameworks must be thoroughly documented and formally approved at the appropriate levels.
Building compliance starts at the top. Under the AMLR, clubs are required to appoint a compliance manager at board level, who holds responsibility for ensuring adherence to all AML obligations. In addition, a compliance officer must be designated at a senior operational level to manage day-to-day anti-money laundering and counter-terrorist financing activities. This officer acts as the primary contact for regulatory authorities and is tasked with submitting any suspicious transaction reports to the Financial Intelligence Unit (FIU). These two roles are distinct and carry clear, direct accountability for compliance within the club.
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#3 Customer due diligence: know who you are dealing with
Customer due diligence (CDD) forms the practical core of the new obligations. Clubs are required to take several key steps:
- Identify and verify the customer’s identity
- Identify the ultimate beneficial owner (UBO) and reasonably verify their details
- Understand the ownership and control structure of the client
- Determine the purpose and intended nature of the business relationship
- Conduct sanctions screening
- Carry out checks on politically exposed persons (PEPs)
Within the football sector, sponsors, agents, investors and potential owners will often qualify as clients for whom these business relationships and due diligence requirements apply.
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#4 Ongoing monitoring: the obligation does not end at onboarding
Customer due diligence is not a once-off drill, nor does the whistle blow on your responsibilities at contract signing. Instead, the AMLR calls for clubs to keep a watchful eye on the pitch, routinely checking that the business relationships and transactions remain in line with what they know of the client and their risk profile. Client information must be kept up to date. In practical terms, a long-term sponsorship agreement or investor relationship remains subject to ongoing compliance oversight even after the contract is signed.
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#5 The reporting obligation: when suspicion arises, act promptly
Starting in 2029, professional football clubs carry a formal obligation to report directly to the Financial Intelligence Unit (FIU). Clubs must swiftly report where they know, suspect, or have reasonable grounds to suspect that funds or activities are the proceeds of criminal activity or are related to terrorist financing, including attempted transactions and suspicions arising from the inability to carry out CDD.
Two obligations arise the moment a suspicion is identified. First, a suspicious activity report must be submitted to the FIU immediately, via the designated compliance officer. Second – and equally important – the “tipping-off” prohibition is activated: neither the club nor its staff can let the client or any third party know that a report has been or will be made, or that an investigation is under way.
What should your club do now?
The 2029 deadline-day may seem distant, but building a compliant organisation takes time. The compliance requirements for professional football clubs are changing fundamentally, and any club that delays its preparations while waiting for supervisory guidance risks falling behind. This demands proactive and strategic planning at the highest levels of management. Clubs should begin by understanding which of their activities fall within the scope of the new regulations, designate clear compliance responsibilities within the organisation, and thoroughly review existing policies, processes and controls. Where gaps are identified, robust systems must be designed and implemented from the ground up.
The warm-up is starting. Get your board and compliance teams moving now. Map out your club’s compliance requirements, assign responsibilities, and audit current procedures. Acting early will protect your organisation and ensure readiness for the 2029 deadline.
If you have questions about how the AMLR will affect your club, or if you need tailored guidance on compliance matters, please do not hesitate to contact us.
