Football clubs and football agents have been named for the first time as emerging risks for money laundering and terrorist financing in an annual government report, published on Thursday .
The sport’s “hidden nature” was raised as a specific issue, which means “the scale of criminality” remains “an intelligence gap” that is “difficult to accurately estimate”.
Even more pressingly for the game’s authorities, the document cited diverse ownership models, profound financial inequality and distressed clubs as specific vulnerabilities, as well as how proceeds of crime could occur through multiple routes, from transfers to falsification of services.
The report, titled “National Risk Assessment of Money Laundering and Terrorist Financing 2025” states for the first time that that “alongside money laundering, football has the potential to be abused for a range of other crimes, including illegal betting, match fixing and bribes” or as an opportunity to “invest illicit funds”.
The report states: “Many clubs have complex offshore corporate structures involving overseas-based enablers and financial products, often in jurisdictions with limited regulatory oversight… Ownership structures using layered front and shell companies, often based overseas or in jurisdictions with low transparency, could obscure the ultimate beneficiaries of clubs and other major stakeholders, such as sponsorship arrangements”.
The report specifically states how “financial distress” of lower-league clubs is a particular risk if they are “unable to access loans from traditional lenders”. Clubs’ propensity for debt to be carried as “normal financial practice” is cited as another vulnerability that could be exploited, and potentially further enabled by poor application of due diligence on investors.
The theme is particularly pointed amid an ongoing impasse between the Premier League and EFL over a redistribution deal, that could yet see the soon-to-be-implement independent football regulator step in.
“Clubs could be used as a vehicle both to launder funds, as well as a final destination for criminal money to be invested,” the report goes on to read. “Players values in particular are difficult to objectively determine which increases the risk of manipulation for money laundering.”
The wider financial industries around football, particularly agents, are also highlighted.
“Professional service providers including accountants, lawyers, trust or company service providers and wealth managers are common features in football related transactions so could be exposed to a risk of facilitating money laundering,” the report states. “In many cases these services are employed in-house by clubs, potentially presenting conflict of interests in detecting and reporting suspicious financial activity.
“As they are employed in house rather than ‘by way of business’, many agents and ‘fixers’ in the sector operate without regulatory supervision, compounding the opportunities and risks of money laundering. Fees paid to agents, intermediaries and others involved in transactions could be a convenient route by which to launder money or pay bribes.
“This risk is raised when agents represent both player and club during a transaction. Lawyers, accountants, financial service firms and others associated with processing these fees and payments should take all necessary steps to understand their purpose and source to ensure they are legitimate.”
