Implications for professional football clubs and football agents:
From 10 July 2029, professional football clubs and football agents will be fully subject to the European anti-money laundering requirements set out in the new EU Anti-Money Laundering Regulation (EU) 2024/1624 (‘AMLR’).
On 13 July 2026, the newly established EU Anti-Money Laundering Authority (‘AMLA’) published a consultation paper on a draft set of regulatory technical standards (Draft RTS) on the assessment and classification of the inherent and residual risk profile of obliged entities in the non-financial sector, in accordance with Article 40(2) of Directive (EU) 2024/1640. The draft RTS set out how supervisory authorities will in future assess the money laundering and terrorist financing risk of obliged entities in the non-financial sector in a uniform manner.
The draft is of considerable significance for professional football: In future, the risk classification will determine how frequently and thoroughly clubs and agents are audited, and which risk mitigation measures supervisors will expect them to implement.
Table of Contents
1. What is the consultation paper about?
The Draft-RTS establish a uniform methodology enabling supervisory authorities to identify, assess and assign the risk profile of obliged entities in the non-financial sector to a risk class.
Under Article 3(3)(n) and (o) of the AMLR, these obliged entities also include football agents and professional football clubs.
Regulatory Technical Standards (‘RTS’) set out the legal requirements in more detail through binding criteria, data requirements and calculation methods. The proposed methodology follows three steps:
The Draft-RTS set out a harmonised methodology. This is based on a three-stage approach:
- determination of inherent risk using sector-specific data points (Annex I),
- Assessment of the quality of AML/CFT controls using a cross-sector set of indicators (Annex II),
- Derivation of a residual risk, which is categorised into four classes (“low”, “medium”, “substantial”, “high”) and is used by the supervisory authority to calibrate the intensity and frequency of AML/CFT supervision.
2. The methodology: How will the supervisory authority measure risk in future?
The Draft-RTS provide for an entity-specific risk analysis for all registered obliged entities in the non-financial sector. This must cover at least one full calendar year.
For each data point from Annex I, the supervisory authority assigns a value between 1 for low risk and 4 for high risk. The following are assessed in particular:
- organisational and ownership structure,
- customers and business partners,
- products and services,
- geographical risk factors,
- distribution and payment channels.
The individual scores are first weighted within their respective categories. This results in an overall score for inherent risk, which is assigned to one of four risk levels. High-risk categories carry greater weight in this assessment.
The process works in a similar way for the for the assessment of the quality of AML/CFT controls (Annex II): here too, the scale ranges from 1 to 4, representing a very high to a low level of quality. The control score derived from this is mapped to levels A to D (Art. 3(6) and (7) of the Draft RTS).
The residual risk is derived from the combination of both assessments. In this context, greater weight is given to the inherent risk.
3. Simplifications for ‘small entities’:
The Draft-RTS provide for a reduced data set for small obliged entities. ‘Small obliged entities’ are defined as companies with fewer than five full-time equivalents and an annual turnover of less than EUR 600,000.
For professional football clubs, this relief is unlikely to be relevant on a regular basis. It is more relevant for smaller football agencies.
However, the simplification does not apply without restriction: if the supervisory authority classifies a sector as high-risk, it may require even small businesses to provide the full set of indicators.
4. Annex I: What does this mean for football agents?
For football agents, Annex I distinguishes between a
- a reduced data set (‘Reduced Set’) for small obliged entities and
- a full data set (‘Full Set’) for all other football agents.
1. Reduced Set
The reduced data set focuses on the key risk factors:
- organisational and ownership structure,
- beneficial owners,
- customers with PEP status,
- links to high-risk third countries,
- business volume,
- scope and value of brokered transactions,
- geographical risks,
- payment structures and the involvement of third parties.
In this way, the AMLA specifically addresses complex corporate structures, international business relationships and multi-tiered payment channels.
2. Full Set
The full data set expands on this information, in particular by providing:
- further details on ownership and group structures,
- parent companies and branches,
- the distinction between resident and non-resident customers,
- more detailed information on business volume,
- cross-border business relationships and payment flows.
This provides the supervisory authority with a comprehensive picture of the individual risk profile. Complex corporate structures, international interdependencies, high-risk countries and non-transparent payment channels may lead to a higher risk rating and more intensive supervision.
5. Annex I: What does this mean for professional football clubs?
For professional football clubs, Annex I requires only the complete data set. In particular, the following are recorded:
- organisational and ownership structure,
- complex shareholdings,
- beneficial owners,
- PEPs and links to high-risk countries,
- parent companies and branches,
- Customer and business partner structure,
- business volume,
- transfer transactions,
- Sponsorship agreements,
- Ticket and merchandising revenue,
- Payments via third parties,
- cross-border payment flows.
The data set thus covers precisely those areas that are particularly relevant in professional football from an anti-money laundering perspective: transfers, investors, sponsorship, international business relationships and complex payment channels.
High transaction volumes, complex ownership structures and the involvement of numerous market participants can significantly increase a club’s risk profile.
6. Annex II: What professional football clubs and football agents must provide regarding their AML/CFT governance and control measures
Whilst Annex I sets out the inherent risk, Annex II assesses the quality of the AML/CFT controls in place.
The focus is on:
- governance and organisational structures,
- management’s responsibilities,
- company-wide risk analyses,
- internal policies and procedures,
- identification and monitoring of business relationships,
- transaction monitoring,
- suspicious activity reporting,
- training programmes,
- internal controls and audits,
- regular review of compliance systems.
The supervisory authority thus not only assesses the risks to which an association or intermediary is exposed; it also examines whether its compliance structures are suitable for effectively identifying and mitigating these risks.
7. Conclusion and outlook:
The Draft-RTS establish, for the first time, a uniform standard for the risk classification of the non-financial sector under anti-money laundering legislation.
For professional football clubs and football agents, this means above all that complex ownership structures, international payment flows, links to high-risk countries and inadequate control systems will in future directly determine the intensity of supervision.
Small football agents may, in principle, benefit from the reduced data set. However, in the event of an increased sectoral risk, the supervisory authority may also require them to provide the full set of data.
The consultation is therefore far more than a technical procedural step. It gives clubs, agents and associations the opportunity to highlight any disproportionate or impractical requirements and to help shape the final form of the standards.
Comments may be submitted until 27 September 2026.
A public hearing organised by the AMLA is also scheduled for 10 September 2026. According to the current draft, the RTS are to apply from December 2028, so that those subject to the obligations have sufficient time for implementation.
Practical tip:
Regardless of how the legislative process proceeds, it is advisable to begin making the necessary organisational and technical preparations now. These include, in particular:
- Active participation in the consultation:
Football agents and professional football clubs should assess whether the proposed data points are practical and proportionate. Suggestions for improvement can be submitted via the relevant associations or in the form of their own submissions. - Establishing a robust AML data framework:
The information set out in Annex I should be recorded in a structured manner at an early stage and integrated into existing data and IT systems in order to be able to fulfil future reporting and record-keeping obligations efficiently. - Further development of AML/CFT governance:
Annex II provides a concrete framework for establishing a robust compliance organisation. In particular, the following areas should be reviewed and further developed:
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- Governance and responsibilities,
- Risk analyses,
- KYC processes,
- Transaction monitoring,
- Training,
- internal controls,
- audit and reporting processes.
The message from the AMLA is clear: anti-money laundering in professional football does not begin in 2029. It is already becoming apparent today what data the regulator will expect in future and according to which criteria it will assess risks.
Anyone who waits until the regulations come into force to adapt their data management and compliance structures risks only disclosing existing vulnerabilities as part of the regulatory risk classification process – and thereby exposing themselves to more intensive supervision.
