This blog post is part of a joint series by Annerton and GRUENGOLD LEGAL on the topic of “Professional Football and Anti-Money Laundering Prevention”, which we launched in December 2025 with an overview entitled “New Compliance Requirements for Professional Football Clubs and Football Agents in the EU” (Part 1).
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This blog post continues the series on professional football and anti-money laundering prevention. Part 2 focuses on the addressees within the football sector. From 10 July 2029, they will be subject to the provisions of the European Anti-Money Laundering Regulation (EU) 2024/1624 (Anti-Money Laundering Regulation, “AMLR”).
The AMLR identifies “professional football clubs” (cf. Art. 3 No. 3 lit. o AMLR) and “football agents” (cf. Art. 3 No. 3 lit. n AMLR) as obliged entities. The definitions of both terms are relatively sparse and leave room for interpretation. In addition, in the case of more complex club structures – for example so-called “works teams” – it must be taken into account that the holding company, as the parent company of the professional football club or as a “non-financial mixed activity holding company”, may also come into focus of anti-money laundering obligations under the AMLR (Art. 2 para. 1 No. 13 AMLR).
Professional football clubs as obliged entities
Professional football only – no other professional sports?
First of all, it should be noted that the AMLR focuses exclusively on professional football, even though money laundering risks are also likely to exist in other professionally organised sports marketed in Europe, inter alia, through lucrative media and sponsorship partnerships. One need only think of the expansion ambitions of the American basketball league NBA in Europe[1] or the revenues of professional ice hockey clubs, which often far exceed the EUR 5 million threshold (which the AMLR indirectly regards as an indicator of increased money laundering risk for a first-division football club pursuant to Art. 5 (1) AMLR, as above this threshold a national exemption from anti-money laundering obligations is excluded).
It is therefore permissible to advance the – at first glance bold – thesis that professional clubs in other sports should also, under general compliance considerations and on a voluntary basis, adopt anti-money laundering measures similar to those that the AMLR will make mandatory for professional football clubs from 10 July 2029. This recommendation applies all the more to clubs that combine several professional sports under one organisational umbrella.
Definition: “Professional football club”
Under Art. 2 (1) No. 52 AMLR, a “professional football club” is defined as
“any legal person that is, owns or manages a football club that has been granted a licence and participates in the national football leagues in a Member State and whose players and staff are contractually engaged and are remunerated in exchange for their services;”
Apart from the criterion of being a legal person and the fact that a professional football club only qualifies as an obliged entity if (i) it has been granted a licence, (ii) its team(s) participate in one or more national football leagues, and (iii) it employs players and staff under contract who receive remuneration, this definition remains vague.
In particular, it does not specify what exactly constitutes a football club. It is likely clear, however, that it refers to all adherents of the world’s number one ball sport – association football played on grass.
Grass football only – or also indoor football?
In principle, the indoor variant “futsal” (an abbreviation of the Portuguese and Spanish terms for indoor football (futebol de salão / fútbol sala)), played five-a-side on a handball-sized pitch with a reduced-bounce ball) also fulfils the AMLR’s concept of football.
At the very least, this variant falls under the concept of football as understood by both the Fédération Internationale de Football Association (“FIFA”) and the Union of European Football Associations (“UEFA”), both of which organise competitions for national and club futsal teams.
It remains to be seen whether futsal will in fact be covered in the future, as the AMLR allows Member States to provide for exemptions for certain professional football clubs, in particular where only a low risk potential exists. Given the economic scale of futsal, this could ultimately argue against including indoor football within the scope of the AMLR.
eFootball as well?
Another variant that may be subsumed under the AMLR’s concept of football is so-called “eFootball”. As early as 2012, the DFL Deutsche Fußball Liga (“DFL”) launched an eSports competition with the Virtual Bundesliga (“VBL”). DFL attributes growing popularity and increasing overall relevance to eSports. A championship is being held, and a media partnership exists with a major streaming provider.[2] In light of these developments, it would be difficult to exclude eFootball from the scope of the AMLR where it is associated with professional structures and relevant revenues. However, under the current DFL rules of competition for the VBL, only clubs playing in the Bundesliga and 2. Bundesliga are eligible, meaning that at least for the time being no additional group of addressees is likely to arise.
Licensing requirement
Another prerequisite is that actors in professional football hold a licence as authorisation to participate in competition. The term “licence” in the anti-money laundering context is to be understood in a non-technical sense and therefore includes both licences expressly designated as such and other forms of admission to competition. In Germany, licences in grass football are granted by the DFL to the licensed clubs of the Bundesliga and 2. Bundesliga, and for the Third Division by the German Football Association (“DFB”) in the form of authorisation to participate in league play.
Owners and operators of professional football clubs as obliged entities
If the above requirements are met, the possible obliged entities under the wording of the AMLR are the professional football club itself or its owner or manager. Although most German professional football departments have been spun off into a corporate entity, the “50+1 rule” requires that the majority of voting rights remain with the registered parent association.
As a result, the circle of addressees under the AMLR is regularly expanded: both the professional football department organised as a corporate entity and the parent association in the legal form of a registered association (e.V.) may fall within the scope of the AMLR. Companies that – in addition to the club – hold shares in the football company may also be covered by the definition (depending on the size of their shareholding).
This requires the implementation of a holistic approach that takes into account the specific structure of the respective club when implementing the AMLR requirements. This includes, inter alia, establishing and ensuring an effective risk management system, such as preparing a detailed money laundering risk analysis, applying customer due diligence measures (know-your-customer – “KYC”) with regard to contractual partners such as investors, sponsors, advertising partners or other partners in transfer transactions, ongoing monitoring of business relationships and transactions, appointment of a money laundering reporting officer and a compliance manager, employee training, etc.
Football agents as obliged entities
Definition of “football agent”
Under Art. 2 (1) No. 53 AMLR, the AMLR defines a football agent – a term that replaces the commonly used German concept of the player agent – as
“a natural or legal person who, for a fee, provides intermediary services and represents football players or professional football clubs in negotiations with a view to concluding a contract for a football player or represents professional football clubs in negotiations with a view to concluding an agreement for the transfer of a football player;”
In addition to the provision of paid intermediary services, the essential connecting factor here is acting for a football player or a professional football club. The term is therefore broader than that of a traditional player agent, as it also covers intermediary activities for professional football clubs in player transfers.
Football agent vs player adviser
The AMLR definition of a football agent requires “representation” and the provision of intermediary services. In German legal terminology, this refers to legal representation (§§ 164 et seq. German Civil Code). The question therefore arises whether a mere player adviser who does not act as a legal representative for a player or a football club, but only provides advisory services internally, may not fall within the scope of the AMLR’s anti-money laundering obligations.
However, it must be borne in mind that the anti-money laundering classification does not necessarily have to correspond to the civil law classification.
Given the objective of the AMLR to harmonise anti-money laundering prevention across the EU, it is unlikely to make a difference whether an adviser in professional football acts externally as a true representative of a player or professional football club, or merely provides advisory services internally. In most cases, a clear distinction between representative/intermediary activities and purely advisory activities cannot be drawn. In both cases, from an anti-money laundering perspective it must be ensured, for example, that in player transfers involving multi-layered intermediary or pre-financing arrangements by third parties – which are often the subject of a negotiation mandate – the applicable anti-money laundering due diligence obligations are complied with.
Holding companies of professional football clubs or football agents
Finally, it should not be overlooked that where a professional football club or football agent is a subsidiary of another company, the overarching holding or parent company qualifies as an obliged entity under anti-money laundering law as a so-called non-financial mixed activity holding company.
Art. 2 (1) No. 13 AMLR defines this as
“an undertaking, other than a financial holding company or a mixed financial holding company, which is not the subsidiary of another undertaking, the subsidiaries of which include at least one obliged entity as referred to in Article 3, point (3);”
Under this new provision of the AMLR, holding companies will in future be classified as independent obliged entities where at least one group company is an obliged entity from the non-financial sector under anti-money laundering law.
[1] See, for example, the article on this in ‘ZEIT’, No. 03/2026, „Auf dem Sprung nach Europa. Die US-amerikanische Basketballliga NBA verdient mit dem Verkauf von Fernsehrechten Milliarden. Nun will sie auch jenseits des Atlantiks einen eigenen Wettbewerb aufbauen. Doch nicht alle Profiklubs sind begeistert.“, available at https://www.zeit.de/2026/03/nba-europa-basketball-liga-expansion-fernsehrechte.
[2] See information from the DFL on the Virtual Bundesliga, available at https://www.dfl.de/de/hintergrund/efootball/virtual-bundesliga/
