This article forms part of a joint series by ANNERTON and GRUENGOLD LEGAL on “Professional Football and Anti-Money Laundering Compliance”. The series began in December 2025 with an overview of the “New compliance obligations for professional football clubs and player agents in the EU – An overview” (Part 1). In February 2026, we continued with an analysis of the entities falling within the scope of the new compliance framework for professional football clubs and football agents (Part 2). At the end of March 2026, we examined the specific obligations applicable to professional clubs and football agents (Part 3).
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With the new EU Anti-Money Laundering Regulation (AMLR), professional football will, for the first time, become systematically integrated into the European anti-money laundering framework. In the first three articles of this series, we outlined the regulatory landscape, identified the relevant obliged entities, and discussed the specific compliance requirements.
From 10 July 2029, the AMLR will apply directly to professional football clubs and football agents. Professional football is therefore increasingly coming into the focus of European anti-money laundering efforts.
Anti-money laundering in football is no longer a topic for the distant future. Although the new European requirements for professional football clubs and football agents will not take effect until 10 July 2029, preparations are already underway. At the same time, a recent high-profile case that attracted nationwide attention demonstrates that money laundering risks are already part of the risk landscape for football clubs. This provides ample reason to take a closer look at current developments in this area:
- Money laundering investigations involving a regional football club have attracted nationwide media attention and can cause significant reputational damage.
- In a recent judgment, the Court of Justice of the European Union (CJEU) confirmed that obliged entities themselves may be directly subject to administrative fines for breaches of anti-money laundering requirements.
- The EU Anti-Money Laundering Authority (AMLA) has recently published draft Regulatory Technical Standards (RTS), which will also apply to the non-financial sector and are therefore relevant to the professional football industry.
1. Money Laundering Suspicion Involving a Football Club
Although the AMLR is not yet applicable to professional football clubs, suspected money laundering cases connected to football are already making headlines in the media across Germany.
This demonstrates that awareness of anti-money laundering risks within the football sector is steadily increasing. For example, the Stuttgart Public Prosecutor General’s Office is investigating an incident at Stuttgart Airport in which approximately EUR 215,000 in cash was allegedly seized from members of a football club based in Southern Germany. Criminal investigations on suspicion of money laundering have reportedly been initiated.[1]
At the very latest, professional football clubs and football agents should treat such developments as an opportunity to review their governance structures and align their internal procedures with the forthcoming requirements of the AMLR.
2. CJEU Judgment Emphasises the Direct Liability of Legal Entities for AML Violations – Also Relevant for the Football Sector
By its judgment of 29 January 2026 (case C-291/24), the CJEU reinforced the principle of direct liability of legal entitiies for infringements of anti-money laundering rules.
According to the Court, the imposition of sanctions on a company may no longer depend on a specific natural person first being formally accused or their misconduct having been definitively established.
From a practical perspective, the significance of this ruling extends far beyond the banking and financial sectors. It affects all obliged entities under the European anti-money laundering framework and will therefore also apply to professional football clubs and football agents once they become subject to the AMLR.
The judgment underscores a clear EU-wide trend towards direct corporate accountability, including in the context of administrative sanctions for anti-money laundering breaches.
3. AMLA’s Current Consultation Process Also Affects Professional Football
The public consultations of the EU Anti-Money Laundering Authority (AMLA), headquartered in Frankfurt, are currently in full swing. Among other initiatives, AMLA is consulting on draft guidelines on business-wide risk assessment under Article 10 AMLR. In the future, professional football clubs and football agents will be required to systematically identify and assess the money laundering and terrorist financing risks associated with their business activities. The business-wide risk assessment constitutes the basis of all preventive measures and controls implemented by obliged entities. Particular attention will need to be paid to areas such as player transfers, agent commissions, sponsorship arrangements, investor structures, payment flows and international business relationships. The ongoing consultation process provides stakeholders with an opportunity to ensure that the specific characteristics of the football industry are taken into account at an early stage of the regulatory process. The consultation closes on 15 July 2026.
In addition, on 3 June 2026 AMLA announced a further public consultation on new guidelines on ongoing monitoring of a business relationship. This consultation will remain open until 3 September 2026. These guidelines explain how obliged entities should continuously monitor customer relationships. This includes, in particular, the regular updating of customer information, the ongoing monitoring of transactions and activities, and the identification of unusual or suspicious behavior. The guidelines have been developed pursuant to Article 26(5) AMLR and are intended to provide practical guidance on how the requirements can be implemented in a risk-based and proportionate manner. They will apply to both the financial and non-financial sectors and will therefore also be relevant to professional football clubs and football agents in the future. A public hearing on the draft guidelines is scheduled for 2 July 2026.
From a practical perspective, professional football clubs and football agents should already engage directly—or through their industry associations—in AMLA’s ongoing consultation processes during 2026 and begin adapting their internal procedures. Waiting until 2029 may leave football clubs and football agents facing a regulatory framework that has already been finalised without their input. It is unlikely that there will be a second consultation round specifically dedicated to professional football clubs and football agents, even though the AMLR will apply to these obliged entities only from July 2029 rather than, by way of exception, from July 2027.
[1] See, for example, reporting on the matter by the German news channels tagesschau.de and bild.de.
