Tackling Dirty Money in Football

For decades, professional football has been beset with allegations of fraud, corruption and money laundering. As billions of pounds (and counting) flow through the game on an annual basis, it has become, in the words of the UK’s National Risk Assessment of Money Laundering and Terrorist Financing 2025, ‘an attractive target for criminals, kleptocrats and other malign actors seeking to launder their criminal funds or generate further illicit gains’.

While the UK’s National Risk Assessment (NRA) may acknowledge the nexus between professional football and illicit finance, the EU has gone one step further, bringing high-level professional football clubs, football agents and European football associations into the scope of the EU’s Anti-Money Laundering (AML) framework from 2029 onwards. The inclusion, for the first time, of football clubs and agents within the scope of the UK’s NRA therefore raises the question of whether the UK should follow the EU’s example and bring football within the scope of the Money Laundering Regulations (MLRs).

To answer this question, the Centre for Finance and Security at RUSI convened a virtual roundtable in September 2025 to discuss how football clubs, players and agents are vulnerable to money laundering and the benefit of any potential regulatory response. Participants were drawn from the public sector, the private sector, academia and civil society and included those with first-hand experience of issues relating to money laundering, financial crime and compliance within professional sports.

Methodology

This paper is based on a review of relevant policy literature and unattributable contributions of participants in the roundtable. The paper sets out the main themes of the roundtable discussions without identifying comments made by any specific participants. Unless otherwise indicated, statements in this paper reflect points raised during the discussions.

The paper starts by discussing the ways in which clubs, players and agents can be used to generate and/or launder illicit funds. It then provides a summary of the key structural deficiencies identified in the roundtable and, finally, turns to the question of the response, including the potential role of AML regulation.

The Nature of the Threat: Football Clubs, Players and Agents

As the UK’s NRA identifies, there are many ways in which elements of ‘the beautiful game’ can be exploited by criminals and bad actors.

Given their enormous wealth, the UK’s top clubs have long been a favourite among the investment portfolios of the world’s ‘super-rich’, a category encompassing US billionaires, Russian kleptocrats and Middle Eastern royals. Fans may often welcome the injection of cash into the game without wanting to ask too many questions about the source of the funds; however, several high-profile cases have demonstrated how some football clubs have provided a home for tainted funds. The purchase of Chelsea FC by Roman Abramovich – alleged to have made his fortune through questionable business dealings and subsequently sanctioned following Russia’s full-scale invasion of Ukraine – and the links between Everton FC and Alisher Usmanov, another Russian oligarch sanctioned in 2022, reflect this troubling pattern.

Football clubs can also be a means of generating illicit profits. In January 2025, five men, including the former chairman of Northampton Town FC, were charged with fraud and money laundering offences. Allegations came to light following the discovery of a scheme in which the men fraudulently profited from money lent with the intention of developing the town’s Sixfields Stadium; they were, in fact, diverting the funds into personal property investments. Similarly, Italian prosecutors have been investigating the recent sale of Milan’s San Siro Stadium, suspected of forming part of a broader urban planning corruption network, which allegedly generated bribes and illicit commissions for some 75 individuals, including the city’s mayor.

Clubs in lower leagues have repeatedly fallen victim to dubious characters who have abused their position for personal gain. When trying to sell Reading FC, following years of fans’ public outcry over his mismanagement, former owner Dai Yongge was revealed to have secured a £50-million loan from a Chinese bank using the club’s stadium as collateral. More directly, some senior managers have misappropriated club funds, as is alleged in the ongoing investigation into Daniel Johnson, a co-owner and director of Hull City Ladies FC.

Fraudsters, too, have found ample opportunity to generate wealth through ticket fraud, thereby weaponising fans’ passion to extract millions of pounds. While reselling tickets in the UK does technically need to occur via exchange on official channels, touting is still alive and well, and accessing second-hand tickets via the black market online remains remarkably easy. Crooks have taken advantage of the explosion in online ticket advertising to defraud some 12,000 fans out of £2.5 million in the last two years alone, with fans from Liverpool FC most often targeted, followed by supporters of Arsenal FC, Manchester United FC, Chelsea FC and Manchester City FC.

Participants at the roundtable pointed out that most professional players begin their careers at a very young age, at which stage they are unlikely to have received any financial education. For a talented few, the salaries are astonishingly high, and many will reasonably opt to outsource the management of their wealth to better-equipped third parties. As a result, however, it is not uncommon for several people to have access to a single player’s bank account, thus creating multiple entry points for exploitation by those looking to launder or steal funds. Vulnerable players, spanning the young players living away from home for the first time to former players struggling with mental health or addiction issues, can also be exploited by organised crime groups.

For example, James Keatings, a former professional football player in Scotland, was found guilty of money laundering offences and was jailed for 13½ months after being discovered with two boxes containing nearly £400,000 in criminal cash. Keatings has been linked to a multi-billion-pound Russian-speaking money laundering network, operating across the UK. The network has been connected to Russian espionage activities, the funding of electoral interference in Moldova and the Russian military–industrial complex. Similarly, the explosive story of Dutch ex-English Premier League (EPL) defender Ronnie Stam, sentenced to seven years last August for his role in an international drug smuggling ring, is indicative of this trend.

However, while post-career recruitment represents one pathway, organised criminals also exploit footballers during their playing years through an alternative method: match-fixing, the practice of paying off players to produce a certain outcome. In the UK, several high-profile convictions and accusations relating to this crime have come to light in recent years.

Another topic of discussion was the web of agents and intermediaries in the game’s orbit. Participants referenced Al Jazeera’s 2021 documentary The Men Who Sell Football at several points during the roundtable discussions as a primer on the tactics used by professional enablers, catering to those looking to hide their identities and money in the football industry.

More specifically, football agents were singled out as potentially high risk, both by participants and the NRA, given their central role in facilitating the lucrative and opaque business surrounding players transfers and image rights. Given the enormous sums and relative lack of oversight, it is perhaps little wonder that scandals abound. For example, in 2020, Spanish authorities charged influential agent Fali Ramadani and his associate with money laundering offences, following the discovery of a scheme that routed player transfers to clubs through shell clubs to inflate prices, concealing €10 million in untaxed profits.

Additionally, the lack of regulation has created vulnerabilities that can be exploited for money laundering. For example, agents can represent multiple parties and inflate their service fees, perhaps most infamously exemplified by the case of agent to the stars Mino Raiola. Raiola represented all three parties in the transfer of Paul Pogba from Juventus FC to Manchester United FC, and reportedly pocketed £41 million from the record-breaking £81-million deal, one of many transfers which eventually sparked an investigation by the Dutch tax authorities. While Raiola was never convicted of any wrongdoing before his death in 2022, the case opened against him demonstrates the structural opacity in which agents operate, which allows for the obfuscation of funds and inflation of service fees as a potential mechanism through which illicit money can be moved in the football transfer system.

While there is certainly scope for individual agents to take advantage, the deviance of intermediaries has also manifested at the highest levels of the sport, with FIFA executives having themselves been implicated in several high-profile corruption, bribery and money laundering scandals in the last decade.

Identifying the Structural Vulnerabilities in the Game

Given football’s global reach and enormous financial flows, some exposure to illicit finance is inevitable; however, participants identified a number of specific vulnerabilities in the structure of the game which allow for its exploitation.

Complex and Opaque Corporate Structures

One of the vulnerabilities most often cited by participants was the ubiquity of opaque corporate structures which make the game an attractive investment opportunity for those looking for a place to park their illicit wealth. One participant presented a diagram representing the web of ownership surrounding an EPL club, demonstrating the multiple layers and complex structures. One example, a 2024 study by the University of Manchester, revealed the widespread use of complex corporate structures and offshore secrecy jurisdictions in the ownership structures of EPL clubs.

While not necessarily an indication of wrongdoing, such arrangements can facilitate the concealment of dirty money in several ways. First, they serve to create layers of confusion which make determining beneficial owners a huge investigative challenge. Most clubs’ stakeholders are almost certainly ‘fit and proper’; however, there is a minority who would fail compliance checks in regulated industries and take advantage of the widespread use of proxies to invest in the game.

Concentrating efforts on encouraging greater transparency about beneficial ownership could serve as a serious deterrent for criminal actors while simultaneously providing law enforcement with better-quality data for investigations. However, there is a considerable risk that adopting a more hardline stance on transparency could result in a level of capital flight that could induce financial shock in some leagues.

Weak Oversight and Lack of Robust Governance Structures

A huge part of football’s attraction to fans and investors is its supranational quality. In the EPL, foreign-born players make up the lion’s share of teams, half of which are owned by Americans. However, its strength of appeal is simultaneously its weakness when it comes to dirty money. Because so much of football’s business is conducted across borders, the lack of consistent regulatory standards and practically non-existent oversight leaves the goal open to bad actors in several ways.

As participants noted, football’s rise to global domination was an organic process, and the various bodies tasked with the game’s regulation are there due to accretion rather than design. While many organisations are tasked with some degree of governance, FIFA has become the de-facto self-ordained global referee of the game. However, the constellation of internally produced ‘FIFAgate’ scandals indicate the consequences of totally unsupervised and unquestioned self-regulation.

FIFA has improved somewhat since 2015, attempting to improve its oversight of agents and transfers and enacting a wave of self-regulatory reforms. These include overhauling its model of governance and establishing a ‘FIFA Clearing House’ (FCH) to make the transfer process more transparent.

In addition, FIFA has enacted reforms aimed at addressing the concerns surrounding the opacity of agents’ activities, attempting to introduce FIFA Football Agent Regulations (FFARs) in October of 2023, which set out several provisions to improve transparency, including the establishment of disclosure and reporting requirements and a cap on agents’ fees. However, these reforms have since been struck down in courts across Europe for violating competition law, and, following an injunction issued by the District Court of Dortmund, Germany, FIFA opted to suspend the contested reforms across the board in the interest of fairness.

Moreover, FIFA’s internal governance improvements, implemented under the auspices of intense public pressure, are increasingly at risk of being rolled back. Given continued accusations of patronage and operational opacity, the authenticity of FIFA’s post-exposé progress should be called into question. If the organisation has – as some detractors argue – failed to substantively change its way of working, the sport remains just as vulnerable to the same corrupt actors the hard-fought internal reforms purported to immunise the game against (in the absence of credible external oversight mechanisms).

The Inherent Loss-Making Nature of Football

Financial precarity alters the incentives of any organisation, and despite the enormous revenue that top-tier leagues generate, football is, by and large, a loss-making business. This was an important point that a number of participants of the roundtable felt was crucial in terms of understanding the business of the game and the nature of some of the vulnerabilities. Analysis carried out by Fair Game, England's leading football think tank, determined that nearly half of England’s football clubs in the top four divisions have less than one month’s cash in reserve to cover their operating costs. Most UK football clubs simply cannot afford to turn away dirty money, and the lack of supervision makes accepting it a low-risk, high-reward decision.

As participants noted, this is particularly relevant in the lower-tier clubs, which may be even more cash-strapped than those in the top tiers. This means that they are more likely to accept questionable funds out of necessity: research shows that the poorer the league, the more likely it is to advertise illegal betting companies. Participants in the roundtable also noted examples of how clubs in dire financial situations may be actively targeted by criminal actors who sense their desperation and recognise football’s opaque business model as a haven for laundering ill-gotten gains. Such was the case in Portugal, where Latin America’s largest drug gang, the Primeiro Comando da Capital, was found to have targeted three desperate third-division clubs, offering much-needed cash injections to launder the proceeds of their drug trafficking empire.

Several participants with experience of dealing with clubs and/or players in a professional capacity highlighted the players’ relative lack of understanding of risks and the immaturity of many of the financial processes in place in clubs. The lack of financial literacy among clubs and footballers creates a significant vulnerability.

The Centrality of Cross-Border Transactions

Cross-border transactions are the lifeblood of football’s business model. However, in their current configuration, the combination of complex international money flows and practically non-existent oversight has left the sport unduly exposed to dirty money. As outlined above, criminals have frequently found opportunities to conceal their ill-gotten gains under the auspices of licit international football-related transactions.

One of the largest transaction categories singled out by participants was the transfer of players, which is an enormously valuable and highly subjective market. The global market for player transfers hit an all-time high in the last trading window (over the Summer of 2025), and are a key source of income for clubs. However, the lack of controls or structure in such transactions means the market is ripe for abuse. As noted by one participant, ‘players are like wine; you can make the value up’. The FCH aimed to bring structure and greater transparency to the international transfer process, and while this is a move in the right direction, it is not without faults. Most importantly, the FCH fails to account for the vulnerabilities resulting from the inherent subjectivity in player valuations.

Lack of Intelligence

Roundtable participants repeatedly emphasised the need to better understand the scale of dirty money in football. Currently, there is no centralised reporting mechanism, and the burden of investigating potential financial misconduct falls on local law enforcement and financial intelligence units (FIUs), operating in isolation from the broader system and with only a small piece of the greater puzzle.

The decentralised system does not match the international nature of the game and has effectively created an information vacuum whereby maintaining oversight of cross-border payments, third-party ownership arrangements and agent fees is practically impossible for competent authorities. In essence, despite being themselves players in an international multi-billion-pound industry, clubs and agents operate with far less financial transparency than firms and workers in, for example, the high-street banking sector.

While FIFA did try to narrowly expand its financial oversight function with the establishment of the FCH and FFARs, the remit of these reforms is too narrow and fails to address the burning question: should FIFA continue to be its own referee? Although many participants cited the information asymmetries exploited by bad actors as central to football’s dirty money problem, there was no consensus on the best path forward to counter this problem.

Responding to the Risks

To open the discussion on potential regulatory responses, a representative from the European Commission gave an overview of the approach to regulating football in the latest AML package. One of the first issues that the Commission faced was the definition of what constitutes a ‘customer’, for the purposes of the regulations. The global AML framework is predicated on the importance of knowing who you, as a regulated entity, are doing business with (also known as ‘Know Your Customer, or KYC checks) and monitoring that customer for any unusual activity. Applying this framework to football clubs, however, is less conceptually clear. The EU’s approach has, therefore, been to move away from a customer-centric approach to AML obligations to one that focuses on higher-risk transactions; therefore, professional clubs only fall within the scope of AML regulations for specific types of activities, including: transactions with investors; transactions with sponsors; transactions with football agents or other intermediaries; and player transfers.

This approach begs the broader question, raised by one participant, of whether a more transaction-centric view of AML risks could be relevant to other parts of the regulated sector, such as the legal and accountancy sector, where the challenge of applying a regime originally designed for financial services has long been an issue.

It should be noted that the EU regime does allow for some flexibility to minimise any disproportionate impact on smaller clubs. The EU allows member states to exempt clubs outside the highest division of football and/or those within the highest division but with an annual turnover of less than €5 million for each of the previous two years, from the requirements if the money laundering and terrorist financing risk is assessed to be low.

It is not yet clear how member states will look to use this exemption, and given that the EU’s requirements do not come into force until July 2029, it will be a while before there is any data to assess the effectiveness of the proposed measures. Several participants referenced the example of Belgium, which brought clubs, agents and the Royal Belgian Football Association (RBFA), into the scope of its national AML framework in July 2020. This followed what was known as Operation Clean Hands (or Operation Zero), a widespread investigation into organised crime, fraud, money laundering, tax evasion and corruption in Belgian professional football. Nearly 60 individuals, including referees, club officials, coaches and agents, as well as a number of top-flight clubs, were implicated in the investigation, which is ongoing.

One participant noted that a number of suspicious transaction reports had been filed to the Belgian FIU by football clubs and the RBFA, providing intelligence to law enforcement on potential criminal activity. While Belgium is seen to be leading the way when it comes to regulating football for AML purposes, there was no consensus in the roundtable discussions as to whether it has had the intended impact. It is also worth noting that the Belgian AML regulations do not yet apply to football agents.

Having gained an understanding of the approach taken by the EU, the discussion then turned to the question of the objectives of the AML regime: to keep bad actors out of the system, to identify unusual or suspicious activity and to provide intelligence to law enforcement. Overlaid with this framing was a question raised by several participants: what is the exact nature of the problem with football that we are trying to solve?

From the perspective of a number of participants, there was not enough overlap between the objectives of the MLRs and the way in which dirty money manifests in football for extension of the MLRs to be the appropriate response. As noted by several experts in AML regulation, football clubs are not able to act as gatekeepers to the financial system – one of the key purposes of the AML regime – which calls for an alternative way to tackle the issue. Another point raised by participants was the fact that regulated professionals – such as lawyers, accountants or bankers – would be involved in many football-related transactions (although it was noted that in-house lawyers are not in scope of the MLRs). On the other hand, participants who were in support of extending the MLRs to football clubs felt that it had benefits in terms of providing a broader range of investigative and enforcement tools and would require clubs, in particular, to improve their record-keeping.

While most of the discussions were focused on the application of the MLRs to football clubs, the question of whether football agents should be within the scope of the MLRs is slightly different. As for football agents, the authors argue that they should be treated in the same way as other dealers in high-value goods, such as those in the art market. This is because of some of the inherent similarities between agents and dealers, such as subjective valuations and the potential for facilitating significant cross-border financial flows.

Ultimately, there was no consensus as to whether applying AML obligations to football was the right approach, although the majority did not seem to be in favour. At the same time, it was universally agreed that some form of regulation – proportionate, appropriate to the risks and designed to allow the game to flourish – was desirable, if not essential. The new Independent Football Regulator in the UK has a daunting challenge and there was concern from some participants that it did not have the resources, capacity or expertise to really tackle the issue of dirty money in football. It remains to be seen whether the EU’s experiment with applying AML regulations to the football sector will clean up football. While there are no easy solutions, participants were united in the fact that something does need to change to stem the flow of dirty money into the beautiful game.