Anti-money laundering set to enter football. Szego (AMLA): «Get ready: the market must be clean» | OneFootball

Interview by Jacopo Carmassi, Principal Economist at the European Central Bank and expert in economic and financial matters in football. This interview was conducted on personal capacity only and does not implicate in any way the European Central Bank nor any other entity to which the author is affiliated.

European football is officially entering the scope of anti-money laundering rules. With the new regulatory package approved in 2024, the European Union has established AMLA (the Anti-Money Laundering Authority, based in Frankfurt, Germany) and launched a process that will bring professional clubs and agents under AML obligations from July 2029. A change set to impact governance, ownership and operations across the sector. We spoke with Bruna Szego, Chair of AMLA, to understand what the concrete implications will be for football and how the system will need to prepare in the coming years.

Bruna Szego, Italian legal and financial expert, became the first Chair of the EU Anti-Money Laundering Authority in 2025. She previously led anti-money-laundering regulation and supervision at the Bank of Italy, bringing decades of regulatory and international experience.

Bruna Szego, presidentessa dell’Autorità UE per l’Antiriciclaggio

The AML reform: a unified European system takes shape

Question. Good morning, Chair Szego. Thank you very much for agreeing to give this interview on anti-money laundering and football. Let us start with a question on the package of EU rules on anti-money laundering and countering the financing of terrorism adopted in 2024: that package established AMLA (the Anti-Money Laundering Authority) and will bring professional football clubs and football agents within the scope of the new anti-money laundering rules from July 2029. What will be AMLA’s main tasks in relation to the football sector, and how is the Authority preparing?

Answer. «The 2024 anti-money laundering package introduces significant changes. It moves away from a system built on directives, which require national transposition and therefore produce slightly different rules across the European Union, creating fragmented supervision with 27 different approaches. Instead, we are building a unified system, characterised by EU regulations and AMLA with a defined set of tasks. One of the sectors most affected by these changes is the non-financial sector, which covers a broad and diverse range of “obliged entities” that must apply anti-money laundering controls to their clients. Some have been under the AML umbrella for a long time, such as lawyers, notaries, auditors, accountants, and real estate agents. Others are now entering the framework for the first time, including professional football clubs and football agents, who will be subject to compliance with the AML package from 10 July 2029. This is a sector very different from others, but there are, in my view, good reasons for its inclusion». 

«On AMLA’s role: our fundamental task is to lead the European Union towards a unified system. We have regulatory responsibilities – in addition to the rules already contained in the EU directive and regulations, AMLA has secondary regulatory powers aimed at ensuring that the rules are genuinely uniform. We will prepare around 40 regulatory products comprising regulatory technical standards, which are then formally issued by the European Commission, and guidelines. Approximately half will be issued this year and the remaining half by July 2027. These rules apply to all obliged entities in both the financial and non-financial sectors, including football clubs. AMLA’s first objective is therefore to create uniform rules. The second objective is to ensure that supervision is carried out consistently».

«This does not mean that oversight of banks and football clubs must look the same. It means ensuring that within the European Union, supervision of each sector under the AML umbrella is carried out in a robust and uniform manner. Currently that is not the case, and significant differences are visible. The same applies to national Financial Intelligence Units (FIUs), which currently have different working methods and resources, and whose setup varies considerably from one country to another. Through its oversight of national authorities, AMLA will ensure that supervision remains consistent and operates on a level playing field throughout the EU, regardless of the Member State in which an obliged entity is established. To this end, AMLA has been assigned a series of tasks and powers, including conducting peer reviews of national authorities and the possibility of promoting enforcement actions where a national authority does not act in accordance with the requirements of the AML package».

«AMLA will not directly supervise football clubs. The Authority does not have direct supervisory powers over the non-financial sector; those powers will be exercised only over 40 selected financial institutions. In the non-financial sector, AMLA’s role is therefore somewhat more removed compared to the financial sector. Our task is to direct, support, and evaluate the work of national supervisors. One of the things we are beginning to work on is the methodology that national authorities will use to carry out this work and, above all, how they will assess the relative risk level of the obliged entities under their jurisdiction. The methodology we are developing will be more sophisticated for the financial sector and less so for the non-financial sector, reflecting our commitment to proportionality and a risk-based approach. For the non-financial sector, we are developing an initial methodology that will be differentiated by sector, including a dedicated methodology for football. We will start at a basic level and build on it in subsequent years».

Why football is entering the anti-money laundering radar

Q. Football was not included in the European Commission’s original legislative proposal but was added in the final package adopted in 2024. What was the rationale for this choice and why should we care about football when we talk about anti-money laundering?

A. «This is a very interesting question which I am glad to answer. As you noted, football was not part of the Commission’s initial package and was subsequently included at the request of the European Parliament. EU legislative procedures involve the Commission, Parliament, and Council. There was a strong conviction within the European Parliament that the football sector carried significant money laundering risks, for a number of reasons: the global popularity of the sport; the considerable sums involved, with very substantial cash flows and financial interests; the prevalence of cross-border transactions; and the fact that the corporate structures of football clubs, or of their investors, are not always transparent. Taken together, these factors expose football to significant money laundering risks. A few figures illustrate how football has become a global industry: according to some estimates, the global football market was worth USD 56 billion in 2024, with growth prospects of up to USD 70 billion by 2030, with approximately two thirds of those amounts deriving from the European football market. Media, sponsors, and ticket sales alone were worth USD 38 billion in 2024».

Q. And the economic and financial figures of football have increased exponentially over recent decades…

A. «Certainly. It is clear that football has grown into something of fundamental importance, not only in terms of overall size but also in terms of the sheer volume of money flowing through the sport. And when you look at other sports, football truly stands apart: even the second largest sport by economic value operates at a scale significantly below that of football».

Q. With the exception of US sports…

A. «Which are, however, almost exclusively American, without a meaningful transnational dimension. Returning to the topic of popularity: 51% of the world’s population follows football, approximately 4 billion people, and when it comes to the World Cup that figure rises to approximately 5 billion. So, there is not only commercial importance here, but also a significant social influence that football exerts. This creates attractive conditions for those who wish to launder illicit proceed. Criminals may be drawn to football not only for financial reasons, but also because association with prestigious and popular clubs, or with famous players, can confer social status and provide access to influential networks. This perception of football’s importance for anti-money laundering purposes is confirmed by several specific analyses. A 2020 Europol report on organised crime and corruption in sport identified football as the sport most targeted by criminal organisations in the EU. The same finding emerged from a 2018 European Commission study, which also highlighted that one of the problems is the lack of uniform regulation on the financial statements of football clubs, making financial reporting and its transparency a genuine concern».

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How the rules are changing: controls on clients, transactions and ownership

Q. Which are the most significant changes introduced by the AML package that the football sector will have to deal with, and how will these changes bring improvements in terms of prevention and the fight against money laundering?

A. «The fact that football clubs and agents are now subject to anti-money laundering rules means that these entities will have to apply AML controls to their customers or to the transactions identified in the regulation».

Q. And is this not already the case today, at national level?

A. «For some countries, this is not something new. Belgium, for example, has been regulating football clubs for AML purposes since July 2020, having extended its preventive AML legislation to professional clubs, football agents, and the Belgian football federation. Italy has introduced a number of requirements that go in a similar direction; for instance, regarding ownership transparency, including fit and proper tests for club owners. However, the European market is highly diverse. The new European rules will create a level playing field among professional clubs in the EU, eliminating the disadvantages associated with the current patchwork of national approaches. And what does it mean in practice to apply anti-money laundering controls to one’s customers or to the transactions identified in the regulation? It essentially means subjecting clients to customer due diligence or to transaction monitoring, depending on whether it is an occasional transaction or an ongoing business relationship. In substance, it is about understanding who the client really is: whether it is the person you are dealing with directly, or whether there is someone behind them, the so-called beneficial owner. You need to understand who they are and, above all, where the money is coming from. How this helps prevent money laundering is fairly intuitive».

Financially fragile clubs and opaque capital: the sustainability challenge

Q. For football clubs, the rules provide that only certain types of transactions are subject to these requirements (with investors, sponsors, agents, and transfer market transactions). How was this scope of application decided, and how will ownership controls be strengthened? (A sensitive matter, given that clubs, fans, and cities have at times been left exposed when owners walk away…)

A. «The rules target the main channels through which money laundering most frequently occurs in the football sector: ownership structures, the player transfer market, and sponsorship agreements. We have already discussed the inherent risks of the football market, but why the focus on these specific areas? Let us start with investors. The corporate structures employed in football are highly diverse and can be extremely complex, making it difficult to understand who the ultimate investor is, who the beneficial owner is, and what funds are being used. This is especially true when transactions are cross-border, as is the case in the majority of acquisitions of stakes in football clubs. On the investor side, you may be dealing with companies whose ownership is not straightforward to determine, particularly where corporate structures are layered, or with high-net-worth individuals. Understanding who the ultimate investor is and what funds they are using is absolutely fundamental. The clubs themselves can take different legal forms, which means that their governance is subject to widely varying rules in terms of oversight and ownership transparency. Another aspect is important to consider from a risk perspective».

«Despite the enormous growth of the football market, many clubs continue to experience financial difficulty. This is probably linked to the way the sector works: major clubs require massive sums to compete and sign the best players, creating a self-reinforcing dynamic. Football is sometimes described as a market in which a small number of clubs capture most of the value while others face constant financial pressure. From an anti-money laundering perspective, this means that some clubs could be tempted to accept funds without looking too carefully at where they come from».

i conti dei top club europei

Dalla Premier alla Serie A, tutti i conti dei top campionati d’Europa a confronto: ricavi a 26 miliardi ma cresce il rosso I ricavi crescono del 5%, ma costi e ammortamenti spingono le perdite a 1,5 miliardi: solo la Bundesliga chiude in utile.

«As for the transfer market: the world of player transfers has become highly international, with players regularly moving across national borders. Payments are often complex, covering portions for the player, the agent, and the club, as well as immediate and deferred payments, bonuses, and fringe benefits. These many different types of payments create risks in terms of monitoring these transactions, their origin, and the reasons for which they are made. An additional risk is the pricing of players: what is a fair transfer value? What is the benchmark? The answer is not straightforward. Values are highly unpredictable, can be inflated, and can be used to disguise transfers of wealth that have no legitimate justification. Finally, on relations with sponsors: the sponsorship market is enormous and growing. A significant portion of club revenues derives from sponsorships, and this, combined with the financial fragility of many clubs, creates the risk of economic dependence on sponsors. Proper checks on sponsors and on the origin of the funds they bring are therefore essential».

Q. One could argue that resolving the issue of economic and financial sustainability would also be key to limiting money laundering risks. Would you agree?

A. «Definitely. The more financially fragile a club is, the more exposed it becomes to the risk of an acquisition or investment involving non-transparent money, simply because the pressure to accept any funding can make it harder to ask the right questions».

Q. You spoke about risk, referring to the issue of corporate structures. What other factors will AMLA consider for football clubs in its risk-based approach?

A. «I would like to recall that the risk-based approach means two things. First, it means having sufficiently flexible regulation that allows measures to be calibrated on the basis of risk, with more stringent requirements for larger and/or riskier entities, bearing in mind that risk does not always correlate with size. There will be a system of analysis by the football supervisory authorities, which will need to be established, because the directive requires that for all sectors subject to anti-money laundering rules, including non-financial sectors, supervisory authorities must exist and must be equipped with the full range of traditional supervisory powers: information-gathering, monitoring, and enforcement. The way in which these authorities carry out their tasks will be supported by the risk assessment system that AMLA is preparing together with national experts, including experts from the world of football. Second, the risk-based approach means that obliged entities themselves, including football clubs, must understand the relative risk level of their clients and apply more or less intrusive controls accordingly. They must equip themselves with procedures and systems capable of assessing the varying risk levels of their clients. There are therefore two dimensions: a more public one, concerning how the supervisory system is structured on the basis of the risk-based approach, and one that concerns the obliged entities directly, that is, how football clubs themselves must apply this approach in practice. Applying highly sophisticated controls where the client’s risk level is low makes little sense. Where the risk level is higher, more robust controls are clearly necessary».

Q. What will AMLA do to ensure a level playing field within the European Union? Let us take a specific example: Member States have the option to partially or fully exempt top-division clubs from the new rules if they fall below a given turnover threshold (below EUR 5 million in each of the two preceding years), with a low risk profile and taking into account their scale of operation. Member States may also grant this exemption to clubs in lower divisions that carry a low risk regardless of turnover, taking into account their scale of operation. Furthermore, economic and financial figures can vary significantly between countries: for example, the EUR 5 million threshold is much lower than the turnover of any Italian top division club. What will AMLA do to encourage Member States to follow a substantially consistent approach on this front?

A. «This is also a very important question. We were discussing the risk-based approach, and this is an example of that approach embedded directly in the regulation. The focus is first on top divisions, with the possibility of exempting clubs not only if their annual turnover is below EUR 5 million but also if they are demonstrated to be low-risk entities. There is then the possibility of exempting all other clubs, again on the basis of an assessment covering both their scale of operation and their risk profile. Exemptions are not automatic: national supervisory authorities will conduct this assessment, but they will do so on the basis of the common methodology I referred to earlier. The aim is precisely to ensure that exemptions are granted across the European market using consistent criteria. This assessment will also need to be revisited regularly, since a club that presents no significant risk today could look very different tomorrow».

Q. As you recalled, AMLA will not have direct supervisory tasks over football clubs. Given the growing European dimension of football, is this supervisory architecture the best possible one, or might it be useful in the future to have a stronger European supervisory role, potentially with direct powers for AMLA?

A. «This point was discussed during the negotiations, not specifically in relation to football, but with regard to the different approach taken by AMLA towards the financial sector compared to the non-financial sector. The decision was to assign AMLA direct supervision, from 2028, over a maximum of 40 financial institutions, and at least 40 after 2030. In the current package, AMLA’s role as direct supervisor is therefore provided for only in the financial sector. This is not merely a question of direct versus indirect supervision; it also reflects a broader difference in the scope and intensity of AMLA’s powers across the two sectors, with a more nuanced and less intrusive role in the non-financial sector. On the question whether football clubs could or should in the future be directly supervised by AMLA, I cannot give you an answer. We are still at the beginning, and any response would be premature».

A system based on cooperation between authorities and industry

Q. How will AMLA relate to national authorities, particularly on football-related matters?

A. «I am particularly glad to take this question because it touches on two of my five long-term objectives as AMLA Chair. On cooperation, I always emphasise that AMLA cannot achieve anything on its own. We need strong cooperation with national authorities, strong cooperation with FIUs, and genuine collaboration and dialogue with industry. The private sector is our partner in the fight against money laundering – it is the industry that applies anti-money laundering controls to customers on the ground, and in my view that makes the continued dialogue with the private sector even more important here than in many other areas of regulation. In my first year of Presidenza dell’AMLA (iniziata nel febbraio 2025) I conducted a roadshow across all EU Member States, meeting not only with supervisors from both the financial and non-financial sectors, but also with the most representative industry associations in each country. In some cases, there were also representatives from the football sector, but that was more the exception than the rule. This gave the impression that the football sector may not yet have fully understood that it needs to be ready by 2029. Cooperation with authorities on one side and with industry on the other is fundamental. In practical terms, for all the regulatory packages we discussed earlier, we work through Task Forces, working groups, and internal committees in which national supervisory authorities are represented and make an essential contribution. We could not do this work alone. All our products are subject to public consultation, and industry feedback is important at every stage. More broadly, the entire regulatory framework provides for a continuous exchange of information between AMLA, national supervisory authorities, and the FIUs. The whole system is built on cooperation. This is particularly important given that the AML package was conceived and adopted in the wake of a number of AML/CFT scandals, where insufficient cooperation between national authorities and inadequate information exchange between FIUs were identified as significant weaknesses».

I club di Premier a rischio riciclaggio: lo studio dell'Università di Manchester Strutture esageratamente complesse e poche informazioni sui proprietari con quote di minoranza. Questi i due punti principali messi in evidenza dalla ricerca condotta su tutti i club.

Q. You mentioned that some representatives from the football sector were present in certain cases during the roadshow. Have you so far received feedback and active participation from the football world in the consultations?

A. «At the moment, things are perhaps a little quiet on that front».

Q. What are the main operational changes that clubs must prepare for ahead of July 2029?

A. «Applying the risk-based approach means being prepared and understanding the relative risk level of your clients. First and foremost, clubs need to understand what is required of them as obliged entities: what does customer due diligence mean in practice? What information must be requested? Is this an ongoing business relationship? What does transaction monitoring involve? What internal systems need to be put in place? None of this can be set up overnight. During the roadshow, this was exactly the message I delivered, particularly to the non-financial sector, which is undoubtedly less prepared at this stage than the financial sector. Start preparing now, start talking to your supervisors. This will require time and investment, and early preparation will make a real difference».

Q. And will clubs also need dedicated internal structures, in addition to a manager responsible for compliance, or can these functions be exercised flexibly by other managers or employees?

A. «The risk-based approach applies here as well. We cannot ask small entities to put in place an internal control system designed for a large firm».

Q. And what will happen to clubs in the event of violations of the new rules?

A. «The directive requires that for every sector subject to anti-money laundering rules there must be a supervisory authority equipped with all necessary powers, including the power to sanction and to take enforcement action, a term that goes beyond pecuniary penalties alone. The directive provides for a toolbox that national supervisory authorities will have at their disposal, covering a range from less intrusive to more intrusive measures. These instruments must be deployed on the basis of the entity’s capacity to carry out its duties adequately. The range runs from a simple reprimand to a request for a functional reorganisation plan, and in more serious cases to the application of financial penalties, proportionate on the basis of factors including the gravity of the violation and the company’s turnover».

Q. What is the message you would like to send to the football world ahead of the new rules entering into force in July 2029?

A. «We are counting on you. Your sector matters, and it matters that football is a clean and transparent market. Start preparing now».

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