Sports Integrity: Anti-Money Laundering and Other Measures
By Athena Constantinou, Managing Director, APC Sports Consulting, Nicosia, Cyprus
Global sports have grown significantly in the last 20 years or so, especially in monetary terms, and are now a multi-billion US dollars industry
This rapid growth has led to increasing opportunities for illicit practices, such as money laundering, match fixing and human trafficking.
Money laundering has evolved immensely in the past few decades, and the sports world, with its relatively low levels of financial regulation, as well as its traditionally non-financially sophisticated nature, has made the industry as a whole and sports clubs, in particular, perfect candidates for these illicit practices.
In the sophisticated times in which we live, the fight to keep sports clean from wide-ranging forms of corruption is an ongoing battle and requires the expertise of professionals.
We have a dedicated sports integrity team comprised of Certified Anti-Money Laundering Specialists, members of ACAMS (Association of Certified Anti-Money Laundering Specialists), who advise clubs and sports stakeholders on the practical application of AML (Anti Money Laundering) legislation to their organizations; prepares relevant policies and procedures; creates and updates AML internal manuals; and trains internal AML Compliance officers.
Specifically, there is a need for the following assistance:
- Assessment and establishment of adequate governance arrangements to ensure effective and prudent management.
- Drafting Clubs’ AML policies and procedures in compliance with the FATF (Financial Action Task Force, the global money laundering and terrorist financing watchdog) 40 Recommendations and the 5th EU AML Directive, depending upon the club’s AML country’s legislation.
- Advice and guidance on how to establish ongoing risk assessment mechanisms and procedures.
- Preparation of due diligence procedures and mechanisms throughout the course of dealings with beneficial owners, executives and third parties in order to manage and mitigate the exposure of clubs to money laundering and the financing of terrorism.
- Setting up record-keeping procedures in relation to due diligence measures, account files and business correspondence, including records of all transactions.
- Provision of training and seminars in connection with the implementation of AML policies and procedures.
FIFA Guidelines Compliance
Many sports governing bodies have set up their own anti-corruption compliance procedures.
Take Association Football, for example, FIFA, its World Governing Body, has recently updated its Compliance Handbook in an effort to support compliance in its member associations and confederations.
Professional advice and assistance is required by these associations and confederations on establishing and implementing integrity programs which adhere to FIFA compliance standards.
Specifically, there is a need for them to have:
- Training and seminars in connection with the contents of the FIFA Compliance Program
- Assistance in setting up compliance teams and creating suitable compliance frameworks and guidelines in connection with such matters as:
- Gifts and Hospitality.
- Anti-bribery and Corruption.
- Conflicts of Interest.
- Reputational Risks.
- Data Protection.
- Raising Concerns.
- Assistance in establishing monitoring procedures to ensure the proper operation of the required compliance systems.
- Providing support and advice for establishing appropriate financial governance models.
With so much money circulating in sports, anti-corruption measures of the kinds mentioned in this Post, not least the anti-money laundering ones, have never been needed so much as at the present time!
The Author, who is a Certified Anti-Money Laundering Specialist and a Certified Public Accountant, may be contacted by e-mail at ‘
