France: Fighting Money Laundering in Football
By Dr Estelle Ivanova, Attorney at Law, Paris, France
The football sector has long been recognised as particularly vulnerable to money laundering due to the considerable financial flows generated by club acquisitions, player transfers, sponsorship agreements and other cross-border commercial transactions.
The international nature of the game, combined with increasingly sophisticated ownership structures and the involvement of multiple intermediaries, creates opportunities for the concealment of illicit funds.
Against this background, France has developed a robust system of financial oversight for professional football, which will soon be complemented by a new European anti-money laundering (AML) framework extending specific compliance obligations to professional football clubs and football agents.
At the national level, financial oversight is primarily exercised through the Direction Nationale du Contrôle de Gestion (DNCG), the independent financial regulator operating within the framework of the Ligue de Football Professionnel (LFP).
Although the DNCG is not an anti-money laundering authority in the strict legal sense, it plays a significant preventive role by promoting financial transparency and safeguarding the economic integrity of professional football. Through its financial supervision, the DNCG reviews football club budgets, payrolls, transfer operations and financing arrangements to ensure that clubs remain financially viable and that their resources are properly documented.
Where financial irregularities are identified, the DNCG may impose a range of sporting and financial sanctions, including transfer restrictions, salary controls or administrative relegation. This system of financial governance contributes to reducing the risk that professional football may be used to introduce illicit funds into the legitimate economy.
The broader fight against money laundering in France is supported by the national anti-money laundering framework, including TRACFIN, France's Financial Intelligence Unit, which receives and analyses suspicious transaction reports and contributes to the detection of financial crime.
Criminal investigations involving suspected financial offences within professional football may also fall within the jurisdiction of the Parquet National Financier (PNF), reflecting the growing attention paid by French authorities to complex financial transactions involving the sports sector.
Alongside these domestic mechanisms, the European Union (EU) has introduced a major legislative reform through the Anti-Money Laundering Package adopted in June 2024. The package is built around three complementary instruments: Regulation (EU) 2024/1624 (AMLR), Directive (EU) 2024/1640 (AMLD6) and Regulation (EU) 2024/1620 establishing the new Anti-Money Laundering Authority (AMLA). Unlike previous anti-money laundering directives, the AML Regulation establishes a directly applicable "single rulebook", ensuring greater consistency and harmonisation of anti-money laundering obligations throughout the EU.
One of the most significant innovations introduced by Regulation (EU) 2024/1624 is the inclusion, for the first time at European level, of professional football clubs and football agents within the scope of the EU anti-money laundering framework. The Regulation defines both "professional football clubs" and "football agents" (Article 2(52) and (53)) and classifies football agents as “obliged entities”, whilst professional football clubs become subject to anti-money laundering obligations in relation to specific categories of transactions, namely those involving investors, sponsors, football agents or other intermediaries, and player transfers (Article 3(3)(n) and (o)).
As recognised in Recital 24 of Regulation (EU) 2024/1624, this legislative choice reflects the particular exposure of professional football to money laundering risks arising from the global popularity of the sport; the considerable financial flows involved; the prevalence of cross-border transactions; and, in some cases, opaque ownership structures.
From 10 July 2029, professional football clubs will, therefore, be required to implement comprehensive anti-money laundering compliance programmes. These obligations will include adopting a risk-based anti-money laundering policy; conducting customer due diligence (CDD) on investors, sponsors, commercial partners, intermediaries and other counterparties; identifying and verifying beneficial ownership; monitoring business relationships and transactions on an ongoing basis; reporting suspicious transactions to the competent authorities where appropriate; and complying with the EU-wide €10,000 limit on cash payments, without prejudice to lower thresholds that may be adopted by Member States.
To comply with these obligations, clubs will also need to establish appropriate internal governance arrangements; designate a person responsible for anti-money laundering compliance; implement effective internal control mechanisms; and provide adequate training for staff exposed to money laundering risks. In parallel, football agents, who are already subject to anti-money laundering obligations under French law, will also be required to comply with the harmonised EU framework.
These developments represent a significant evolution in the governance of professional football. Financial supervision will no longer focus solely on ensuring the economic sustainability of clubs but will increasingly encompass broader compliance obligations designed to enhance transparency; strengthen investor confidence; and reduce opportunities for financial crime. Clubs will be expected not only to demonstrate sound financial management but also to integrate anti-money laundering compliance into their corporate governance and day-to-day operations.
The forthcoming implementation of the EU anti-money laundering legal framework marks an important step in strengthening the integrity of professional football. By combining the established system of financial supervision in France, with harmonised European compliance standards, the new framework is intended to enhance transparency, accountability and resilience against increasingly sophisticated forms of financial crime. In an era of growing international investment and complex cross-border transactions, robust anti-money laundering compliance has become an essential component of good governance throughout the professional football sector.
The phased implementation until 10 July 2029 provides professional football clubs and football agents with a valuable transition period to develop robust compliance frameworks before the new obligations become fully applicable.
More importantly, the new AML framework is not intended to remain static. It provides for periodic reviews of its application, requiring the European Commission to assess, inter alia, whether the threshold for identifying beneficial ownership should be lowered and whether the EU-wide €10,000 limit on cash payments should be adjusted in light of practical experience.
Dr Estelle Ivanova may be contacted by e-mail at ‘
