Money laundering in professional football - current developments

German money laundering legislation already imposes obligations on a large part of the financial sector, such as banks, payment service providers and FinTechs. However, the risks of money laundering are also becoming increasingly present outside the financial sector. As a result, the legal professions, goods traders and estate agents are already among the obliged parties. Football clubs and player consultants are not yet included.

However, the risk potential for money laundering in professional football is significant. This is due, among other things, to the enormous sums of money involved in sponsorship, transfer fees and investments. As early as 2009, the FATF cited the complicated networks, different financial channels and the large number of people involved as factors that make professional football susceptible to being misused for money laundering purposes.

Current suspicion of money laundering in connection with FC Bayern Munich

A recent case involving FC Bayern Munich shows that such risks can actually materialise. The billionaire Alisher Usmanov is suspected of having illegally moved money from criminal offences amounting to several million euros. Following Russia's invasion of Ukraine, Usmanov became a sanctioned person and his EU assets were frozen. He is now suspected of having rented a box in the club's stadium, the Allianz Arena, for more than 250,000 euros with the help of a letterbox company. Investigators from the Federal and State Criminal Police Office hoped to find evidence in this case in the rooms of the football club's headquarters and in the stadium when they searched them at the end of April 2023. FC Bayern Munich itself is not listed as a defendant, but as a witness in the proceedings.

No money laundering rules for professional football clubs in Germany to date

Bremen had already pursued a motion in the Bundesrat in 2022 that would have made professional football clubs in the first, second and third leagues and player consultants companies subject to money laundering obligations. However, the motion failed in October 2022.

New developments at European level

The European Council had already published its proposal in December 2022, which states that professional football clubs should also be included in the group of obliged entities in future. The European Parliament took up this proposal in its position in April 2023. According to the Parliament's wishes, professional football clubs in the first and second leagues (with a turnover of at least EUR 7 million per year), match consultants and national football associations (in Germany, the German Football Association "DFB") should comply with the obligations of money laundering law in future. The regulation is currently undergoing crucial negotiations - the outcome is uncertain. It therefore remains to be seen to what extent players in professional football will be obliged in future. In view of the existing risks, however, this would be welcome.

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