The interview sets out a series of considerations on the implications of the applicability of AML rules to the football industry, including AMLA's role within the new EU framework, the rationale for bringing football within the scope of AML rules, the main money laundering risks affecting the industry and the expected impact on football clubs and agents in terms of supervision and compliance.

AMLA Chair's key considerations are the followings:

• Football industry and AML: Football is included in the AMLR as the global popularity of the sport, the amount, frequency and internationality of cash-flows involved as well as the opacity of corporate ownership structures of most football clubs and sponsorship agreements with high considerations may lead to vulnerability to money laundering activities. With respect to the scope of application of the AMLR obligations, the focus is on top-tier divisions. Clubs may be exempted if their annual turnover is below €5 million or if they are considered low-risk entities. However, exemptions are subject to national supervisory authorities assessments which will be based on methodology developed at EU level.
• Impacts of football clubs: With AMLR, football clubs and agents must apply controls on their clients and transactions. In practice, this means that they must identify their clients and their relevant ultimate beneficial owner, monitor the relevant transactions and identify the source of funds. Such measures could also involve the establishment of a compliance function but this requirement should be applied on a risk-based approach in order to not impose complex organizational structures on small entities. Such adjustments will require time and investment; football clubs and agents are therefore encouraged to begin preparing for their implementation as early as possible.
• AMLA's Role: AMLA's role is to lead the EU towards a uniform AML system. In this regard, AMLA will not supervise football industry directly but rather indirectly, by coordinating with national authorities, including national authorities duly established to supervise football industry[1], and national financial intelligence units ("FIU"). AMLA will also cooperate with private sector players through task force, working groups, internal committees, public consultation and industry feedback; however, to date, football clubs have shown limited engagement in AMLR-related consultations and negotiations.

Authored by Jeffrey Greenbaum, Elisabetta Zeppieri, and Domenica Esposito.