Money Laundering through the Football Sector

This report is based on four main sources: an extensive literature review, the analysis of the answers to a questionnaire sent to FATF and FSRB members; the results of a typology workshop and subsequent consultation with the football sector. The study has also relied on the experience and cooperation of the private sector. Criminals have shown adaptability in finding new channels to launder the proceeds of their illegal activities and sports is one of the many sectors that are at risk of being inflicted with criminal money.



With the growing economic importance of sports during the last two decades, especially football, money gradually started to exert a strong influence on the world of sports. This influx of money has positive effects, but also negative consequences. In order to get a better understanding, this study identifies vulnerabilities which make the football sector attractive to criminals. These are mainly related to the structure, the financing and the culture of this sector. The study analyses several cases that illustrate the use of the football sector as a vehicle for laundering the proceeds of criminal activities. After this analysis, money laundering (ML) through the football sector is revealed to be deeper and more complex than previously understood. Indeed, this analysis appears to show that there is more than anecdotal evidence indicating that a variety of money flows and / or financial transactions may increase the risk of ML through football. These are related to the ownership of football clubs or players, the transfer market, betting activities, image rights and sponsorship or advertising arrangements. Other cases show that the football sector is also used as a vehicle for perpetrating various other criminal activities such as trafficking in human beings, corruption, drugs trafficking (doping) and tax offences. This report is based on four main sources: an extensive literature review, the analysis of the answers to a questionnaire sent to FATF and FSRB members; the results of a typology workshop and subsequent consultation with the football sector. Results to the questionnaire were obtained in October 2008 from 25 countries, mostly European, seven South-American countries, two from Asia and Australia. The responding countries differ widely in size, role and organisation of football in society (ranging from large countries with big football leagues to smaller nations or nations with only non-professional football). Differences in information, position and interest in the person or organisation that provided the answers (national football association, government representatives, national FIUs, the police or judicial authorities) needed to be taken into consideration as well. All the comments of the private sector were taken into account when considered relevant.

Table of Contents
EXECUTIVE SUMMARY
INTRODUCTION
Scope
Methodology
CHAPTER 1: MONEY LAUNDERING AND SPORTS
Which sports?
Why football?
CHAPTER 2: STRUCTURE OF THE FOOTBALL SECTOR
Football governance
Football finances
CHAPTER 3: VULNERABILITIES OF THE FOOTBALL SECTOR
Vulnerabilities related to the sector's structure
Vulnerabilities related to the sector's finance
Vulnerabilities related to the sector's culture
CHAPTER 4: CASES AND TYPOLOGIES
Ownership of clubs
The transfer market and ownership of players
Betting activities
Image rights, sponsorship and advertising arrangements
Related illegal activities
CHAPTER 5: OVERVIEW OF ANTI-MONEY LAUNDERING INITIATIVES
International and national public authorities
Sports organisations CHAPTER 6: POLICY IMPLICATIONS
Key findings
Issues for consideration
REFERENCES
ANNEX – FATF QUESTIONNAIRE