Spain’s major football teams will have to subject their financial operations to greater scrutiny. The new anti-money laundering law being prepared by the Government will require clubs to identify the investors, sponsors, and intermediaries they work with and to report the most significant transactions to the authorities, with special attention to changes in shareholding and player signings. The goal is to prevent these sports entities from being part, directly or indirectly, of the complex networks that move black money around the world.
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All the changes are included in the draft Preliminary Bill on Comprehensive Measures for the Prevention of Money Laundering and Terrorism Financing, with which the Government intends to definitively adapt Spanish regulations to the new EU legislative framework before July 2027. For now, the text is available on the Ministry of Economy’s public consultation and information portal, where it will remain until September 30.
Professional football has become a priority target for lawmakers due to its enormous business volume, cross-border transactions, and complex corporate structures. The European Union already focused on the sector two years ago when it shaped its anti-money laundering regulation. Now, the Executive wants to finalize the adaptation of the national framework to this scheme.
To this end, leveraging the same regulation, the Government will also launch the National Financial Integrity Authority (Anifi), a new unit that will channel all control work. And, in parallel, it will update the list of obligated entities to monitor and provide information, which it considers the “first guardians of regulatory compliance.”
In addition to professional clubs, this group includes football agents, which tightens the net around the king of sports. With these new measures, the Government aims to close one of the channels that, according to national and international risk analyses, criminal organizations are using to move and launder funds amid the tightening of controls by traditional banks.
The preliminary idea is that oversight of football will focus on four areas considered especially sensitive. Specifically, sports entities must report operations with investors, whether they involve changes in capital or are structured through other financing methods. Contracts signed with sponsors, operations and commissions agreed with football agents or other intermediaries, and movements related to player transfers or signings will also be examined.
In all these cases, regardless of the amount of money involved in each transaction, clubs and representatives will have to identify the individuals and companies with whom they conduct operations and verify who is actually behind them. The regulation also requires verifying the identity of the ultimate beneficial owners who ultimately own or control the funds or companies involved in a transaction.
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The draft, however, includes mechanisms to modulate obligations based on the risk level, to the point of excluding clubs considered low risk. Thus, the EU regulation inspiring the draft allows excluding teams with an annual turnover below five million euros. A threshold that, in practice, does not apply to clubs in Spain’s First and Second Divisions, whose accounts comfortably exceed that amount. For football agents, the deadline to adapt to the new rules is extended until July 2029.
More guardians
Football is just one of the activities under the new control perimeter. The draft expands and updates the list of obligated entities to include, among others, real estate developers and agencies, including intermediaries of luxury rentals when the annual rent reaches or exceeds 120,000 euros.
It also includes people who trade in cultural goods, including art galleries and auction houses, when the transaction amount is at least 10,000 euros. This amount also marks the monitoring threshold for storing or trading goods in free zones or customs buildings. Also included in the list are gambling providers, intermediaries of residency-by-investment programs, and professionals dedicated to the deposit, custody, or transport of money.
Monitoring politicians’ siblings
For monitored subjects, the regulation expands control over the siblings of those who hold or have held certain high political offices, both at the state and regional levels and, in certain cases, local. Until now, enhanced measures on relatives of these profiles focused mainly on spouses, parents, and children. The draft now broadens the focus to siblings of heads of state, heads of government, ministers, secretaries of state, undersecretaries, and parliamentarians, as well as senior party officials. The criterion also extends to equivalent positions in local entities with more than 50,000 inhabitants.
To identify these relatives, banks and other obligated entities may use specialized files and databases provided for by the law itself. The regulation also foresees an official list of positions considered politically exposed persons, which will facilitate their identification. Once the relationship is detected, banks, real estate agencies, gambling companies, and other obligated entities must apply enhanced due diligence measures, with greater checks on the origin of funds and assets and closer monitoring of transactions.
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