UEFA-Europol Memorandum of Understanding: What this means for football’s evolving risk map

Why it matters

Football's financial ecosystem has grown increasingly complex, and with that complexity comes vulnerabilities. FATF has repeatedly highlighted the risks associated with opaque ownership structures, hard-to-value player rights and cross-border payment flows. Although suspicious-match alerts fell during 2024, overall volumes remain significant.

The MoU gives Europol a more direct role in intelligence-sharing across jurisdictions. Although the agreement is principally concerned with cooperation, information exchange and the provision of expertise relating to serious or organised crime affecting EU Member States, its practical relevance extends beyond the EU. UK clubs, intermediaries and investors operate within the same European transfer market and financial ecosystem, and many transactions naturally span multiple jurisdictions. As a result, the UK's new Independent Football Regulator (IFR) will sit alongside – and not apart from – this wider enforcement landscape, with cross-border transactions and financial flows increasingly likely to come into view through UEFA-Europol cooperation.

Against that backdrop, scrutiny is moving from conduct on the pitch to the movement of funds around it.

Ownership and source of funds

Ownership remains one of the most sensitive areas for integrity and economic-crime exposure. Several UK clubs have entered administration in recent years where owner funding later proved insufficient or uncertain. In other cases, clubs have been acquired through offshore companies or complex corporate structures, which can make screening checks on significant persons more difficult. There are also examples of leveraged or non-transparent financing structures being used to acquire clubs, masking the identity of backers or the origin of capital. These patterns underline why ownership is not only a governance concern but also a potential entry point for illicit or undisclosed finance.

The IFR, established under the Football Governance Act 2025, is designed in part to address these vulnerabilities. It also sits within the UK government's wider anti-corruption agenda, with the 2025 Anti-Corruption Strategy identifying football as a sector at risk of corruption and illicit finance and envisaging a stronger role for the IFR in working with law enforcement and other regulators. Its licensing regime will introduce enhanced fit-and-proper owner tests and source-of-funds verification across the top five divisions in English football, sitting alongside the existing Premier League and English Football League tests. The aim is to increase transparency at the point capital enters the sport and ensure that the funding stands up to scrutiny.

Intermediaries and disguised payments

Transfer activity and intermediary relationships present another significant area of risk.

In the year to March 2025, HMRC opened investigations into 12 clubs, 90 players and 16 agents, recovering £90 million in unpaid tax. Over five years, recoveries linked to the football sector amount to many hundreds of millions of pounds.

HMRC's May 2024 guidance on agents' fees reflects this focus. Dual-representation arrangements – where an agent purports to act for both the player and the club – typically involve splitting a single fee into “player services” and “club services”. Historically, this was often recorded as a 50/50 split even where the agent's work was largely player-focused. HMRC now makes clear that this presumption will not be accepted.

Where the allocation does not reflect commercial reality, the structure can obscure who actually received value and create opportunities for disguised payments. For example, allocating most of a £1 million fee to “club services” reduces the player's taxable income even though the agent's work may have been almost entirely for the player. By shifting taxable remuneration into the club-services category, the reporting position diverges from substance and enters the territory of potential misstatement or false accounting. HMRC therefore expects clubs to maintain contemporaneous evidence of the services provided and fee-allocation decisions.

Agent regulation more broadly is in transition. FIFA's 2023 global agent framework was introduced to increase transparency and curb the use of opaque commission structures. One element – a cap on agents' commissions – was designed in part to limit opportunities for hidden, circular or inflated payments that could distort financial reporting or conceal remuneration. In the UK, however, an FA tribunal found that implementing the FIFA-mandated fee cap domestically would be anti-competitive. This ruling meant that the new global agents rules are only partially applicable in the UK, and required the FA to diverge from the new FIFA rules. But the underlying direction is consistent: regulators want clearer visibility over who pays whom, for what work, and through which channels.

Financial reporting and valuations

Financial-reporting integrity sits closely alongside these concerns. Italy's plusvalenza investigations showed how inflated player valuations, circular swap deals and undisclosed side arrangements can artificially enhance balance sheets or defer liabilities. These practices raise clear fraud and false-accounting risks where valuations are not grounded in genuine market conditions or where contractual terms are not transparently recorded. They illustrate how easily reporting accuracy can be compromised when remuneration flows or valuation decisions are not subjected to independent scrutiny.

Looking ahead

The MoU underscores the convergence between financial transparency and sporting integrity. While cross-border financial flows are climbing the enforcement agenda, match-fixing and betting manipulation remain football's core integrity risks – and merit fuller analysis in their own right.

The UK government's new Anti-Corruption Strategy 2025 also treats football as a sector vulnerable to corruption and illicit finance, and commits to supporting the Independent Football Regulator to strengthen its anti-corruption capabilities and links with law enforcement. That broader corruption lens is closely connected to the financial-reporting and tax themes addressed in this note and will merit separate consideration as the strategy is implemented.

As cooperation deepens, the boundary between economic-crime enforcement and sporting governance is likely to narrow further, with issues in one area increasingly triggering scrutiny in the other.

Authored by Reuben Vandercruyssen, Liam Naidoo, and Sam Tahir.