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 |
Money Laundering through the Football Sector
