With anti-money laundering obligations rapidly expanding across the football industry, Monaco has emerged as an early leader by publishing a dedicated AML/CFT practical guide for sports agents.
The Principality’s AML supervisory authority, the AMSF, recently published a practical anti-money laundering and counter-terrorist financing guide dedicated specifically to sports agents. While many jurisdictions impose AML obligations on regulated professionals, Monaco appears to be the first to produce a detailed operational guide tailored exclusively to the realities of sports-agent activity. This initiative deserves recognition as an important contribution to the international compliance landscape.
The guide is particularly relevant because professional sport, and football in particular, is entering a period of heightened regulatory scrutiny. Transfers, intermediary arrangements, sponsorship structures, image-rights agreements, cross-border payments, offshore ownership vehicles, politically exposed persons (PEPs), and sanctions risks have all attracted increasing attention from regulators and law enforcement agencies.
Based on the official materials identified in our review Monaco's AMSF guide appears to be the only official AML/CFT practical guide specifically dedicated to sports agents issued by an AML supervisory authority or FIU-type body. While FATF and other organisations have published studies and typology reports on money laundering risks in football, equivalent operational guidance tailored specifically to sports agents has not been identified in other major jurisdictions.
Monaco’s existing framework
Monaco's sports-agent sector is relatively small in size but highly international in scope. As at December 2025, the Principality had 97 registered sports agents operating across more than 80 countries. According to AMSF statistics, the sector submitted 61 annual activity reports in 2024, achieved an 89.7% compliance rate with the AMSF questionnaire process, and generated one suspicious activity report to the CRF. These figures highlight both the global reach of the sector and the rationale behind the development of dedicated AML/CFT guidance.
In Monaco, sports agents are already subject to AML/CFT obligations under Law No. 1.362. The AMSF guide translates those legal requirements into practical procedures, covering customer due diligence, beneficial ownership verification, sanctions screening, ongoing monitoring, suspicious activity reporting, record retention, and enhanced due diligence for higher-risk situations.
Importantly, the guide addresses the specific risks that arise in the sports sector, including complex intermediary chains, opaque ownership structures, international transfers of funds, tax evasion, betting, ticket sales, broadcasting rights and sponsorship and the involvement of multiple parties in player transfers.
Rather than simply restating legislation, the guide provides a practical compliance framework that can be implemented by sports agents in their day-to-day activities.
Europe moves towards Football Sector regulation
Monaco’s initiative comes at a time when the European Union is introducing a new AML framework for professional football.
The European Union has already adopted Regulation (EU) 2024/1624, which will bring football agents and certain activities of professional football clubs within the EU AML framework from 10 July 2029. They will be required to undertake customer due diligence, identify beneficial owners, assess source of funds, monitor transactions, maintain records, report suspicious activities, and implement internal compliance controls.
The new regime reflects concerns that professional football may be vulnerable to money laundering through player transfers, sponsorship arrangements, investor structures, and cross-border financial flows.
France has already started the process
France has also moved in this direction through Loi n° 2025-532 du 13 juin 2025 « visant à sortir la France du piège du narcotrafic ».
Sports agents are already subject to French AML legislation through Article L.561-2 of the Monetary and Financial Code.
The 2025 law expands the legislative framework by amending Article L.561-2 to allow certain football clubs and sports companies affiliated with the French Football Federation (FFF) to become regulated entities under conditions that will be defined by a future implementing decree.
As of June 2026, the decree has not yet been published. The precise scope, thresholds, exemptions, and operational requirements applicable to football clubs therefore remain to be confirmed.
The same legislation also strengthens France’s wider AML framework through enhanced beneficial ownership controls, expanded investigative powers, stronger asset-tracing mechanisms, mandatory AML training requirements, and additional tools for combating organised crime and narcotics-related money laundering.
Preparing for the future
Although full implementation of the EU football regime remains several years away, football clubs, investors, family offices, agents, and advisers should begin preparing now.
Risk assessments, beneficial ownership verification, source-of-funds reviews, sanctions screening procedures, transfer-chain due diligence, and governance controls are likely to become increasingly important across the sector.
Rosemont Consulting can assist sports agents, clubs, investors, family offices, and corporate structures in developing practical AML/CFT frameworks, conducting risk assessments, implementing due diligence procedures, and preparing for both current Monaco requirements and the forthcoming European football compliance regime.
Monaco’s sports-agent guide may have been designed for a local market, but its significance is much broader. As football moves towards a new era of regulatory oversight, the Principality has provided what may well become the benchmark for practical compliance in the sector.
For more information, please contact consulting@rosemont.mc
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