FIGHTING MONEY LAUNDERING IN FOOTBALL IN SWITZERLAND
Professional football involves substantial cross-border financial flows, including club investments, acquisitions, player transfers, agent payments, sponsorships and image-rights arrangements.
These transactions can involve complex ownership and contractual structures, making the sector relevant from an anti-money-laundering perspective.
Switzerland is also particularly significant as a centre of international sports governance and the home of FIFA and UEFA.
The current Swiss legal framework
Money laundering is a criminal offence under Article 305bis of the Swiss Criminal Code (SCC). The Article criminalises acts capable of frustrating the identification of origin, tracing or confiscation of assets where the person knows, or must assume, that those assets derive from a felony or a qualified tax offence.
Switzerland also operates a preventive anti-money-laundering regime under the Federal Act on Combating Money Laundering and Terrorist Financing (AMLA; SR 955.0). It applies to financial intermediaries, including persons who professionally accept, safeguard, invest or assist in transferring third-party assets (Art. 2 AMLA).
Football clubs and football agents are not automatically subject to the AMLA merely because they operate in professional football. Whether the AMLA applies depends upon the activity actually carried out and whether it falls within the statutory scope.
Football-related transactions will nevertheless often involve banks and other regulated financial intermediaries. When establishing a business relationship, a financial intermediary must identify its contracting party (Art. 3 AMLA) and, with due care, establish and verify the identity of the beneficial owner (Art. 4 AMLA). Opaque ownership structures, unusual third-party payments or difficulties in identifying the ultimate beneficial owner may, therefore, require additional clarifications. A reporting obligation arises only where the statutory threshold for a substantiated suspicion is met (Art. 9 AMLA).
A major change from 1 October 2026: the Swiss Transparency Register
A major change to the Swiss legal framework will take effect on 1 October 2026 with the entry into force of the new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (“Bundesgesetz über die Transparenz juristischer Personen und die Identifikation der wirtschaftlich berechtigten Personen (TJPG)).
The Swiss Parliament adopted the TJPG on 26 September 2025. On 12 June 2026, the Federal Council decided that both the TJPG and the revised AMLA would enter into force on 1 October 2026.
The reform introduces a central Federal register of beneficial owners, the Swiss Transparency Register, which will be administered by the Federal Office of Justice. A control body within the Federal Department of Finance will be responsible for checking the correctness, completeness and currency of the information contained in the Swiss Transparency Register.
The new rules apply to the legal entities covered by the TJPG, subject to its statutory scope and exemptions. Their application does not depend upon whether an entity is active in professional football. It depends primarily upon an entity’s legal form, its connection to Switzerland and any applicable exemption. This distinction matters because Swiss football clubs may be organised as companies or associations. Whilst conventional associations are generally exempted from the Swiss Transparency Register under the final statutory framework, Swiss professional football clubs structured as joint-stock companies (AG) are fully subject to the TJPG. The assessment must, therefore, be made on an entity-by-entity basis.
For in-scope Swiss football clubs, the practical issue will be to identify their beneficial owners and, with due care, verify both their identity and their status as beneficial owners. This may require particular attention where ownership or financing involves holding companies, minority investors, shareholder agreements, loans or several entities within an investment structure.
Unlike a conventional public commercial register, however, the Swiss Transparency Register will not be freely accessible to the general public. Access will be limited to the authorities and other persons or entities authorised under the applicable legal framework.
For Swiss football, the practical consequence is significant: even where a club itself is not subject to the AMLA as a financial intermediary, its corporate ownership structure may now be subject to substantially increased beneficial ownership transparency under the TJPG.
New AML obligations for certain advisory activities
The reforms taking effect on 1 October 2026 do not stop at the Swiss Transparency Register.
The revised AMLA also introduces due-diligence obligations for certain professional advisory activities which are considered particularly exposed to money laundering risks. According to the Federal Council, the reform is intended to close gaps in the existing anti-money laundering legal framework in Switzerland by combining increased transparency regarding beneficial ownership with due diligence requirements for certain risk sensitive advisory services.
This aspect may become relevant where advisers provide services connected with the incorporation, acquisition, sale or restructuring of companies, or with the creation and administration of corporate, fiduciary or domiciliation structures. Such activities may arise, for example, in connection with football club takeovers, investor structures or multi entity ownership arrangements.
This does not mean, however, that every lawyer, adviser or consultant involved in a football transaction automatically becomes subject to AML obligations. Ordinary litigation, contractual advice and sports law advice do not, merely because of the mandate, necessarily fall within the relevant regime. The analysis depends upon the precise professional service provided, the role assumed by the adviser and the statutory conditions of the revised AMLA. Under the existing AMLA, regulated status is linked to activities such as professionally accepting, safeguarding, investing or transferring third party assets (Art. 2 AMLA).
Football regulation provides an additional layer of financial oversight
Swiss football is also subject to the regulatory framework of the Swiss Football League (SFL) and the Swiss Football Association (SFA). Those private law sporting rules are distinct from statutory AML obligations but may require financial reporting and thereby increase transparency in the sector.
The significance for Swiss professional football
The reform does not make the Swiss professional football sector generally subject to the AMLA.
Its principal practical effect is likely to be increased beneficial ownership transparency for in-scope entities, alongside continued AML scrutiny by banks and potentially relevant duties for professional advisers carrying out specifically regulated activities.
It is advisable, therefore, that complex club ownership, investment and financing structures should be reviewed at an early stage.
We advise on money laundering legal issues in football in Switzerland and information may be obtained from Kim Gamboni by emailing her at gamboni@valloni.ch.