The Malta Football Association (MFA) has confirmed that, for now, the new anti-money laundering (AML) regulations are unlikely to have a major impact on local football clubs and agents, even as these entities prepare to come under the same scrutiny as banks and financial institutions.
Earlier this month, WhosWho.mt reported that under the EU-wide framework enforced by the Anti-Money Laundering Authority (AMLA) – working alongside local regulators such as the MFSA and FIAU – professional football clubs and agents, crowdfunding platforms, credit intermediaries and investment migration operators are being added to the list of “obliged entities.” This makes them subject to the new Directive.
Speaking to WhosWho.mt, Malta Football Association (MFA) Vice-President Matthew Paris explains that while professional football clubs across Europe are being identified as potential subject persons under the new rules, the sixth AML directive will not be applied universally across all EU-based top-tier football clubs.
Instead, the directive introduces a two-pronged test:
1. Club turnover exceeds €5 million yearly
Dr Paris notes that, to date, “no club in Malta has a turnover equal to or exceeding the threshold established by the EU Directive,” meaning that Maltese football clubs should not currently be considered subject persons under the rules.
He adds, however, that football is a dynamic environment, and changes in club revenues could alter this position, “in which case and consequently, the aforesaid position could change,” he warns.
Dr Paris was asked whether this risk could change given that Ħamrun Spartans are competing in the Conference League and have already earned approximately €960,000, suggesting that, if they progress further, their turnover could approach €5 million.
“The financial benefit will only be relevant for one club, whilst 92 per cent of the clubs participating in the league shall remain below the threshold,” he explains.
While he did not provide the average turnover of Malta's top clubs, Dr Paris noted that club spending tends to lie between €500,000 and €1.5 million. Since football clubs are not known to generate much by way of profit, the revenues of even the top earners are likely a way off from the €5 million threshold.
2. The club poses a significant risk to anti-money laundering efforts
Dr Paris stresses that the MFA has long prepared to mitigate any potential risks.
“All top-tier football clubs are required to publish audited accounts annually, and we have introduced due diligence and AML regulations to ensure our structures are well organised and protected from external threats,” he says. These measures were introduced in 2017 and 2021, respectively.
He also highlights that in 2019, the MFA signed a data-sharing agreement with the Malta Gaming Authority (MGA) to facilitate information exchange for the prevention and investigation of match-fixing and corruption incidents in sports.
“On this basis, the second test is also not met,” Dr Paris continues.
Ultimately, “whilst the MFA will make its case accordingly, the decision rests with the supervisory authorities and not the FA per se,” he concludes.
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