Money Laundering through the Football Sector
Money Laundering through the Football Sector
Money Laundering through the Football Sector
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ANNEX – FATF QUESTIONNAIRE<br />
<strong>Money</strong> <strong>Laundering</strong> <strong>through</strong> <strong>the</strong> <strong>Football</strong> <strong>Sector</strong> – July 2009 <br />
1. Do you consider <strong>the</strong> football sector in your country to be vulnerable to money laundering? If yes,<br />
please describe <strong>the</strong> vulnerabilities?<br />
2. Do you have cases of <strong>the</strong> misuse of football clubs and <strong>the</strong>ir networks to launder <strong>the</strong> proceeds of<br />
crime (such as money laundering <strong>through</strong> player transfers, investment of illegal funds in clubs,<br />
gambling on football competition, <strong>through</strong> sponsorship, talent pools, business clubs)? If yes,<br />
describe <strong>the</strong>se cases in as much detail as possible and provide information on <strong>the</strong> persons or<br />
networks involved.<br />
3. <strong>Football</strong> clubs and <strong>the</strong>ir networks can also serve as a vehicle for perpetrating illegal activities<br />
such as fraud, corruption, bribery, illegal gambling. Sporting clubs can <strong>the</strong>refore also be seen as a<br />
source of „dirty money‟. Do you have any cases illustrating this kind of illegal activity? If yes,<br />
please describe <strong>the</strong> schemes used.<br />
4. By which means money laundering cases <strong>through</strong> football clubs have been detected (i.e. STRs,<br />
police investigations, newspapers)? If any, please provide <strong>the</strong> number of STRs relating to football<br />
and sporting clubs.<br />
5. Please provide an estimate of <strong>the</strong> amount of money laundering in each of <strong>the</strong> case you have<br />
described. Do you consider <strong>the</strong> cases illustrative (common) or exceptional (uncommon) for<br />
laundering <strong>the</strong> proceeds of crime <strong>through</strong> football?<br />
6. Please give a substantiated estimate of <strong>the</strong> overall size of money laundering <strong>through</strong> football in<br />
your country (in absolute numbers or related to <strong>the</strong> overall money laundering problem or<br />
compared to o<strong>the</strong>r money laundering schemes)?<br />
7. Do individual clubs, football associations, federations or public authorities take measures to<br />
prevent money laundering and o<strong>the</strong>r illegal activities (see question 3) <strong>through</strong> football, including<br />
on <strong>the</strong> basis of international measures? If yes, describe <strong>the</strong>se measures and if possible, provide<br />
<strong>the</strong> text of <strong>the</strong>se measures. What kind of measures could be useful to prevent money laundering<br />
<strong>through</strong> football?<br />
8. Which o<strong>the</strong>r sporting activities are notably vulnerable to money laundering in your country?<br />
Please describe some typical money laundering schemes <strong>through</strong> sporting activities o<strong>the</strong>r than<br />
football. Give a substantiated estimate of <strong>the</strong> overall size of <strong>the</strong>se money laundering schemes.<br />
© 2009 FATF/OECD - 41
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