Premier League club structures carry money laundering risks, study finds

The ownership structures of Premier League clubs could enable money laundering and other financial crimes, academic research has found. In a study published in the journal Sport in Society, criminologists from Manchester University looked at the ownership structures of each top-flight side in the 2023-24 season.

They observed a prevalence of complex set-ups, with Manchester United having 13 legal entities within their ownership chain and Aston Villa’s structure featuring companies registered in four overseas territories. The researchers said they were unable to fully identify the owners of a majority of clubs.

“Twelve of the 20 clubs have at least 10% of their holdings which – due to secrecy provisions – cannot be formally traced back to their beneficial owners,” said Dr Pete Duncan, one of the authors.

“For many of these clubs – including Premier League giants Liverpool, Manchester City and Tottenham Hotspur – the entirety of clubs’ shareholdings cannot be formally verified. We are not suggesting that the publicly stated beneficial owners are, in fact, merely front persons obscuring the true beneficial ownership of these clubs. We are simply pointing out that the conditions of these clubs’ ownership structures enable that possibility.”

The research looked at the workings of clubs according to three key criteria: the presence of unnecessarily complex ownership structures; entities within the ownership structure located in places perceived to be “suppliers of secrecy” (such as offshore tax havens or the US state of Delaware); and an absence of information or data on all “beneficial owners” (defined as shareholders and investors with at least a 10% stake in a club).

Analysing these three conditions, researchers found that structures used by clubs commonly “combine multiple enabling conditions” for “illicit” behaviour. They also observe that “the combined use of multiple secrecy jurisdictions and opaque entity types that ultimately result in the obscuring of true beneficial ownership is concerning”.

The findings were based only on publicly available information and do not take in any changes made this season. The authors point out that such structures are not evidence of wrongdoing in themselves. “Our objective is not to determine whether illicit finances are indeed being channelled through the [Premier League],” they write, “but rather to highlight existing conditions that have the power to enable the misuse of the football industry for this purpose by motivated actors”.

The authors argue for greater transparency and a new approach towards the owners’ and directors’ test (ODT) taken by those looking to acquire “control” of a Premier League club or a minimum 25% of its voting rights. The study calls on the proposed independent regulator for English football to deliver a test that adds “enhanced due diligence and source-of-funds checks for current and prospective owners” while “structures which make use of multiple enabling conditions should be flagged as particularly high risk for misuse for the management of illicit finances”.

In the version of the Football Governance Bill passing through parliament, a revised ODT would have to be taken by anyone looking to acquire more than 25% of a club in English football or to exert “significant influence or control” over its activities. As part of that test, individuals would be expected to prove that they are “financially sound” and the source of their funding.