On 29 September, the Premier League published the decision of the independent Commission in its case against Manchester City. The Commission found every charge proven bar one, including that the club disguised owner funding as sponsorship revenue across nine seasons. City say they will appeal. For financial crime professionals, the more important question is different: how did conduct of this kind go undetected for so long, and could similar risks be going undetected at other clubs today?

In financial crime terms, the Commission's findings describe well-known typologies: disguising the true source of funds through third parties, settling liabilities off the books through connected entities, and financial statements that misrepresented who really funded the club. These risks are common across professional football, yet they are not always examined through a financial crime lens. In this analysis, FINOMNI sets out what clubs and leagues should be assessing.

Background: what the Commission found

This analysis is based on the Commission's redacted Core Decision and the Premier League's statement, both published on 29 September 2026.

The Premier League began investigating City in December 2018, after Der Spiegel published documents taken in a hack of the club's servers. It charged the club in February 2023, and the Commission heard the case over 42 days between September and December 2024. Its Core Decision, published in redacted form on 29 September 2026, found:

• A Disguised Funding Scheme. From early 2010, City entered into sponsorship agreements with Abu Dhabi sponsors that recorded fees well above fair market value. The sponsors paid only part of each fee; the balance was paid by ADUG, the owner's holding company, and booked as commercial revenue. The Commission found the agreements to be shams, and that the club's income was overstated by more than £830 million between 2009/10 and 2017/18.

• Undisclosed related parties. The Abu Dhabi sponsorship agreements were related party transactions and should have been disclosed as such.

• Hidden liabilities. Several arrangements under which ADUG paid the club's own liabilities, including remuneration and image rights payments, were also shams, leaving the club's expenses understated.

• Concealment. For many years, regulators and even the club's auditors were unaware of the scheme.

• Intent. The club knew its accounts did not give a true and fair view, or was reckless as to whether they did, and clearly intended to circumvent the Premier League's rules.

• Non-cooperation. The club made concerted efforts to stop and frustrate the investigation. One of the non-cooperation charges was not proven.

These are disciplinary findings under Premier League rules, not criminal convictions. They remain subject to appeal: City say the decision contains material errors of law, principle and fact, and have until 2 October to appeal. Sanction will be decided at a separate hearing. FINOMNI's focus is not the appeal or the sanction, but what the conduct found tells the rest of football about financial crime risk.

Why this applies to clubs

UK football clubs are not regulated firms under the Money Laundering Regulations 2017, so they have no statutory AML programme of the kind banks operate. That does not mean these risks sit outside their responsibilities. The pressure comes from four directions:

• The Independent Football Regulator now tests owners' source of wealth, as we explained in Two Tests, One Blind Spot.

• The failure to prevent fraud offence reaches many clubs, as we explain in section 6 below.

• The Proceeds of Crime Act 2002 applies to everyone, and a club that receives criminal property through a commercial arrangement is exposed, as we set out in Beyond the Badge.

• Banks, lenders and sponsors are regulated, and increasingly apply their own AML obligations to the clubs they deal with.

In the EU, the position is changing formally. Under the EU Anti-Money Laundering Regulation (Regulation (EU) 2024/1624), professional football clubs and football agents become obliged entities from 10 July 2029, two years after the regulation applies to other sectors. The regulation does not apply directly to UK clubs. But UK clubs in multi-club ownership groups with EU clubs, or dealing regularly with EU clubs and agents, will increasingly find their counterparties held to it.

What clubs should be assessing

1. Source of funds behind commercial revenue

The risk:

The Commission found that City's Abu Dhabi sponsors paid only part of the recorded fees, with the balance paid by the owner and booked as commercial revenue. In financial crime terms, this is a misrepresentation of the true source of funds, a pattern compliance teams know from third-party payment and front-company schemes: a genuine contract and a genuine payment, but a gap between who appears to pay and who actually funds it.

FINOMNI’s view:

“Sponsorship due diligence often focuses on the agreement itself. The Commission found that documents were created both to reassure sponsors that they would only ever pay the smaller sum and to conceal the arrangement from regulators and auditors. No review of the sponsorship agreement would have surfaced that. The risk sat in the flow of funds behind the contract.”

What to assess:

• Is the payer of record always the contracting party?

• Can sponsorship values from connected or state-linked partners be justified against market benchmarks?

• Do you understand how a sponsor funds its obligations when it has links to your owner?

2. Third-party payments and concealed liabilities

The risk:

The Commission found that ADUG paid liabilities belonging to the club, including remuneration and image rights payments, through arrangements recorded outside the club's own contracts and accounts, in one case in a consultancy agreement between other parties. The typology is familiar: a third party settles an obligation so that neither the true payer nor the true liability appears on the books. Names are redacted in the published decision, though earlier reporting linked one arrangement to former manager Roberto Mancini, who denies wrongdoing.

FINOMNI’s view:

“Splitting remuneration across connected entities and jurisdictions keeps each contract plausible on its own and each payment below the threshold of scrutiny. The same structure recurs across football in image rights companies, consultancy agreements and intermediary fees, which is one reason the EU has brought football agents and professional clubs into its AML framework.”

What to assess:

• Can you see the total economic benefit received by players, managers and intermediaries across all connected entities?

• Do any payments go to offshore vehicles linked to them?

• Do consultancy and image rights agreements have clear, evidenced deliverables?

3. Beneficial ownership and PEP exposure

The risk:

City's owner, Sheikh Mansour, is Vice President of the UAE, and the Commission found that the club's Abu Dhabi sponsorship agreements were related party transactions that should have been disclosed as such. That places the club and its connected sponsors firmly in politically exposed person territory.

FINOMNI’s view:

“The Commission found these sponsors were related parties even under the accounting definition, yet they were never disclosed. Football's rules, including the Premier League's Associated Party Transaction rules, focus on whether connected deals reflect fair market value. AML frameworks ask a different question: who ultimately stands behind the money.

A state-linked company is not automatically a PEP or a known close associate under the Money Laundering Regulations, but where a senior PEP or their family can exercise control or influence over it, banks would typically apply enhanced due diligence. That gap between a pricing test and a source-of-funds test is where the risk sits for any club with state-linked or politically connected ownership.”

What to assess:

• Do you have a full map of your beneficial ownership, including holding companies, trusts and lending between connected parties?

• Which of your commercial partners are connected to your owners, applying an AML standard rather than only the accounting definition?

• Is new owner funding, including loans and top-ups, traced to source? Our analysis in Two Tests, One Blind Spot explains why incumbent owners are the blind spot here.

4. Financial reporting: an audit is not assurance

The risk:

The Commission found that City's financial statements for nine seasons did not give a true and fair view of its financial position, and that for many years regulators and even the club's auditors were unaware of the scheme. Heavy reliance on revenue from connected parties is a recognised red flag in its own right.

FINOMNI’s view:

“An audit tests whether transactions are properly recorded. It does not necessarily test who ultimately funded them, particularly where documents have been created to conceal that. A clean audit opinion is not assurance that related-party revenue is what it appears to be, and boards should not treat it as one. The City decision is now a documented example of why.”

What to assess:

• Do your finance and compliance functions independently review the substance of connected-party revenue, not just its accounting treatment?

• Does your board receive a clear view of where commercial income depends on parties connected to the owner?

5. Investigation readiness and record-keeping

The risk:

The Commission found that City made concerted efforts to stop and frustrate the Premier League's investigation, and that some of the club's witnesses gave evidence they knew to be untrue. In AML supervision, obstruction and untrue explanations are treated as risk indicators in their own right, and City's non-cooperation had already been upheld as a serious breach in the 2020 UEFA case.

FINOMNI’s view:

“Investigation readiness is a control in its own right. A club that cannot quickly produce complete records, original documents and witnesses is exposed regardless of the underlying facts.”

What to assess:

• Are your record-keeping and retention policies consistent across all group entities?

• How would you respond to a regulator's information request?

• Does your governance make clear who decides on disclosure?

6. Fraud prevention procedures

The risk:

Since 1 September 2025, large UK organisations can be criminally liable if an associated person commits a specified fraud intended to benefit them and reasonable prevention procedures were not in place. The offence does not apply to past conduct, but many clubs now meet the size thresholds.

FINOMNI’s view:

“Inaccurate accounts and disguised payments through associates are exactly the kinds of risk a club's fraud risk assessment should now cover. They are not always framed in those terms.”

What to assess:

• Do you have a documented fraud risk assessment covering commercial revenue, remuneration and connected-party transactions?

• Would your procedures stand up as reasonable?

What leagues and governing bodies should be assessing

1. Source of funds, not just fair value

The issue:

The Premier League's Associated Party Transaction (APT) rules test whether owner-connected deals reflect fair market value, and in September 2025 City accepted them as valid. But the Commission found that sponsors paid only part of the recorded fees. A deal can look commercially plausible and still be funded by the owner.

FINOMNI’s view:

“In AML terms, fair value is a pricing check, not a source-of-funds check. Verifying where the money actually comes from is the core control banks apply to PEP-connected counterparties, and it is not the focus of football's current rules.”

What to assess:

• Do connected-party approvals verify source of funds, not only fair market value?

• Are payments reconciled to the contracting party, so a third-party payer is flagged?

2. Prevention at the point money moves

The issue:

The Premier League opened its investigation in December 2018. Nearly eight years later, the Commission has published its findings, but the appeal and the sanction are still to come.

FINOMNI’s view:

“Effective AML frameworks are preventive and risk-based: due diligence at onboarding, controls on each payment and ongoing monitoring. Disciplinary processes are retrospective by design. When scrutiny depends on enforcement after the event, conduct of this kind surfaces slowly, if at all, which is a large part of the answer to the question we opened with.”

What to assess:

• Is enhanced due diligence applied at licensing, owner approval and major sponsorship approval?

• Is owner funding and connected-party activity monitored between those points?

3. Detection should not depend on a leak

The issue:

The decision records that UEFA questioned City's sponsorship arrangements in 2013/14 but settled with the club in 2014 without making findings. In 2020, many of UEFA's allegations were dismissed as time-barred. The conduct now found proven came to light through documents from a hack, not routine oversight.

FINOMNI’s view:

“In financial crime terms, this is a detection gap. Warning signs were raised as early as 2013/14, but no routine control turned them into findings. And a case that fails on time limits leaves the underlying risk unresolved, not cleared.”

What to assess:

• Which red flags in your oversight would surface disguised funding without a leak?

• When concerns are closed, is the reason recorded and the risk still tracked?

4. Treat findings as a trigger event

The issue:

The Independent Football Regulator and the FCA are now scrutinising English football, and EU clubs come under national AML supervision from 2029 within a framework coordinated by AMLA. Our analysis in Football's New Regulatory Era sets out how those regimes are converging.

FINOMNI’s view:

“In AML practice, an adverse finding is a trigger event for reviewing a customer's risk profile. The same principle should apply to owner suitability: findings like these should prompt a fresh look at source of wealth and funding. The City decision is likely to be an early test.”

What to assess:

• Do adverse findings trigger a review of owner suitability and source of wealth?

• Is relevant information shared with the bodies responsible for those decisions?

Beyond the verdict

The Commission's decision answers a question about Premier League rules: whether one club complied with them. It does not answer the wider question that clubs, leagues and their counterparties now face: do we know who is really funding football, and could we demonstrate it if asked?

That question matters regardless of how any appeal ends. The risks described in the Commission's findings, from connected-party sponsorship to layered ownership and third-party remuneration, exist across the game. What is changing is the expectation that they are identified, assessed and evidenced. Until recently, football sat largely outside the financial crime frameworks that apply to regulated sectors. In the UK, the Independent Football Regulator, the FCA and the failure to prevent fraud offence are narrowing that gap. In the EU, the AML Regulation will bring clubs formally within scope from 2029.

For clubs and leagues, the practical step is to adopt the discipline regulated firms already apply: a risk-based approach that maps where money enters the organisation, verifies who stands behind it, and applies controls when money moves, not years later. Those that do will be far better placed for the scrutiny that follows.

For banks, sponsors and lenders dealing with clubs, the implications are immediate: update adverse media and risk assessments to reflect the Commission's published findings, noting that they remain subject to appeal; revisit any file that treats the 2020 outcome as a clearance; make sure sponsorship payments are commercially justified and evidenced, as we set out in Beyond the Badge; and map exposure across ownership and group structures.

FINOMNI works with clubs, leagues and the businesses around them to assess and manage financial crime risk in sport. If you would like to discuss any of the issues raised in this analysis, please get in touch.