Belgium Leading the Way in the Fight Against Money Laundering in European Football

In this episode of Integrity Insights, host Filip Brokes is joined by Professor Niels Appermont, a professor of economic law at Hasselt University in Belgium, and an expert in sports law. Neils discusses his research into money laundering in football, with a particular focus on Belgium’s fight against corruption and the broader challenges of enforcing anti-money laundering (AML) regulations in the sport.

Niels shares insights into the Operation Zero scandal, a 2018 Belgian investigation that exposed widespread corruption, money laundering, and match-fixing in professional football. The investigation led to reforms in Belgium's legal framework, including the introduction of AML regulations for football clubs.

Key themes discussed:

• The scope of money laundering in football: Neils explains how football has long been a target for illicit financial flows, with many clubs and agents using shell companies, false invoicing, and match-fixing to cover up corruption and illegal activities.
• The Belgian response: After Operation Zero, Belgium introduced AML regulations that cover professional football clubs, making them responsible for client identification, beneficial ownership checks, and monitoring potentially suspicious transactions.
• Key challenges: Neils discusses the practical difficulties Belgian football clubs face when implementing AML measures designed for the financial sector. These include issues with defining who qualifies as a “client” and dealing with the complexity of football transactions such as player transfers and sponsorship deals.
• International lessons: We also compare Belgium’s experience to the upcoming EU-wide AML regulation for football clubs, set to take effect in 2029. Neils explains the key differences and areas where Belgium has been a pioneer in implementing AML measures in football.

Key Takeaways:

• Money laundering in football is a significant problem, but it's hard to quantify due to the opaque nature of the sector.
• Belgium's proactive stance on AML in football makes it one of the few countries in the EU to regulate football clubs under AML obligations.
• Football clubs face unique challenges when trying to implement AML measures due to the complex nature of football transactions and the international scope of the sport.
• The upcoming EU-wide AML regulations for football clubs could lead to a fragmented approach that may not fully address the sector’s risks.

Listen now to explore the intersection of football, corruption, and financial crime and learn more about the evolving regulatory landscape in European football.

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Transcript

 Neils, thanks for coming on the podcast. Thank you very much for having me. It's my pleasure. Uh, let's, uh, let's do the intro very quickly. Can you tell listeners who you are and what, what you do? I am a professor of, uh, economic law at Household University in Belgium, where I mainly teach, uh, company and commercial law.

Um, but I also have a research interest in, uh, sports law and everything related to football. So, uh, hence my, uh, research on this topic. And I also, Neil say, also just, uh, saw on your LinkedIn profile that you're a member of the Royal Belgian Football Association. Yes. Uh, that's actually one of the reasons how I got into, uh, football research.

Um, a couple of years ago, a uh, friend of mine who I, uh, studied with, where I did my law degree with, uh, send me, um, a call basically, which was launched, uh, by the RBFA. Um, and at the time they were looking for. Well, lawyers basically to, uh, populate their disciplinary organs. Um, and, and out of interest, I just, uh, yeah, sent them my resume and an application and, uh, at that time they got back to me.

And they basically said, well, um, we're now dealing with the, the fallout still of the, uh, the operation Clean Hands, the Operation Zero Scandal on which we'll probably talk some more in the next few minutes. Um, and we're going to create something new, uh, a clearing mechanism, uh, in order to gain some more control on, on the invoices.

Paid, uh, to, to, uh, player agents, uh, by, by clubs and, and football players. And we're going to create this clearing system to gain some, some insight on, on the financial flows and to make sure that these invoices and these contracts, that they don't violate the rules, basically out set, uh, out by the, the football, the Royal Belgian Football Association.

Um, and if they're not in. Conformity, then we will not allow them to be paid out anymore. But we need independent, uh, lawyers to, to basically, uh, double check this mechanism. And we're going to create something called a clearing chamber. Um, and I was in that clearing chamber for a couple of years. We will talk about your research and the operations, zero, a little bit, LA later on.

But I wanted to ask you, you know, based on your. Research so far. Uh, how big of a problem would you say money laundering is in football? Because that's not necessarily something that people connect. It's actually hard to say. Um, it seems to be that everybody's in agreement that it is a big problem. And there's a lot of, uh, official reports saying this.

There's, uh, also some. Ports from, for example, Europe Poll, who dismantle, um, a ML and money laundering schemes or corruption schemes in, in football, uh, in, in different countries in Europe. So it started out with a report in 2010 from the financial election task force, uh, money laundering in, uh, in football.

Um, but it also was confirmed through multiple reports by the European Commission and, and very recently in July, 2025. By the, uh, uk uh, revenue service. Uh, so basically everybody seems to be in agreement that it is a big problem, but it's very hard to quantify because of the Yeah. By nature, very, it's by very nature, very opaque, of course.

And it's very hard to get a grasp, uh, to get a grasp on, on the exact numbers. Um, but yeah, most reports speak of, uh, millions to billions of euros. Um, but again, it's, it's very hard to put an exact number on it. Have you, have you focused on, in your research, on any particular instances of, uh, money laundering in football, whether in, I don't know, Belgium or internationally?

Well, we focused specifically on the Belgian situation because our point of departure was basically the new Belgian legislation and, and how that would interact then with the football sector and how it would work. Or not, or, uh, which structural problems there might be. Um, but yeah, of course the, the Operation Zero Scandal, which, which, uh, broke loose in 2018 demonstrated that there is a big problem.

And, and it is also a problem I think of, of culture, um, that a lot of stuff which is deemed to be acceptable by, by some players, uh, and actors, uh, within the football sector. Um, well, it's actually not, uh, very acceptable when you take, uh, when you look at it from, from a legal point of view. Mm-hmm. Okay, so let's, let's get into it a little bit.

This operation. Zero, which you said broke out in 2018. What, what, what happened there exactly? Well, um, basically the Belgian, um, judicial and, and police authorities conducted a very wide investigation into money laundering, corruption, and match fixing into the Belgian professional football sector. Um, and.

The public learned, I think of this investigation in 2018 when the, well, a lot of, uh, searches were being done, I think more than 40 searches, uh, and with, uh, players, coaches, referees, uh, clubs. Um, so basically the police just, just entered their premises, uh, on the basis of a warrant, and they conducted a lot of, a lot of evidence gathering.

And then in, during those days, uh, the information started to trickle out. Um. And it turned out, uh, that, um, later I think 6 56 people, um, were indicted. Um, a lot of, some of them referees, some coaches, some players, some player agents. And, um, at that time, Mr. Dion Kovich, who was a well-known player agent in Belgium, um, he opted to collab, cooperate basically with the authorities, uh, in, in order for a reduction, um, yeah, in, in, in the, in, in this conviction, uh, in, in, for the penalty.

And he basically laid out all these schemes that were being used also by him in professional football, um, to basically, uh, try to fix. Fixed games to bribe referees, to bribe coaches, um, to engage in, in tax evasion schemes, in order to have clubs, um, yeah, paid players, uh, and, and, and reroute those, uh, payments, uh, through all kinds of shell companies and, and, uh, which were situated abroad, uh, for scouting.

Um. Yeah, ex exercises, which, which basically never happened, but a lot of invoices were being paid to all kinds of foreign companies, and that money was then being rerouted back to Belgium. And, um, it was then, uh, yeah, collected somewhere in cash in order to pay out bribes. So there was a lot of stuff happening at the same time.

So it basically showed, um, yeah, a, a culture of, of corruption basically within the sector. So it was a, a very big scandal at the time, uh, in Belgium. And of course it led to, to reactions also from the legislator, which basically decided in the wake of that scandal to unilaterally then impose the preventative anti-money laundering obligations on the professional Belgian football sector.

And this was, was this, uh, this, this scandal or the investigation, was it con confined to, to Belgium specifically, or I suppose the, the highest professional football league in Belgium? Or was this more like a European wide investigation? It focused on Belgium. Um, so a lot of Belgian clubs, uh, and, and actors within the professional football sector were of course, uh, indicted.

Uh, but what we saw in, in the scandal, of course, is that it didn't, the, the. The operations weren't confined to Belgium. So these people were using, like I said, uh, shell companies abroad. Uh, and, and they were, um, paying invoices for scouting. Um. Missions abroad, which in reality never really took place. But of course, uh, those invoices seemed genuine and they could be paid by the clubs.

And like I said, the money was then rerouted to all kinds of foreign shell companies. Also within Europe, by the way. Um, and eventually collected. Back in cash at Belgian banks. And then they were used to pay out, uh, salaries or to pay out, uh, extras due to certain coaches. Um, there was also this one story about a club official who received, uh, a Rolex watch for himself and his wife from an agent.

Uh, because he made a certain transfer happen, uh, or a certain player was going to be on the pitch. Uh, so again, there was a lot of stuff happening at the same time. There was also this one game, um, a relegation game played by two Belgian clubs. Where, uh, apparently the referee was approached also by these player agents and club officials in order to make sure that the right club was going to stay in the first division and the right club was going to relegate.

Um, apparently even certain sports journalists were approached, uh, in order to, um, write articles which would shed that referee in a positive light, even though he was going to make certain questionable decisions in order to cover it up. Uh, so. Again, as I said, it was, uh, the scandal, um, exposed a lot of, a big variety of, of activities actually.

Uh, none of which, um, it's very, um, yeah, ethical or, or, and most were, were also illegal. And is it clear somehow from the investigations who was actually in charge of running these schemes? I mean, you keep mentioning the agents, so they clearly played an important role, but also the, the club club owners or who, who else was Yes.

Kind of like behind this. They, they were all implicated. So the, the main revolved around two agents, one of which was Mr. Kovi, who, who mm-hmm. They confessed everything, but also a number of club officials who were, uh, indicted, uh, referees coaches. Um, but the problem. Was that later? Uh, when, when. 56 people were, were officially indicted.

Um, a lot of them entered into plea bargains with the judicial authorities and they paid, um, well, yeah, a certain sum of money in exchange, uh, for not having to confess their guilt, um, and not to be, uh, prosecuted any further. Um, and afterwards, one of the, um. Investigators in charge, um, also passed away. So currently the remainder of the investigation is still in, in the, in the limbo.

And looking back at it, it's very hard to actually, uh, determine. Who was actually guilty and who was not. Uh, because it's not the case that if you are, um, suspected of certain criminal activity, that you're automatically guilty. Uh, an investigation has to demonstrate that you actually are. But in many cases, these investigations.

Later, were never really carried out. We're never really double checked. Most of these people, uh, actually never went, came before a judge. And, and, and, and certain procedures are still ongoing. Um, the only, um, public authorities, which seemed to have benefited directly from it are the tax authorities because, uh, a lot of investigations were also done by them into the tax fraud, uh, dimension of the operation.

Clean hands, uh, scandal and. If I recall correctly, I think the, the Belgian tax authorities, um, tried to collect something of 121 million euros in, in, uh, unpaid, uh, taxes or avoided taxes. Wow. And so, yeah. Um, something came of it, but, but ultimately, I think not as much as, uh, one would've put, uh, when the scandal broke out, only, only partial happened.

Yeah. Yeah. And, and, and a lot of the people who were actually implicated or suspected during those, uh, during this investigation, they're still active today mm-hmm. In Belgium professional football. But again, it's very hard to determine who was actually guilty or who is not, because Well, yeah. They actually never came before a judge.

It never came to a trial. Mm-hmm. And so you, you, Neils already mentioned that in, in, in, in response to. To, uh, to, to these indictments and investigation. The, the Belgium thirties, uh, voluntarily expanded the, the scope of the country's a ML rules as one of the only two, uh, countries in the European Union, along with Bulgaria to actually include, uh, its, uh, professional football clubs among the so-called obliged entities for a ML purposes.

Uh. How did that kind of come about? Was it immediate? You know, was it like something immediate that, uh, that, uh, materialized after these, uh, after these revelations? Or did it take a while and how was it? Im implemented, it took a little while. So, uh, the law was voted in 2020, 2020. Um, and it, it's, it's, it's a little, it has a little bit of particular history, so, um.

Belgium at the time was one of the countries which was still working on the transposition of the fifth European a ML directive. Um, but we had some, some problems with our government in the sense that one of the majority parties had decided for reasons totally unrelated to, to football or to, to this, uh, scandal to, uh, withdraw from the majority.

Um, so new elections had to be organized. What we still had in those days was a, a, a minority cabinet. Uh, so the political parties were still running. The government did not have a majority in Parliament and at the time. Some of, uh, the, the parliamentarians, uh, some of the, the people's representatives in our, in our federal parliament, um, try to include an amendment to then include professional football in Belgium's a ML legislation, which was.

Opposed in those days by our sitting finance minister, Alexander Deco, who would later become our prime minister. Um, so normally this would not have happened as the, the government and the minister in charge were actually opposed to those plans. But since the government did not have a majority in parliament anymore, um, the parliamentarians could just vote on it.

And that amendment was actually accepted by parliament. Hence. The professional football sector was included in Belgium's a ML legislation, but under normal circumstances, this probably would end have happened. Seeing as the government itself, the executive branch was opposed to those plans. So it was a, it was, so, it was a kind of a coincidence.

Which also makes sense because as I, as, as we discussed, Belgium is only one of the two countries that actually has this type of legislation in the European Union. So it's, that's interesting. Uh, I didn't know this, this background story. What, what would you say, Verde, I mean, this is something that you.

Actually discussed in, in, uh, your, uh, paper that, uh, I think was published in November, 2024, uh, about the money laundering and compliance in professional football. Yes. Um, and what were, what uh, would you say were the main challenges that the football clubs in Belgium faced when they, you know, when attempting to conduct the required risk assessments that, uh.

Very, basically this, this whole framework was originally designed for financial sector. So, uh, one would expect there to be some challenges. Well, the, the law, as I said, was adopted in 2020 and was identity to force in 2021, so roughly a year later. So the sector and, and the government, uh, they had some time to prepare for its entry.

Force. But when it did, um, it turned out that there were still a lot of questions pending. Um, and that was also uncovered by our research. So basically, um, who is, um. Subjected to a ML uh, um, obligations in, in Belgium on the basis of the preventative anti laundering legislation. In football, it's the RBFA itself.

So the federation professional football clubs and agents, but the law for the agents never really entered into force due to belgium's federalized structures. So, um. Currently, uh, they're still, uh, well not covered even though the law says it is, but it just hasn't entered into force for them. But for the clubs and the RBFA, it did enter into force in 2021.

And what we saw is that, of course, as you mentioned, um, a ML legislation was originally developed for banks and financial institutions, and that led to certain questions about how the law then should actually be applied to football clubs. A number of cases. Um, there was some, some clarity in the sense that the supervising authority in Belgium, which is the Ministry of Economic Affairs, the FBS economy, um, entered into a dialogue with the sector, of course, and, and did some auditing in the first, uh, phase without, uh, handing out fines in case of, of non, or, uh.

Incomplete compliance in order to get the sector up to speed. But there were also a number of structural deficits, I think, uh, in the law, which made it very difficult for the law to be applied very, yeah. Smoothly to the sector. So, um, and one of those things was, for example, the client concept. So the Belgian law on, which is based of course on European directives and on on on international FATF, uh, recommendations states that.

Obliged entities should identify and verify the identity of their clients. But who is a client of a football club? Uh, for, for a bank or a financial institution, if you open an account with them, it's quite straightforward that you are, are deemed to be a client. But football clubs, well, they have so many different activities and, and so many different, uh, actors they encounter in their dealings.

Um, and it was hard to see who can then be. Regarded as a client or not. So suppose that you are, uh, a spectator who just buys a match ticket for one day? Well, yeah, I think purely legally speaking, and, and, and if you, if you apply conventional techniques of interpretation, well that person is considered to be a client, but it's very hard, of course, for clubs to, uh, do, uh, no KYC uh.

Procedures on every single person buying a ticket. Same in case for player transfers. Um, and of course agents, uh, commercial counterparties. Uh, so some working, uh, methods had to be developed, but ultimately it took until, um. March, 2023 for a royal decree to be published in the Belgian Official Gazette, which provided for some more official, uh, guidance.

And it basically narrowed down the, the scope of this client concept and gave some guidance on who should be considered a client, uh, of a football club. And it turned out, um, that the concept is interpreted quite widely, but one seemingly glaring omission is the fact that, uh, investors and owners. Uh, so shareholders, for example, are not considered clients, which I think is a defensible interpretation, but specifically in football, they do represent one of the major, uh, a ML risks, uh, by having, uh, yeah, laundered money being injected into football clubs, uh, by basically buying them or investing.

So, so who is considered a client then? If it's not the, the, the, the shareholders. Or the investors? Yeah. That's something like I said, that the, uh, royal decree of 2023 outlines, uh, somewhat. So who is considered to be a client? Uh, well, certain spectators, if they deal with. The club for an amount of, uh, 10,000 euros or more.

So if you're buying business seats, for example, and, and the contract is worth more than 10,000 euros, you're considered to be a client. Uh, other football clubs are considered to be a client, for example, in the case of a player transfer. Although you can ask certain questions, uh, relating to the setup because if you, as a football club are, um, acquiring a player from another club, I think you are more their client than the other way around.

Uh, but it's somewhat easier to understand if you have a, an outbound player transfer to another club than so another club is acquiring a player from you. So, uh, then that club can indeed be considered a client, but the legislation as it now stands, covers both, uh, sponsors are also covered agents, um, counterparties, which are, um, leasing a stadium, for example, uh, or a part of it for an event.

Um. And for ex and also, um, other federations, for example, FIFA or U afa, when they deal with a football club or a Belgian football club receives money from them, for example, because of their participation in a European, uh, uh, in European competition. So it's just the conference league or the Champions league.

Um, UR might, in those cases be considered a client of a Belgian football club and needs to be subjected to these KYC procedure. Interesting. And speaking about, uh, the, the sponsors, uh, I found particularly interesting because we, as, as you know, we, we actually met at this, uh, play the game conference that took place a couple of, couple of months ago in, in Finland and there I, a lot of the speakers, a lot of the panelists there, uh, kept emphasizing the importance of illegal betting and, and its impact on, on, on the sector.

And particularly the sponsorships of these usual Asian based, uh, betting companies, uh, their sponsorships of various European based football clubs, and how this is a big, uh, uh, big kind of threat to the, to the sector. Uh, is this something that the Belgian a ML rule addresses? If you say that sponsors, uh, are in scope, would, would, for instance, a Belgian, uh, professional football club be obliged to conduct.

A KYC on a potential sponsorship deal, and would they have to establish the ultimate beneficial owner of the, the company that is, uh, that wants to enter into that partnership. In short. Yes. Uh, so sponsors of football clubs are considered to be clients according to the existing, uh, legislation in Belgium.

And hence, if a football club, um, wants to, uh, conclude a sponsorship contract with, for example, an a foreign betting company, uh, that betting company will have to be subjected, uh, by the football club to all, uh, necessary procedures. And so, um. Identification, verification of identity, um, the identification of the ultimate beneficial owners.

And then once the OP contract is operational, uh, the club has to monitor that contract and, and has to look out for, um, atypical transactions and, and transactions which do not fit the client profile. So. What, what I think, um, 'cause we also spoke to, when we did this in our research to one of the, the sponsors of the bill of the amendment, which led to the adoption, uh, of, of the law in 2020.

Um, and he basically said, well. We also hope, of course, that this, uh, achieves the aim of cleaning up the sector a little bit. So to have football clubs double think, uh, and, and to think twice whether they, uh, would actually accept the sponsorships or not. So, um. I think one of the aims of the legislator was also to, uh, have a little bit of a de-risking effect whereby football clubs and other actors within the sector who just steer clear, uh, from certain deals which they would otherwise perhaps have made, uh, but which they would deem too risky from an a ML perspective and hence not conclude anymore in the future.

And that might then lead to a better image for the football sector itself. Because Belgian football clubs are often themselves subject to de-risking and de banking efforts. From banks and financial institutions in Belgium, a lot of them actually have a very hard time getting access to a bank account, um, at an affordable rate.

Hmm. And, and, and, and how, uh, you know, given that, um, you, you've spent a lot of time kind of analyzing this, this, this Belgian, uh, ML law applying to football sector. How does it differ from the upcoming? We also already mentioned the upcoming new regulation, which we'll put. The football, uh, professional football clubs, EU wide in scope as of 2029, we actually had a pod, uh, podcast, I think it was the sixth episode with Nick Rodinsky, uh, that we, uh, published in June, 2024.

I would invite every, everyone to go back and listen to that episode, but, uh, what are the kind of, like the main differences between those two, uh, regulations? Well, there's quite a number of them actually. So, um. The new a ML regulation, which will indeed enter into force in 2029. And that itself is already an exception because the rest of the regulation will enter into force in 2027.

Football got two extra years to prepare. Um, but when it does, uh, there will be a number of differences. Uh, first main differences that federations, such as the RBFA will. Are not covered under the regulation while the RBFA is covered under the Belgian uh legislation. So we'll have to see what happens.

Secondly, uh, professional football clubs are covered, but there are a number of exceptions, uh, in the regulation. So, for example, the regulation says. The professional football clubs can be exempted, uh, if they play in the first division on the basis of a proven low risk for a ML, which has to be determined on the basis of certain criteria put forward in the regulation.

And, um, a turnover of less than 5 million Euros in the. Two, uh, proceeding, uh, accounting years, um, which might already lead to certain type of fragmentation, especially in in countries with football competitions, which are not as big, where, where a lot of smaller clubs are also participating. And then, um, there is also the possibility to exempt other professional football clubs playing in national leagues.

Which is not the first, uh, national League, also on the basis of a low proven risk. And there the, uh, second, um, condition of, of uh, having less than 5 million Euros turnover, um, disappears. So it's going to be a fragmented landscape, uh, probably. Um, and then. Professional football clubs are only or will only be subjected in 2020 900 regulation, um, under the a ML obligations in case of four types of transactions, uh, transactions with another football club, transactions with player agents, transactions with, uh, sponsors.

Um, and transactions for, uh, a transfer of player. So, um, and also the owners, uh, that's the, the final one. So, uh, transactions with owners and investors. So we see there are a number of differences. So the transactions with owners and investors will be covered also in Belgium, but also in the rest of the EU as of 2029.

But for example, um, transactions with, uh, lesses, uh, or counterparties were, for example, rent out a part of a stadium for an event. They're not covered under the European regulation. And then finally, um, agents will also be covered under the regulation, uh, formally. Again, this is also the case under the Belgian law, but due to Belgium's federal structure, um, the entry into force required an agreement between the federal government and the regional governments.

And that agreement has never materialized. Hence, layer regions are at the moment not subjected in Belgium. Let, let me ask you one, one last question based on your, you know, experience with the a ML framework in, in Belgium and seeing how this, because this is really like a unique situation that we have in the European Union is, is discussed.

Belgium is one, one of the only two countries that have had this type of legal framework in place. So this. Amazing opportunity to kind of analyze and see what, what has worked, what has not. And based on this is, which is something that you have been kind of doing based on, based on your, uh, you know, research, what, are there any kind of modifications or changes that you would like to see in the, into EU a ML framework that will be implemented in 20 20 20 20 29?

Yeah, it's a good question. Um. I think that the restriction of the scope for professional football clubs, the only four types of transactions, as I mentioned, type transactions with investors and owners, player agents, player chances, and sponsors. Um, I think it's somewhat too narrow actually. Um, for example, I already mentioned, uh, the case of, of lessees and, and, and, and other counterparties who, for example, ran out a part of a stadium.

'cause what you see with, with a ML, I think is that, um. Well, it always, the dirty money always tends to look for the road where it encounters the least resistance. And so if you know that those four transactions are covered, you'll probably structure your, um, dirty, uh, transaction as a transaction, which is not one of those four.

Uh, so it's very, it's very difficult. I understand that this was a, the result of a compromise, uh, um. EU wide to see whether to make, to make it workable for football, but still at leaves some glaring omissions, as does the Belgian law at this point in time. Also does, uh, because investors are not, uh, subjected.

Secondly, I also understand the reasons behind the possibility to, to, uh. Well, to create exemptions for certain smaller clubs, but still, uh, it, it does somewhat distort the level playing field. And also when a club, for example, promotes to the first division, um, and has, uh, a turnover which exceeds 5 million euros, then it'll be covered.

But if one year later it's relegates again, um, then it might again not be covered. So it's very difficult, I think, to keep track of all this. It might perhaps, um, might have been better to also include, um, in one way or another, in a certain role, the federations, uh, to, to gain some oversight on clubs or to centralize perhaps, uh, certain procedures, uh, for, to make life easier for the clubs, um, while taking into account also their, um, their specific role.

Uh, because in Belgium, one of the difficulties is, for example, due to the fact that the RBFA is subjected, the RBFA has super. Provide licenses to Belgian football clubs. So suppose the RBFA now receives a Belgium. Information, accounting information from a certain club within the licensing procedure and something smells off, uh, well then yeah, of course they would have to notify the Belgian FIU, uh, but suppose then they say, well, um, you can't go ahead with this transaction.

You can't, or, or we will not go on the license to this football club. Well, that's a financial debt sentence for a club on the basis of a mere suspicion that something might be off or a ML, uh, might or. Money laundering might be taking place. Uh, and, and that will probably then lead to all kinds of, uh, legal proceedings, uh, between the club and, and the federation.

So it's very difficult to, um, take all these different interests into account. Um, but I think that. The, the sector, um, and legislation in order to be effective should make that exercise and, and, and to develop a, a framework which is actually more tailored to the sector. So what we'll probably see, or what I hope to see that in the next few years, uh, uh, amla, uh, will develop some more specific guidance on how.

The regulation should be applied to the sector. Um, and, and I hope to see some more, uh, guidance popping up there. Okay. I mean, we still have about four years before it takes, uh, takes effect. So maybe they'll, maybe someone will listen to us and, uh, make some changes, uh, accordingly. But Neils, uh, I wanna thank you for your time.

I really enjoyed the, this conversation. There is very, there's actually very few people I feel like in the European Union who have. This specific expertise. So I really appreciate that you, you know, found the time to join the podcast and, uh, I wish you a merry Christmas as we are recording just before Christmas.

Thank you for having me. It.