The Financial Conduct Authority (FCA) issued a formal letter in early June 2026 to football clubs mainly in the Premier League, highlighting significant concerns over sponsorship arrangements with unauthorised cryptocurrency exchanges and trading platforms. The FCA warns that such partnerships expose UK consumers to potential harm and creating serious financial crime risks under the Proceeds of Crime Act 2002 (POCA).
This intervention aligns with the FCA’s focus on protecting consumers and reinforces the need for robust due diligence and ongoing monitoring of third-party relationships. This is particularly relevant for any firm or organisation considering partnerships, sponsorships, or third-party relationships involving crypto businesses, trading platforms or financial services providers.
Key Developments
Increased Scrutiny of Unauthorised Crypto Sponsorships
The FCA has observed a rise in football clubs partnering with unauthorised firms offering crypto exchanges or trading platforms. Many of these firms appear to be providing regulated services without authorisation, which constitutes a breach of section 19 FSMA and/or making unauthorised financial promotions, which constitutes a breach of section 21 FSMA. Both breaches would amount to criminal offences and may result in legal, operational and reputational risk for the football club itself.
Consumer Harm and Legitimacy Risks
Such sponsorships can provide unauthorised firms with high-profile platforms to promote services to UK consumers and, in the football sphere, a loyal customer base. The arrangements may also expose clubs and potentially other partners to receiving criminal property, triggering POCA obligations.
Clear FCA Expectations on Due Diligence
The FCA letter sets out baseline steps that all organisations and clubs especially should take:
- Verify the third party’s and/or sponsor’s regulatory status and whether the firm has been flagged on the FCA Warning List;
- Assess the nature of services offered by the firm and whether they constitute regulated activities;
- Review controls to prevent UK consumer access (e.g., geo-blocking, disclaimers) where appropriate;
- Conduct enhanced due diligence and seek independent legal advice where concerns exist;
- Maintain ongoing monitoring throughout the sponsorship term.
Regulatory Implications and Compliance Considerations
This communication reinforces firms’ obligations under the Money Laundering Regulations 2017, POCA 2002, SYSC, and broader financial crime frameworks. Key lessons include:
- Embedding thorough third-party due diligence and risk assessments into sponsorship, partnership, and supplier onboarding processes;
- Comprehensive Business-Wide Risk Assessments (BWRA) and ongoing, risk-based monitoring;
- Ensuring own communications about sponsors do not constitute unauthorised financial promotions;
- Understanding source of funds and reporting suspicious activity where required.
A critical deduction from the FCA letter, is that sponsorship and partnership decisions are no longer just commercial, they carry material financial crime and regulatory risks. Failing to perform adequate due diligence on third parties and partners can expose organisations to enforcement action, fines and significant reputational damage. Strong Financial Crime controls and proactive Risk Management are essential.
How Complyport Can Help
Complyport offers tailored solutions to help firms strengthen AML and third-party risk controls, particularly in high-risk sectors such as crypto and sponsorships. Our services include:
- Third-party due diligence frameworks;
- Policy, Control framework and governance enhancements;
- AML/CTF/CPF BWRA reviews and updates;
- Financial Crime gap analyses and policy enhancements;
- Staff training on emerging financial crime risks;
- Ongoing monitoring and compliance support;
- Regulatory readiness and advisory services.
Book a Meeting with a Complyport SME
To ensure your firm’s sponsorship, partnership and third-party arrangements meet FCA expectations and robust AML standards, book a consultation with a Complyport Subject Matter Expert today.
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