A World Cup Special - Dirty Money, Beautiful Game

James Booth Hello everybody, welcome back to Silent Eight Talks. You should know me by now, James Booth. I'm global head of anti-money laundering, counterterrorism and sanctions at Silent Eight. Happy World Cup month and today is a bit of a treat because I get to combine two things, well maybe I should say three things with our guest, that I really care about the most of financial crime football. And as many of you will know, Oona, who is a well-known compliance specialist, I'm going to let Oona say a bit more about who she is in just a moment, but Oona and I have become friends over, how long would you say Oona, the last year or two? Yeah. So many of you might have seen Oona's recent publications, which we'll ask her to speak about, but most notably around football and with it being the World Cup, we thought what a perfect opportune moment to talk about financial crime and money laundering when it comes to football. So we're in the midst of the World Cup, 48 teams, full swing across North and South America. On the back of the England game last night, which was a little bit of disappointment, but Oona Vandenberg, welcome to the show. How are you?

Oonagh van den Berg Thank you, Mr. Booth. I am doing incredibly well, as always, and I'm super, super excited to be chatting with you today. I have to be honest, I am not your atypical football fan. I, my husband, Gerio, is an absolute football fanatic. So I live vicariously through him in terms of what's happening in the football world. But I'll be honest, I think like many kind of non-diehard football fans, when it comes to the World Cup, there's just something so different about it. Like it's really, it brings people together, it brings communities together, and it's just, it's really joyous. And in our house, we have a little bit of a conundrum at the moment, where Ireland obviously aren't, they're playing, my husband's Dutch, we live in Portugal. But, you know, and our eldest daughter, she's at school in Scotland. So we're like, which flag do we hang this year? I was about to ask, how are you dealing with this at home? What are you doing? We've just gone with the United Nations approach. Everybody's flag is outside. Oh dear. The Dutch flag keeps falling down, which my husband feels is a terrible omen. So he's like, that's it, that's it, you know, the Dutch aren't going to get through. But after the game the other day, what was it, 5-2? They did incredibly well. But I had to laugh. My middle daughter, she's become a little, she loves to watch the football with her, with her daddy. And she's a real, like, she's real orange, you know, she's Netherlands through and through. And on Sunday, I was listening to BBC Radio 2, as I do, and they were playing some musicals. And one of them was from the, what was it, the original Mary Poppins. So I said to my daughter, do you know who that is? That's the original Mary Poppins song. And she goes, and who's singing it? And I said, oh, that's Dick Van Dyke. What? Wait, she goes, Papa, Van Dyke's singing a song on the radio. And I went, no, no, no, no, no, no, no, not that Van Dyke. So, but yeah, it's beautiful to see it through the eyes of the kids as well. Like they get really excited. And our youngest, she's only three. And when Portugal scored last night, she came running in and she did a whole dance for us. She has no idea what's going on. But it's, as I said, not a football fanatic myself, but the World Cup is something pretty special.

James Booth So before I just give a bit of a summary as to what you've been doing, because you've probably been the busiest person on the planet this year. Who are you actually rooting for to win the World Cup? Oh, that's really controversial. I promise this will be a secret until it goes out on Apple

Oonagh van den Berg and Spotify in two days. I answer one way, my marriage ends. You know, I'll be honest, having lived in London for, for, for, you know, the best part of seven years, um, I have to say, I think, I think there's a real, a real love for England. Um, I love to see England playing. I want them to succeed. I would love finally for us to win a world cup so we can stop reminiscing about the previous one that we won. Um, so I have to say, I suppose England, um, although I shouldn't say that too loud cause I am Northern Irish and we have our own football team, but given they didn't get in and given Ireland didn't get in, you know, yeah, it would be England, but please don't, don't mention that too loudly.

James Booth We can, um, we can, we can, we can blow that bit out. I've not added the explicit content warning, which I'll do now in case, but, but naturally I'm going for England, but obviously you and I were chatting in New York a little while ago and I was unraveling the heritage story that I've got and obviously found out I'm quarter Portuguese and you've invited me to your lovely home with your lovely family. And that'll be my first visit to Portugal. So I have to be honest that I'm, uh, I've sort of got a bit of a sweet spot for them now, but then if we start dissecting and parts of Africa that I'm from, I mean, England and Portugal, I'll go for Scotland.

Oonagh van den Berg You know what you should do here, James, you should put out the list of all countries that you have, uh, you know, a genealogy association with, and then people will actually just reach out to you and invite you to their houses. That's how it works. So go through the list.

James Booth Sympathy invite. Is that what we're saying? It's a sympathy invite.

Oonagh van den Berg No, it's not. It's a cultural heritage visit. Uh, you know, people want you to come so you can experience your heritage.

James Booth I can't wait to meet your husband and have this side of the debate with him and see what he says.

Oonagh van den Berg My husband doesn't like people coming into the house.

James Booth Oh dear, so Una, you have been, fair to say, busy, haven't you? Now I know we've got a fairly big agenda to get through with football, but I think it would be doing a disservice to you for everything that you're doing for the compliance world. You've sort of published a series of books, I think you're awful at modernising compliance, the series, keynote speaker, lecturer, a NED, founder of some compliance, and I've actually just brought a new book out, haven't you, about football and financial crime.

Oonagh van den Berg I have indeed. So it's been a really busy year. And this was actually a conscious decision. A lot of people have seen me, you know, as, you know, doing keynote speeches and attending various conferences, either in a moderator or a kind of like an MC capacity over the past year. And obviously in the background, I do have my own consultancy business. I spent 20 years working in the industry in-house in the likes of Citi, Deutsche, HSBC, Standard to name a few, and ING as well. And then I started my own consultancy business. And after having my daughter, my youngest, I kind of took a step back and really wanted to kind of reframe and refocus on where my energies lie in terms of legacy building. And I think as I've come to the middle of my life, that's become something which has become more important to me. My mother once said to me, Una, we all come into the world the same and we all But it's what you make with your life that makes a difference. And I started then ask myself, you know, I'm in my mid 40s now and I'm like, well, what is my legacy and where am I going with my career? And I love working in our industry. Don't get me wrong. It's not easy. It can be difficult. We meet we meet the best of people and we sometimes meet the worst of people, unfortunately, like any industry. But the core of what we do in our products, and I just love being able to think outside the box and constantly improve upon what we do and really just say, like, OK, using improved skill set diversity, improving technology capabilities now with the evolution of AI functionalities, what we can do with that. I get so excited every day about what we can do. And so I kind of thought to myself, well, what can I do to really show that enthusiasm? And I do have a social enterprise that we set up back in 2020, where we give free training to the industry, which is part of my kind of pay it forward. We don't make any money. In fact, it's loss making. And the only reason we do it is to try and bring theory through to help people, not technical regulatory training, but theory, like how do I actually do the job? And that is what the Modernizing Compliance book series has all been about. It's taking all of that theoretical knowledge and into the book. So currently we have nine books published in the series. I've just finished the last book, which has had to be separated into two volumes, which is on financial crime auditing, which was actually my last internal role in Citibank. I was APAC head for regulatory and financial crime internal audit. So it was bringing all of that together for a full suite book, which are series, which starts with the effectiveness era, which is where we are now with FATF. And then moving through the building blocks of how do you develop a structured, future-proofed compliance framework that is continually developing and helping me constantly see my top and emerging risks. So I know where the fires are going to eventually pop up and where, and preempt what I need to do in advance. So, you know, we've built books around building out the control room, I would say the control tower for compliance, which is your MI, which is critical. Before that data governance, like clean up your data, then obviously moving into the realms of AI, like what can you use AI for? What are the disciplines? And importantly, AI is not artificial intelligence incorporating into your framework. It's not technology. That's an entire organizational transformation, which starts first and foremost for first and foremost with governance. So I really wanted to hit home that about 70% of AI projects fail, because they're started from the wrong perspective. It's about governance. It's about transformation. It's about looking at how you're going to utilize the skills of this technology in its purest form to future-proof your organizational aspirations. So what is your product roadmap? What's the future direction of the organization? AI is a holistic implementation tool. It is not a silo tool. So I wanted to, and that was actually one of the foundations of writing the series. It was like, people are jumping to AI without thinking about the real reality of what it means. And there's a lot of pre-work that's required. And in fact, in writing the AI book, Jaap van der Molen, who many people will know, he's global head at ABN AMRO of financial crime transformation. He actually worked quite closely with me on reviewing the book and brought so much credible input into it as well. And in fact, I dedicated the book to Jaap as a result of that. So these books have been written alongside some of the top industry practitioners, including myself, if I may say. But the one book that I really wanted to publish was, I suppose, in a way, on one half, my husband, as I mentioned, is a football fanatic. But as we've seen with the AML regulations in Europe and also in the UK, there is now an towards financial crime rule adoption, AML rule adoption in the football ecosystem. And my question was, well, what does that actually mean? I have worked in nearly every discipline in financial services from wholesale, corporate banking, investment banking, private banking, asset management, retail, insurance, crypto, digital assets, now moving into football. So I wanted to research it, to really understand. And actually what shocked me the most, James, was the fact that the frameworks and the complex structures that are used actually led me back to my days doing my university degree. I actually studied to become a tax lawyer. And when I started looking at all of the different frameworks that have been used and the ecosystem around football, it just takes your breath away. Forget about the beautiful game. The ecosystem that's designed around football for money movements is, in its purest sense, beautiful. But however, because of the way it's designed, it is the perfect conduit for money laundering.

James Booth It is. And there's some great books out there. I have a terrible feeling that there's many people that will be listening to this podcast today. I've had so many times at conferences, they're like, you and Una need to sit down and do a podcast and have a chat. And I'm like, no, we do talk about stuff, but stuff that we can't repeat on a podcast. We never stop talking. No, and it's stuff we can't repeat on a recorded record. But I've got a feeling today we might be about to ruin everyone's love of the game because when you start to peel some of those layers back, it starts to get a little bit spicy, doesn't it? So I'd really want to build on it. It's the World Cup, so we're all in football season and it'd be doing a disservice to not talk about more about what's sort of sat behind this. And I think from what I've gathered, Una, is that, and you published it and I'll direct everybody to a really good article you did on this on LinkedIn, actually, and I've used that to sort of base some of this conversation. That article's on LinkedIn and I'll drop it in the comments as well when we post this on Apple and Spotify. Your argument seems to be that the threat to football no longer is the 90 minutes or, well, should I say the 105 minutes because of whatever's happening in America with all the breaks at the moment. Yeah, well, so to speak, yeah. But your argument is that football is sort of stopping becoming a sport and becoming more of a financial ecosystem. And the FATF warned about this about 2009, didn't they?

Oonagh van den Berg Oh, God, yes, they did. It was actually, it was a 2009, 2011. They actually, FATF came out and said, you know, guys, this is an area that has received, that has not received the focus that it deserves. In fact, even Pat Lorden, ex-head of the, ex-guarda, ex-head of the Irish FIU, commented on the post the other week and said, you know, you're absolutely right. This is an area that for too long has not deserved the focus. And when you're working in intelligence, whether it's in the likes of Europol, Interpol, local law enforcement, FIUs, they see the conduits that actually occur with organised crime into the football ecosystem. And the questioning where the money is coming from, because people want the money in order to further, whether it's the club or the player transfers, etc. So a lot of the questions that we would ask from a financial institution perspective aren't asked. You know, there are obviously corruption risks, there are ownership transparency risks, there is sanction exposure risks. And we can we can talk in detail about that. Look at Chelsea's a great example. And that wasn't a direct sanction exposure. That was when somebody who owns the club is added to a sanction list, what actually happens and the Chelsea the Chelsea situation is a is a very interesting kind of, should I say, discussion point or indeed case study. But there's also things around kind of betting integrity and governance failures. And unfortunately, there remains a substantial gap in understanding practically, and implementing capability across the football ecosystem. And we really, really need to focus on this because football is, as we've discussed, entering a period of increasing regulatory scrutiny with governance and integrity expectations likely to accelerate significantly as we move towards 2030, which is when AMLA, the European Anti-Money Laundering Association, is going to then start actively overseeing these non-financial entities, so to speak. The UK, also as well as the Football Association, has set up an independent body that's overseeing this as well. There's so much happening in this space, and I don't think that anybody is actually fully understanding what is going to happen in this space. Many organisations are underprepared.

James Booth Massively. And I think we'll look at this from an international and maybe a domestic level, and we have to sort of talk about the UK just because it's one of the country, well, the strongest league in the world for revenue and everything else. But I was part of a consultation period with RUSI through Catherine Westmore around the report that they put out. But let me set some numbers around this. So I've extracted these, and I know you've taken these from the FIFA transfer index. So 2023 was about £9.6 billion in transfers, 2024, just over £8.5 billion. And then summer of last year, correct me if I'm wrong, it was about £9.5 billion, with over £3 billion happening in the Premier League in the UK alone. These are huge numbers, Una.

Oonagh van den Berg Yeah. And if you look at the estimated net worth of global football, and this is from Ruzi, you're looking at around US$600 billion in terms of the economic footprint. And that is, that's bigger than some small countries' GDP. This is phenomenal. And even if you look across borders, like player transfers, on average FIFA international transfers processed in 2024, over 80,000. 80,000 transfers. So this is phenomenal, but it brings with it unfortunately some very, very complex commercial relationships, massive capital flows, and also questions around legitimacy. And the question is, when there is so much speed, if we look at a comparison here with digital assets at the speed of transactions, we are very lucky in the digital space that we have blockchain analytics. We can actually look at where monies have been. Let's take Bitcoin in its most simple capacity. We can look at it from its inception, the whole way through its line of ownership, and we can actually see where it's moved from historically. And then going forward, future, we will be able to see where it moves to. When you're dealing even with just player transfers of over 80,000 a year, how are you tracking that? How are you tracking the capital flows, most of which are coming through shell companies? It is a nightmare from a monitoring perspective. And these organizations do not have the tools in place currently. Yes, they'll have. They have all of these organizations have MLROs. If you look at Chelsea, Man United, Man City, they have an MLRO, they have a head of regulatory legal. But if you compare it to financial institutions, and remember, we are also on the back foot with some of our historic legacy systems, which are static rules and scenarios. These guys are even more on the back foot. And the question is, are the tools currently fit for purpose? The quick answer is no, they're not. And they will need a significant amount of data and AI functionality to really get a true feel of what's happening in the ecosystem. And that is going to require a significant investment from their side.

James Booth Absolutely. I'm going to burst a myth for everybody here. So people make an assumption that a football transfer, player A is sold to club B. Club A transfer money through their bank, it clears through the FIFA clearinghouse and it reaches the bank of bank B who departs at the funds. But that is so far from the truth. You have sovereign wealth funds, you've got private investors, sponsors that are involved in the deals, banks, of course, betting operators, technology providers, agents, lawyers, accountants, intermediaries, players themselves. And it pretty much touches every country on earth, doesn't it, Una?

Oonagh van den Berg Yeah, and transfers is actually a really, really good example, James. I'm glad you, we didn't, by the way, guys, we didn't actually discuss this in advance. So well done, James, for bringing this up. What is really interesting, and this is where I'm getting really nerdy because I got really excited about this, a player's valuation varies significantly between clubs, agents, analysts, investors, supporters, and the media. And so the question is, each assessment potentially is defensible. So which valuation is it? It's subjective. And this is where objective value ends and opportunity for manipulation begins because you have, let's say, subjective value. The buying, the selling club says we're selling for 80 million. The buying club says we're buying for 120 million. Remember, there's going to be additional fees involved there with agents, etc. An analyst could value the player at 95 million based on performance, the market, etc. The agent may value the player at 150 million because they want the best outcome. The supporters may value the player at 200 million. And media may publish that the player was sold for 110 million. All of them have, potentially, reasonable basis for the valuation, but there are multiple values. And unfortunately, where you have subjective valuation, high value, multiple intermediaries, and cross-border payments, guess what you have? The perfect recipe for financial crime. It is a

James Booth perfect recipe for money laundering, isn't it? I'm just thinking of the placement, the layering, and integration, which I know is a bit of an archaic model anyway, but you can start to see how some of these put in I'll give everybody that's listening an example about this nature of subjectivity.

Oonagh van den Berg By the way, James, I can actually give you a visual to share as well for the audience if they want to see it, which I'll send over to you afterwards. You've got some good

James Booth ones on your LinkedIn at the moment, Una, I'll give you that. Thank you. Some of the football ones. But anyway, this is one I was going with. I think of an Adidas football boot, and if I go to my local shopping centre and I buy this Adidas football boot that I've seen Messi wearing, and it's 150 wears that boot, even though it's 150 pounds in the mall, it's now worth 150,000 pounds. The subjective nature, to me, because I think Messi is the best ever, but to somebody that

Oonagh van den Berg doesn't like football, that's where it gets. Just going to come back to the heritage there. You've already mentioned that you're a quarter Portuguese. You've now said that Messi is the best player ever, and you want to come to Portugal. I think you're going to have to change your trip.

James Booth Well, okay, so let me clarify this. The most naturally gifted footballer ever is Messi, but best example of a manufactured footballer where you're putting hours and hours and hours of your life into the gym and training is Ronaldo. Well, that's exactly it. That's what

Oonagh van den Berg I always say. If you're looking at God-given talent, and I think Ronaldo wouldn't disagree with this, he was never the most gifted footballer, but what he demonstrates is when somebody is fully committed themselves to being the best they can be, he is your a perfect example, I believe, globally, irrespective of working capacity, whether it's football, this guy just shows you what hard work and determination and being in the right place at the right time with the right opportunities can do for you.

James Booth So before, because this will go for editing, I just want to, I just want to re-emphasize something, Ronaldo, who's the greatest footballer of all time, if you had a boot of his, it would be worth, but look, there's so much to tackle, and we've got, you know, not loads of time to do this, but if you had to point to the single easiest player, to hide dirty money in football, transfers, agent commission, image rights, whatever it is,

Oonagh van den Berg where do you think that is, and why? Oh, that's a really good question, the challenge is, is that there's basically nine key areas, and I won't go through them all today, but there's kind of nine key areas, where, James, I'm gonna have to pause one second, the rain has just started, I need to close the door, because it's gonna get really, really heavy. Well, we can't, we

James Booth can't go through all the points anyway, because simply, you've got a book, book to sell, Luna, so we need to make sure that, um, that we're able to do that. It was, uh, that is a really heavy

Oonagh van den Berg rainstorm, which has started, wow, um, El Nino at its true, its truest, so I'll be honest, when you talk about financial crime, um, I think that we need to differentiate between the types of financial crime, and where, where they could most readily raise their ugly heads, um, and I'm actually not going to focus here on, on drugs, like, you're atypical, like, drug flows, etc., but let's talk about human trafficking, like, that, for example, this is one area people wouldn't naturally jump to, youth academy, academies, and talent pipelines, there is a massive market for youth exploitation and trafficking, so think about all of these young players, who at 16 years old, leave their home countries, and go to youth academies, and we have them across Europe, we have them in the Middle East, China, you name it, everywhere, the UK, not all of those youth players end up in the first team, or indeed the second team, some of them may go to kind of, they won't go into premier leadership, for example, we take the UK, they won't go into a premiership team, but they may play second or third division, but many of those players are in a country, where they don't know the language, they have no relatives, and they're basically out of the club, they're out of the academy, where do they go? In some instances, these kids these children have actually been the hope of their entire, not just family, but their entire village or community from where they've come from, that they're going to make money that will help support their entire family and the ecosystem around that. So going back home, in many instances, is actually not even a choice. And in some cases, these children actually get offered football contracts to move to other countries. But those contracts actually aren't football contracts. It's actually inadvertent human trafficking. So similar to what we see with the hiring for the Southeast Asia pig butchering centres that we've seen.

James Booth I hate that term, pig butchering. It's an awful term, isn't it?

Oonagh van den Berg It's an awful term, but I don't think that we should spend time trying to get a new term. Let's put it this way. Until the pigs start protesting, they're insulted by it. Let's focus our attentions on trying to stop the fraud, so to speak. But in my, you know, what I see here is very, very similar to that. People apply for jobs with very reputable institutions, then go out with the airline ticket to, for example, Bangkok, waiting to be picked up at the airport to be brought to the local office where they've applied for the job. And sometimes it's the big four. It can be reputable firms. This is what's published in the media. You've seen like, you know, Uber, et cetera. These people are going for well-respected, organizations. But when they get there, unfortunately, the job is not real. It's a fraud. And they end up having their passports taken and they're inadvertently kidnapped and then forced into forced labor. And this is what's happening with a number of these individuals in the youth academies. And there is in the book, we actually covered some of the stats on it as well. And the statistics are harrowing, absolutely harrowing in terms of the exploitation, of children. So if you go to, I think, chapter 15 in the book, most people look at the success stories, but people don't look at the talent economy and what actually is around, what is around that. And we actually have some really nice visuals around this, about the vulnerability that it creates for children. So yeah, so it's a, it's a very, very dangerous area in terms of financial crime. And that's just one aspect of financial crime. But if we look at the kind of the wider ecosystem within football, tax evasion is a 101. Like image rights, we've seen court cases with Messi and Ronaldo in this, where they used offshore structures to funnel image rights. And in both instances, they were prison sentences. And luckily, neither party had actually been to prison before. If either party had had a criminal conviction previously, either Messi or Ronaldo or both could have ended up in prison as a result of this that's how serious this was. So tax evasion, it's a 101. And then you also have the issue with fraud, with irregularities around fees, commercial sponsorship and partnerships, overvaluation of sponsorship deals, reputational sanctions exposure. And that also brings us into club ownership and investment structures. The investment structures in clubs are exceedingly complex in terms of corporate structures. And ownership at times is very opaque. We have a lot of consortiums that own football clubs. And it's a bit like whenever you're doing due diligence for an investment fund, you know, how, what percentage are you looking at when you start conducting due diligence on the individuals behind it? And what percentage of ownership are you looking at? And if we look at enhanced due diligence in most jurisdictions, you have to look at you know, anything above 10%. But if it's just, I'm supposed football, you would, you would do right. But if you're onboarding an entity as a financial institution, which is a shell company or structure used in this, you may not necessarily know about the exposure, because it could be one or two degrees from separation. So this client could end up being on your books, potentially medium risk, when in fact, they're funneling monies from the football ecosystem through the really going to have to step up their game here and understand the kind of the pay through on various accounts, which, in all honesty, I know it's not football related. But if we look at wildlife trafficking, for example, still to this day, the ability of financial institutions to identify corporate structures involved in these types of activities is minimal, because our traditional systems are not equipped for it. So that's just some examples. And we could talk about digital assets and kind of NFTs. That has been a big area as well. There's, you know, token manipulation. Obviously, a really good example here was the UK FCA coming out the other day to say football clubs should not be sponsored by unregulated digital asset providers, because it gives the perception to the public that they are regulated. And in fact, I did a post on this all of the clubs currently operating in the UK that are sponsored by digital asset firms, and only one of them was fully authorized with the regulator. There are lots of

James Booth ethical questions around this anyway, but especially with sponsorship of things like gambling and, you know, children's football kits, you can't often buy with the branding on. But I think the powerful thing that you've just spoke about there, Una, is of course, it's all really bad. And a lot of what you've said is probably not new. But I do think that shining the spotlight on the humanitarian issue that I think you've just done so well. And people might be thinking, well, why on earth would what's the what's the riches at stake here? Now, I just want to be clear that I think you referred to these case studies before. I'm not making any allegations that these were crimes were committed. But if you want to, people want to understand what's the incentive to do this. When a transfer involving Paul Pogba and his agent, the agent pocketed almost 50 million euros in a fee. That's the motivation, isn't it? Yeah, absolutely.

Oonagh van den Berg It's all the motivation. One on one is money. And even if you look at money structures and hidden controllers, when ownership and control are not the same thing, these are all we know we need to distinguish legal ownership from actual control. And that is one of the most challenging aspects of ownership analytics. And again, something within financial institutions, we struggle to do because of the information we have. You know, we receive, we know from a regular tree perspective, we are required to obtain, you know, the memorandum of association and the articles from cooperation. We get all of this information, but the truth is the person listed in official documentation is not always the person making decisions. And then you have to look through. And so the question is rarely who's the owner, but who controls it. So, you know, we need to go beyond the registry, so to speak. We need to identify the beneficial owner. We need to follow the money and the influence to understand the real exposure and understand why decisions are being made. And we have some really good examples of this. There was in Arnheim, there's actually a really, really good example of this.

James Booth Where the Chelsea, sorry to interrupt you, but they're also part of the Chelsea family.

Oonagh van den Berg That was it. But nobody actually, a succession of named individuals were recorded in the corporate documents. So that was the visible ownership. But it wasn't until 2023 that through investigations by the Bureau of Investigative Journalists and The Guardian, which came through in the Cyprus confidential files, that basically it was shown that it was secretly bankrolled by Roman Abramovich, who owns Chelsea, exactly to your point. So, and at least 117 million US dollars have been channeled through shell companies in British Virgin Islands, Luxembourg, Belize, to name a few. And as a result of that, they received a sanction and point deduction. But, this is the challenge. It's legal owner on the record versus real controllers, control and ownership. And in this case, it was only uncovered because of investigative journalism. Now, financial institutions, and with all due respect to people working in financial crime, they are not investigative journalists. They're not out there, you know, getting information that is not readily available in the public domain. And that is the challenge that we actually have.

James Booth It doesn't take much to just put a Google in and to find ownership structures of specific companies. And there have been multi-layers of complexity, all within legal means, might I add, and how easy it is to dissolve those. But you did mention, so I think we've touched on fraud, we've touched on the humanitarian, with you were trafficking and money laundering, clearly. You've briefly touched on Chelsea and the Roman Abramovich era, and that's probably one of the most famous involving sort of a sanctioned situation. The Abramovich case essentially froze an entire institution overnight, didn't it? And when Chelsea Football Club was sold, I think five years ago now, the proceeds are still actually sat frozen. Why would that be a thing here? So this is where the sanctions world now comes into the financial crime landscape, doesn't it?

Oonagh van den Berg Sorry, James, could you just repeat that? Apologies that we kind of broke up a little bit.

James Booth Yeah, apologies for that. So we were just sort of making a segue to the Abramovich case where Roman Abramovich faced sanctioning from the UK government, and those sales proceeds are still frozen all these years later. This is where the intersection of sanctions and

Oonagh van den Berg football now come together, isn't it? Absolutely. And unfortunately, that situation with Abramovich is a very visible one because of the change in sanction regimes because of geopolitical issues. But what we're not seeing actually is the hidden sanction nexus within many organisations and what we don't see in the background is we see very, very clearly, even with players, player contracts, registered players, football clubs. OK, we see that all on paper. But what we don't see is third party investors. We don't see economic right holders. We don't see the offshore companies in full transparency because of data privacy limitations and secrecy limitations. And what we importantly don't see is influence over basically valuations, players' destinations, et cetera, because of potential corruption in the background. And that corruption element as well is something really important. And unfortunately, FIFA itself was not immune to this. And we actually saw this back in 2015 when Swiss police, acting on a US state's indictment, arrested football officials from Don Raids in Zurich. And that actually also included the head of FIFA, who was at that time the president, Sepp Blatter. And what had actually happened was he was receiving kickbacks. He was receiving monies under the table. But what his son had been doing, and this was the stupidity of it, was going into banks and asking them what the reporting threshold was and structuring payments so that the payments always went back. The reporting threshold. And that then was something that really brought about the importance of looking not just at individual payments, but combinations. And that actually had an impact on financial institutions, should I say, rules around transaction monitoring. So no longer it was a value of this amount, but a value of this amount or a combination which exceeds X in this period of time. So that case was a really interesting one, not just from the corruption, but also it was a very interesting case on how monies were actually constantly put in below reporting thresholds.

James Booth Yeah. So, I mean, if people that are listening to this will be tearing their hair out, but this brings us back full circle about the interpretation of things like the FATF guidelines and implementing those at a national level and inside your organisation. So I'm going to throw a bit of a curveball question, Una. I feel there's going to be a part two to this because I think we need to do one after the come back and talk about it. Hopefully I'll have a signed copy in my hand by then that you keep promising me, Una. Yes, please. But here's an interesting one. So FATF had their roundup meeting this week, of course, the presidency with Mexico is now handing over to the United Kingdom. But part of that meeting was an announcement on the grey listing. And you're probably thinking, where the bloody hell are you going with this, James? Bosnia and Herzegovina were added to that grey list in the plenary of this month. And they're actually at the World Cup. They're in Canada's group, I believe. Canada have just also had their mutual evaluation adopted as well. So do you think, and looking forward to the Saudi Arabia World Cup as well, do you think hosting a World Cup would sharpen a country's regulation around financial crime?

Oonagh van den Berg That's a really, really good question. I'm proud of that one. No, no, it's really good because it actually has been a focus area about the potential elements, especially around human trafficking, et cetera, that can result out of the, you know, a World Cup being hosted. And there's a lot of entities which are actually talking about this at the moment. A hundred percent, yes. It really does, for the countries that are, you know, in 2030, Portugal, Spain and Morocco are going to be jointly hosting the World Cup. And, you know, we talked about human trafficking earlier. Estimates suggest that between 6,000 to 15,000 young African players are trafficked into Europe. And there actually was a case study from 2024. A human rights watchdog documented a Ghanaian player who died during a trafficking operation. And, you know, this is the reality of it. So there's going to be big questions around, right? We have these clubs that are going to be hosting the World Cup. We're going to obviously have an entire hospitality industry supporting the World Cup. There's also going to be a lot of, you know, of, should I say, people involved in terms of various aspects of, from everything from ticket sales, from on the day, security, etc. This makes a country ripe for financial crime, unfortunately, in the context of massive, the Olympics is also another perfect example. Any country that hosts one of these events opens itself up to a lot of attention in this regard, because unfortunately, how vast this is, you cannot get away from the fact that there will be bad players, because the bad players will look for the easiest way to flow that money. And that's the reality of what's going to happen. So to your point, yes, I'm a bit of a nerd when it comes to FATF, by the way. If you go to my virtual risk solutions, the website there, I literally do an analysis, I've actually done an analysis in all of the reports that have been issued to date, but I've actually... I've actually created a... And I haven't published this, maybe I should. I've actually published a review, an assessment based on a lot of research on where I think each country's evaluation potentially is going to go this time around with the mutual evaluations. Because it's... I've spoken with a number of the evaluators, even the team that's out in the US currently doing their mutual evaluation. And I'll be honest, it is cutthroat this time around. They are being driven to build, it's not about show me your policy, show me your procedures. It's like, this is all great, but show me that it works. Show me it's effective. Show me the results. Show me your SAR submissions. Show me your client account. Show me how you've made decisions on risk ratings of customers. All of this. And organizations are now being asked to defend not the framework, but if the framework actually works. And I'll be honest, the challenge you have is in many organizations, if you said to the compliance officer, okay, explain to me, even as simple as your geographic risk assessment, how have you given this scoring to these countries? Humbleweeds will blow through. How have you completed your EWRA or your BWRA? People will be scampering around trying to find it to start with. And then when they do find it and dust off the dust, the question will then be, okay, tell me how you formulated this EWRA. Again, many organizations have used external companies to develop this. And again, this was one of the books that I wrote, how to do this. This was something that was drummed into me from a very early stage in my career. If you can't explain it, you can't do it. And we need much more explainability in our industry. And if something isn't effective, that's fine. Not everything is going to work. It's about trial and error. And to be honest, that's what innovation is. It's allowing us to feel and try different ways of doing things to see if it works. We know that our controls are not fit for purpose, but yet we still keep trying to do the same thing again and expect different results. And the reason why we do that is there's a complete lack of understanding in how the one-on-one foundations of our frameworks have been built. If you cannot explain your BWRA, your EWRA, forget about even talking to me about the rest of your framework, because that is the foundation upon which you've built your house. That is the foundation of your controls. And if you can't do that, then I don't even want to have a further conversation with you, because that document should be living and breathing on your desk 24-7. Your MI should be feeding into that to tell you where and which risks need to be re-evaluated, where and which controls potentially need to be modified. New and evolving typologies and threats should be feeding into that document as well, constantly evolving your... continually improving your control framework. And guess what? They're not. And it's not rocket science. This really is not. But many organizations don't do it because the fear factor is people don't understand how to do it. So it kind of bringing it back to the book series. That's why I wrote the book on it because I said, guys, here's how to do it. Please now get it done right and then make it better. I want people to take the lessons that I've learned, knowledge and experience that I've obtained, and I want them to do better that's the success through my eyes is somebody saying to me, oh no, this was great as a starting point or as kind of like an intermediary. But in fact, to make this even more sophisticated, this is what I would do. That's for me, a feeling of success.

James Booth Yeah, I think we should probably do a part two on this soon. And we should probably bring in the, and I'm serious, I think we should bring this in where we maybe drill down into where the risks from football and sport in general, and we can broaden this slightly with the Olympics coming and so on, about what the controls are and considerations that banks need to put in in EWRA and the BRAs as well. So I'm already sensing the shaping of a second part to this, Una, if you'd be up for that.

Oonagh van den Berg James, I think the truth is you and I could talk all day, every day, so I'm more than happy.

James Booth We should do one after a few glasses of wine because they're always really interesting conversations. Oh, thank God.

Oonagh van den Berg No, I don't know if people want to hear me on wine. I don't know if that's a, if that's a mass industry ask.

James Booth Well, we'll find, we'll find out, won't we? But let's, let's, we are sort of coming to the end of today. So we will do a part two because everybody's heard it here that Una's agreed to it. And what we're going to do is take these risks that we see in football and build on obviously the points that Una's spoke about over a published series. And we'll talk about what that means if you're in a bank or you're in an institution that may be handling some of these transactions. But Una, thank you as always for your time. And I look forward to part two that you have now inadvertently signed up for Well, I'm looking for it.

Oonagh van den Berg We didn't even touch on Burnley and Everton. So literally, and not, you know, for the PSR break.

James Booth You're breaking up. No, no, we will. I've got a list of stuff.

Oonagh van den Berg No, I know. I know that's what I'm saying. There's so much more to unpack. James, it's been an absolute pleasure. Thank you so much to you and for signing on to it for having me today. And I'm really looking forward to round two.

James Booth I look forward to part two. Safe travels, Una. And thank you for everything you do. Thank you.

Oonagh van den Berg Take care, James. All the best.