Player Image Rights Manipulation

Criminals manipulate licensing or sponsorship contracts tied to an athlete’s image to disguise illicit funds. Offshoring and shell companies are often employed to conceal beneficial ownership or the origin of the proceeds, giving the appearance of legitimate endorsements or royalties for laundering purposes. In many instances, clubs in financial distress or seeking to attract star athletes accept inflated fees for image rights deals, even though the underlying commercial exploitation may be minimal or nonexistent, thereby legitimizing criminal proceeds. Criminals also create or leverage third-party ownership structures—often referred to as talent pools—and route funds through multiple entities to obscure ultimate beneficiaries and hamper AML scrutiny. By funneling fees through offshore accounts or secrecy-prone jurisdictions, they layer transactions and integrate illicit proceeds into the legitimate sports economy. Additionally, criminals sometimes transfer a player’s image rights to corporations in tax havens, structuring deals that disclaim any true commercial exploitation while funneling illicit funds as purported licensing fees. Because there are no consistent accounting rules for these transfers, clubs or intermediaries can easily conceal suspicious activity. Investigations also indicate that criminals may fully simulate or overvalue sports sponsorship arrangements to move illicit proceeds while minimizing scrutiny. The self-regulated nature of professional sports, together with limited oversight of sponsorship or endorsement agreements, exacerbates these vulnerabilities and complicates efforts to trace the true source of funds or identify real beneficial owners.

[
Code
T0129.001
]
[
Name
Player Image Rights Manipulation
]
[
Version
1.0
]
[
Parent Technique
]
[]
[
Risk
Customer Risk, Jurisdictional Risk
]
[
Created
2025-02-12
]
[
Modified
2025-04-02
]

Player Image Rights Exploitation

Tactics

ML.TA0009
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Illicit proceeds are formally introduced into the legitimate sports economy as purported licensing or sponsorship revenues, effectively mixing criminal funds with lawful capital through inflated or fictitious image rights transactions.

Risks

RS0001
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Customer Risk
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Criminals exploit the opacity of beneficial ownership in shell companies and complex third-party ownership arrangements tied to player image rights. By disguising illicit proceeds as inflated or fictitious licensing fees, they obscure the ultimate controllers of the funds and evade AML scrutiny. This reliance on convoluted ownership structures is the central vulnerability enabling the laundering scheme.

RS0004
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Jurisdictional Risk
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Offshore or secrecy-prone jurisdictions are deliberately used to host shell companies and bank accounts, facilitating opaque contracts, layered ownership structures, and minimal disclosure requirements. This cross-border aspect compounds the core vulnerability by further obscuring the provenance of illicit funds.

Indicators

IND00311
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Disbursements for athlete image rights deals made in repeated round amounts or structured payments that deviate from standard sports contract norms.

IND00337
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Athlete image rights contracts with fee structures that do not align with the athlete’s established public profile or market exposure, lacking a clear commercial rationale.

IND00359
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A cluster of high-value athlete image rights transactions in a short timeframe, structured to move funds while appearing as legitimate sponsorship or endorsement deals.

IND00513
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Sponsorship or endorsement arrangements with no corresponding public promotional activity or marketing campaigns, indicating the absence of genuine commercial exploitation of athlete image rights.

IND02873
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Licensing, sponsorship, or endorsement contracts that significantly exceed typical market benchmarks and the athlete’s historical earnings, indicating artificially inflated contract amounts.

IND02874
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Frequent or rapid changes to athlete image rights contract terms beyond normal negotiation patterns, enabling repeated adjustments to payment amounts.

IND02875
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Use of legal entities or intermediaries with no demonstrable business activity or beneficial ownership transparency to process licensing, sponsorship, or endorsement payments.

IND02876
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Use of offshore accounts or secrecy-prone jurisdictions for athlete image rights payments, hindering identification of the true source or final beneficiary.

Data Sources

  • Provide official filings such as financial statements, profit-and-loss reports, and tax returns of clubs and intermediaries.
  • Permit verification of declared endorsement or licensing revenues against actual commercial activities, uncovering discrepancies.
  • Detect potential tax irregularities and unsubstantiated income streams, indicative of inflated fees or nonexistent commercial exploitation tied to image rights deals.
  • Involves publicly available information from websites, social media, and news outlets.
  • Helps confirm whether any genuine promotional or marketing campaigns actually occurred, thereby detecting fabricated or nonexistent sponsorship activities used to launder illicit funds.
  • Contain detailed clauses, fee structures, and invoice data relevant to athlete image rights agreements.
  • Help verify whether stated licensing or sponsorship fees are consistent with the athlete’s market value, uncovering inflated or fabricated payments used to disguise illicit funds.
  • Encompass contracts, amendments, and other legally binding agreements.
  • Allow scrutiny of frequent or unusual changes in athlete image rights contract terms that facilitate repeated adjustments to payment amounts or ownership structures, indicating potential manipulation.
  • Provide comprehensive records of financial transactions and account details, including timestamps, amounts, currencies, and parties.
  • Enable detection of repeated round amounts, structured payments, or clusters of high-value deals in short timeframes, revealing potential layering or other suspicious patterns tied to inflated image rights payments.
  • Documents cross-border financial flows, including involved jurisdictions and intermediary banks.
  • Helps track offshore payment routes and identify secrecy-prone regions, exposing layering or other steps undertaken to obscure the origin of illicit funds in image rights deals.
  • Provide details about the true owners, shareholders, directors, and registration status of companies or intermediaries.
  • Assist in identifying shell entities or opaque ownership chains used to conceal beneficial owners involved in image rights manipulations.

Mitigations

Classify jurisdictions with weak corporate transparency laws or a record of sports-related financial misconduct as high-risk for image rights transactions. Impose enhanced scrutiny or service limitations on any deals routed through these markets to reduce their utility for layering illicit proceeds. By assessing jurisdictions prone to secrecy or lax oversight, institutions can preemptively mitigate fraudulent image rights activities.

Perform specialized Enhanced Due Diligence (EDD) on clubs, sponsors, or intermediaries involved in high-value athlete image rights transactions. Cross-verify beneficial owners using official and external registries, verify the commercial legitimacy of purported promotional or licensing activities, and scrutinize fee structures for unusual markups. This approach uncovers concealed ownership layers, reveals inflated contract valuations, and addresses the risk of laundering funds through manipulated image rights deals.

Configure rules to flag recurring or structured image rights payments, especially when amounts deviate significantly from known market rates or when payments originate from secrecy-prone jurisdictions. Investigate abrupt contract amendments or short-interval payouts that suggest layering. By focusing on unusual payment patterns and non-transparent counterparties, institutions can detect illicit funds disguised as legitimate sponsorship or endorsement deals.

Apply rigorous due diligence to third-party entities brokering athlete image rights, focusing on their ownership structures, organizational transparency, and documented business operations. Mandate AML clauses in contracts, conduct periodic reviews, and require evidence of legitimate marketing or talent management activities. This prevents criminals from using opaque middlemen or shell companies to funnel illicit funds under the guise of image rights arrangements.

Leverage open-source intelligence and external records to confirm genuine promotional campaigns, media coverage, or other public evidence supporting the legitimacy and scale of athlete image rights agreements. Compare contracted fees against established market benchmarks for the athlete’s public profile and performance history. This helps identify artificially inflated valuations or nonexistent commercial exploitation commonly used to launder illicit proceeds through image rights.

Regularly reassess existing athlete image rights contracts and payment flows to ensure they align with the stated commercial rationale over time. Investigate abrupt fee escalations, repeated amendments, or the introduction of unverified offshore entities. Continuous monitoring of contract terms and beneficiaries ensures that criminals cannot systematically launder illicit funds by repeatedly adjusting or renewing image rights agreements.

Instruments

  • Criminals route inflated or fictitious image rights fees through bank accounts, often located in offshore or secrecy-prone jurisdictions. This enables the layering of illicit funds within routine financial transactions.
  • By commingling purported sponsorship or royalty income with legitimate deposits and withdrawals, criminals obscure the true source of the funds, complicating AML detection efforts.
  • Criminals establish or utilize shell companies or 'talent pool' entities that hold player image rights. By controlling equity stakes through nominees or layered structures, they conceal beneficial ownership.
  • They then route inflated payments for image rights through these entities, presenting them as legitimate investments or shareholder returns, effectively integrating illicit funds into the sports sector.
  • Criminals re-characterize illicit funds as legitimate licensing or endorsement fees for an athlete’s name, likeness, or brand. By inflating or fabricating these IP rights agreements, they disguise illegal proceeds as purported royalties or sponsorship income.
  • The lack of standardized accounting rules allows suspicious payments to flow through clubs or intermediaries under the guise of commercial IP transactions, effectively layering illicit funds into the sports economy.

Service & Products

  • Criminals transfer or deposit purported image rights earnings into accounts located in secrecy-friendly jurisdictions, layering funds and masking their origin.
  • The limited transparency associated with offshore banking hinders regulators from detecting anomalous or inflated player image rights transactions used to launder illicit proceeds.
  • Criminals register companies in secrecy-prone or offshore jurisdictions under the pretext of legitimate talent or endorsement management.
  • These offshore entities receive illicit proceeds disguised as legitimate licensing or sponsorship fees, making it harder to trace the true source and beneficiaries of the inflated payments.
  • Criminals form or manage shell entities and nominee structures to camouflage the signatories of sponsorship or image licensing contracts, making it difficult for authorities to identify the true owners of the funds.
  • These structures mask beneficial ownership when channeling inflated or fictitious image rights fees, hampering transparency in the sports sector.

Actors

Athletes may be aware or unaware that their image rights are used to channel illicit funds. The commercial appeal of their brand provides a plausible cover for inflated licensing or sponsorship arrangements, making it harder for financial institutions to detect suspicious transactions.

Criminals deliberately manipulate athlete image rights contracts to disguise illicit proceeds. They establish or exploit third-party ownership and offshore structures, routing funds through secrecy-prone jurisdictions to obscure the true beneficiaries. Financial institutions face increased difficulty detecting the disguised nature of these fees, which appear as legitimate endorsements or royalties.

Criminals incorporate or use shell companies—often registered offshore—to receive artificially inflated licensing or sponsorship fees. These entities obscure the ultimate ownership of funds and mask the illicit sources, undermining financial institutions' ability to trace transactions or identify real beneficiaries.

AT0069
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Some clubs, particularly those aiming to attract star players or address financial issues, accept overvalued image rights fees. This practice allows criminals to disguise illicit funds as legitimate payments, complicating financial institutions' oversight of these transactions.

References

  1. Financial Action Task Force (FATF). (2009, July). Money laundering through the football sector. FATF. https://www.fatf-gafi.org/en/publications/Methodsandtrends/Moneylaunderingthroughthefootballsector.html

  2. FATF (Financial Action Task Force). (2021, July). Money laundering from environmental crime. FATF. https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Money-Laundering-from-Environmental-Crime.pdf.coredownload.pdf

  3. Cindori, S., Manola, A. (2020). Particularities of anti-money laundering methods in football. Emerald Group Publishing. https://www.emerald.com/insight/content/doi/10.1108/jmlc-09-2019-0075/full/html

  4. De Sanctis, F. M. (2014). Football, Gambling, and Money Laundering: A Global Criminal Justice Perspective. Springer. https://doi.org/10.1007/978-3-319-05609-8