The FCA’s 3 June warning was aimed mainly at football clubs in the Premier League. It focused on sponsorship arrangements with financial firms that lack FCA authorisation to provide or promote financial services to UK consumers.
The regulator said it believes some of the unauthorised crypto firms and trading platforms may be using football partnerships to target fans. A club badge, a sleeve logo, or a pitchside advert can provide a company with a level of trust it has not been given by regulation.
Regulator Puts Sponsor Money Under Review
That brings about two risks at once. Fans could use a product without the usual protections in the U.K. There may also be questions for clubs about how they vetted the sponsor before agreeing the deal.
The FCA has written directly to football clubs and said it is engaging with the government, the Premier League, and the Independent Football Regulator.
The Legal Risk Is Wider Than Branding
The alert is not only about reputational harm. The FCA also said some firms may be providing regulated services without authorisation or making unauthorised financial promotions.
These matters are regulated by the Financial Services and Markets Act 2000. The regulator has also expressed a separate financial crime worry. Benefits obtained through unauthorised regulated activity or unlawful promotions may constitute criminal property under the Proceeds of Crime Act 2002.
That makes a difference in the tone of the debate. A sponsorship agreement should not simply be regarded as clean revenue because the contract is straightforward.
Clubs, meanwhile, have to guard their own media output. A post, campaign page, or video about a sponsor’s product can itself become a financial promotion if it prompts fans to sign up for the service.
What Clubs Need to Check
The FCA expects clubs to confirm whether the sponsor is FCA-authorised or relies on an exemption. Among other things, it wants clubs to know what the sponsor is selling.
Access controls are part of the same check. If a sponsor declares it does not have British users among its targets, geo-blocking, disclaimers, onboarding checks, monitoring may be relevant.
The regulator also referred clubs to its Firm Checker and Warning List. But it added a key warning: Non-inclusion in the Warning List does not mean a company is operating legally. Clubs may nonetheless require separate legal advice.
Football Faces a Wider Sponsor Test
The FCA letter is set against a separate debate about unlicensed gambling sponsors within the English game. Entain recently called upon the newly established football regulator to prevent clubs from taking money from betting firms that do not possess a licence in the UK.
The two disputes differ under the law. One involves financial services. The other is related to gambling law. However, the pressure for clubs in practice is similar.
Football clubs are being asked to show that sponsor money does not expose fans to unlawful or high-risk financial products. That’s a higher standard than many commercial teams have had in the past.
Takeaways
The net effect is likely to be a slower sponsor approval process and more legal review of deals before they are signed. Clubs that treat this as a paperwork exercise might miss the larger issue. Sponsor due diligence in UK football is becoming part of fan protection and board-level risk management.
