1INTRODUCTION Money laundering as a crime only attracted interest in the 1980s, essentially, within a drug trafficking context.

It was from an increasing awareness of the huge profits generated from this criminal activity and a concern at the massive drug abuse problem in western society which created the impetus for governments to act against the drug dealers creating legislation that would deprive them of illicit gains. In the past, the term "money laundering" was applied only to financial transactions related to organized crime. Today its definition is often expended by government regulators to encompass any financial transaction which generates an assets or a value as the result of an illegal act, which may involve actions such as tax evasion or false accounting. As a result, the illegal activity of money laundering is now recognized as potentially by individuals, small and large business, corrupt officials, members of organized crime (Such as drug dealers or the Mafia) or of cults , and even corrupt States or intelligence agencies ,through a complex network of shell companies based in offshore tax havens. The increasing complexity of financial crime, the increasing recognized value of so-called FININT in combating transnational crime and terrorism ,and the speculated impact of capital extracted from the legitimate economy, has led to an increased prominence of money laundering in political , and economical legal debate. FININT or the Financial Intelligence is the co-operation where the informations about financial entities are gathered and shared, in order, to identify the nature of these companies in interest as well as their intention. It has been largely involved in the curbing of the money laundering activities. FININT has been using the tecnique called the data mining where mass flow of information of certain individuals as well as companies from banking institutions to identify people who are involved in the particular

activities.There are many different Financial Intelligence around the world involving in FININT such as FinCEN of the United States, AusTRAC of Australia as well as FIU of India.The collection of the data by FINNIT will then be taken into scrutiny for any abnormal activities, the sources of the money, the destination of the money as well as the parties involved in the transactions which would most likely to be a great system to look into when it comes to money laundering activities mechanism.

In many jurisdictions, money laundering is seen as an "activity based" offence. According to the Financial Transactions and Reports Analysis Centre of Canada,money laundering is categorised into 3 main areas ; Group based , Financial Activity based and the country based.Group based activites are such as the agenda to money laundering by certain organisation or groups such as mafia or organised crime groups.In Canada for instance, the reknown organised crime group called as the Hells angel and the Mafia was alleged to have attempted to penetrate into the Quebec building contruction industry which have stirred a fear amongs the law enforcement society1. Finacial Activity based has been an area which has been largely infiltrated by the money laundering activities. Financial Activity based money laundering activities are carried by transferring money from different sources via banking institution which largely involved the off-shore banking industry as well as creditor companies.Country based activity could be defined as the activities of money laundering being carried out in certain countries which has deficiencies in the mechanism of curbing money laundering. The Financial Action Task Force (FATF) has came out with an extensive list of seven countries which adds on to the present list of countries that probably cause a risk to the international financial system as
1

"Ftq Construction Union Wants Corruption Inquiry." Cbc News. November 17, 2010.

"Dropping The Hammer On Organized Crime." Ctvmontreal.Ca. October 22, 2009.

they are not able to implement and enforce anti-money laundering as well as combating the uprisingof financial terrorism measures2. Methods of traditional money laundering and reverse money laundering. There are a wide variety of traditional money laundering dated back to even as early as 1920 in United States. Different culture or society of a place would constitute into different method of money laundering.Merchadising laundering has been among the oldest method where precious earth material such as gold and gems are bought and sold at the border of the geographical area.Another method of merchadising laundering is by the way of bartrade trading system where it could be offering method of legalising the money. Secret banking system is another method of money laundering traditionally used. In China, the Chinese invented the simplest form of activity called as fei chien where the dirty money is deposited in a gold shop in Guangzhou where the owner will have it overstamped dollar notes with a mark at the side.It was then presented to the moneychanger in the Chinatown of London where the owner will provide him with the cash of the amount transacted in Guangzhou.3 In India and Pakistan, the method of traditional money laundering is quite alike to the Chinese fei chien where they could launder the money from a place to another in a matter of hours where theres a Hawalah network. In most countries the local laws follow the international conventions. The Most important of these are: I-The Vienna convention, 1988 II-The European council convention, 1991
2

Monroe, Brian. "Fatf Adds Seven To List Of Countries With Poor Aml Controls." Moneylaundering.Com. October 22, 2010. 3 Lintner B,Vladivostok, Spreading Tentacles: An Influx Of Illegal Chinese Immigrants Into The Russian Far East Is Helping Chinese Organized-Crime Gangs To Gain A Lucrative New Foothold In This Lawless Territory .Far Eastern Economic Review. October 02, 2003

III-The Palermo convention, 2000 Whats the role of OECD? OECD or Organisation for Economic Co-operation and Development which mainly promote the policies to improve the standard of living of the people around the globe. The relationship of OECD in the issue of money laundering in sports is that OECD work hand in hand with Financial Action Task Force to examine the co-operation between tax and anti money laundering experts that involved in the sports money laundering. Joint workshops between OECD and FATF had been carried out to gather intelligence and share experiences on some common practices of both parties4. Of my main concern for the purpose of this thesis will be critically evaluating the Financial Action Task Force hereinafter referred to as FATF5 Recommendations and all other regulations in relation to money laundering in sports, to research pitfalls within the current suggested framework with the intention that my research will remedy such pitfalls by providing sound recommendations to the existing framework. Although globally we are moving in the right direction towards combating money laundering with the current FATF recommendations, my thesis would seek to strengthen and solidify the frailness in the area of sports, and is envisaged that my thesis will fill in the gaps that have been left gaping. My thesis main focus and scrutiny will be on the lack of regulation on international sports whereby I shall be examining all pertaining regulations that are related which includes sports law regulations. Regional Level Sports International level sports could be divided into two different types which are the regional competition and worldwide competition. Regional competition is only open to countries of a certain region for instance: ASEAN which is
4

The (40 + 9) Recommendations of the

Financial Action Task Force (FATF), international treaties, conventions and

OECD Official Website <Http://Www.Oecd.Org/Pages/0,3417,En_36734052_36734103_1_1_1_1_1,00.Html> Accessed On: 14TH June 2011 5 The (40 + 9) Recommendations Of The Fatf And The Inception And The Formation Of The Committee At Basel, Switzerland Can Be Accessed At Http://Www.Fatf-Gafi.Org

only applicable for South East Asian Countries whereas Worldwide competition is open to all countries in the world but commonly restricted with qualifying levels.For example: Malaysia Tennis Open . Sports at national level could be understood as sports events which are carried out where the representatives of the different constituencies or states will be gathering to compete. Common practise is that the winner of the national level competition will be representing the country for International Competition. National level sports are for example: Super Bowl in United States for the American football and National Open Fencing Competition in United Kingdom.

BACKGROUND OF THE STUDY statistics and case name Thaksin Sinawatras case Roman s chelsea owner Example and cases IPL My thesis will be critically analyzing the current regulations and policies of international money laundering in sports: 1. That current FATF recommendations are silent in respect to the sports industry and it is this environment that there is evidently a lot of money laundering activities and my thesis will identify such environments and propose further recommendations under the FATF. 2. In addition, the thesis will explore and recommend how anti money laundering policies in relation to the sports industry be incorporated as currently, this industry has little or no regulation. The current

framework is simply silent in this area which is alarming as there is very high activity of money laundering in sports. As such, combating money laundering in the international sports industry is of paramount importance as large amounts of ill gotten money is pumped into this industry which is then successfully laundered and used for other menacing purposes. LITERATURE REVIEW Recent fatf recommendation Example: online gambling in sports sports gambling buy and sell players/payment wages b and s of clubs advertisement/sponsorship merchandise- proof of cases Money laundering, the metaphorical "cleaning of money" with regard to appearance in law , is the practice of engaging in specific financial transactions in order to conceal the identity ,source and destination of money and is a main operation of underground economy and such activity is now evidently being practiced in the sports industry. The international response to the underground economy has been coordinated by the FATF, whose original 40 principles form the basis of almost all international response to money laundering activity. A further 9 recommendations designed to counteract funding to terrorist organizations, were added on June 30,2003 due to the September 11-2001 terrorist attacks, to form what are now known as the (40+9) principles of antimoney laundering and counter-terrorism founding. The law relating to international money laundering is covered under the United Nations Convention against Illicit Traffic in Narcotic Drugs and

Psychotropic Substances of 1988 convention, to give effect to its provisions and the further international efforts against money laundering. In addition, to a number of General Assembly resolution and enact by the European Union and FATF aimed at the development of preventive measures and more effective co-operation between Member States, the Economic and Social Council has adopted supporting comprehensive research and assistance programmers6 and promoting the criminalization of money laundering7, as recommended by the Commission on Crime Prevention Criminal Justice. Sadly there is no mention in any of the recommendations on how to curb money laundering in the international sports industry. This issue of not wanting to meddle into the sport is a big surprise as there is an access of money changing hands in the sports industry with football having the voluminous amounts of money changing hands every other day. Take for example the transfer window for English football alone was in the region of 350 Million Pounds in cash.8 This amount is tranfers of footballers in one summer in England alone. What about the rest of the world football transfers figures? There are many areas pertaining to the sports industry that need to be examined and investigated in the area of international sport in relation to money laundering. The Money Laundering techniques used vary from basic to complex techniques, including the use of cash, cross border transfers, tax havens, front companies, non-financial professionals and PEPs. In many cases, connections with other well-known ML typologies were identified such as trade based ML . One of the limelight case that has involved the reknown ousted Prime Minister of Thailand ,Thaksin Shinawatra whom are also famous for the allegation of corruption in his home country and fled to United Kingdom after the coup detat began in Thailand.Subsequently, he had taken over
6 7 8

Resolution 1993/3o Resolution L994/13 This Amount Can Be Confirmed By Referring To Http://Www.Deloitte.Com/View/En_Ie/Ie/News/Ie-Pressreleases-

En/8b54bcb8e5cca210vgnvcm2000001b56f00arcrd.Htm

the Manchester City football club for 81.6million in total and then sold the club with the profit of 21 million.9 As carefully the scrutiny of the sales of the football club, it would be a manner of money laundering if the alleged 81.6million used by Thaksin to purchase the football club is gained in corruption or other illegal proceeds. To add to the funnel of money laundering in taking over clubs, the famous case of Roman Abramovich whom currently own the Chelsea Football Club would have been of cross fire when comes to money laundering in sports10.The French authority had launched inquiry into Russian investments in France which included Abramovich in order to prosecute the Russian investor guilty of money laundering.This has been closely related to the activities involving Chelsea Football Club.As there are an incidentally significant rise of tycoons recently whom purchase the major football clubs such as above mentioned as well as Westham and also the Italian Football Clubs and Bulgarian Football Clubs11. Nickolay Gigov who is known involving the arm dealings in Bulgaria, owns Lokomotive Sofia of Bulgaria.Aside from football, the latest scandal involving money laundering in sports is the Indian Premier league in the sports of cricket. The Indian authority launched investigation and found the real beneficiaries of Rs. 1.25 million payoff made by the cover company British Virgin Island for the TV rights of the IPL cricket series12. Indian detectives found the real beneficiaries of a Rs1.25 billion (approximately $27 million) payoff that was made to a British Virgin Islandsbased company Park House Holdings Limited for TV rights of the Indian Premier League (IPL) cricket series. This money is said to be part of the Rs42.5 billion ($94 billion) facilitation fee that was allegedly paid for TV rights by Multi Screen Media, Singapore, to Mauritius-based World Sports Group (WSG). examples?, the use of non-financial professionals and NPOs for ML purposes examples?, ML through the security sector, the real estate sector and the gaming sector examples?.13

Tariq Panja And Arif Sharif, Manchester City Owner Agrees To Sell To Abu Dhabi Bloomberg, September 1, 2008. <Http://Www.Bloomberg.Com/Apps/News? Pid=Newsarchive&Sid=A1qqm9gkexwq&Refer=Uk>

10 11

R. Tieman, Abramovich Under Probe ,Evening Standard.3rd Of June 2005. Novinite, Bulgaria:Soccer Symbol Of Organised Crime And Corruption ,Flare Network.19th January 2011.

12

British Virgin Islands-Based Firm To Be Investigated By Indian Agencies. Oct 15,2010 <Http://Bvi-GreyArea.Offshore-Journals.Com/British-Virgin-Islands-Based-Firm-To-Be-Investigated-By-IndianAgencies-500.Html >

13

Money Laundering Through The Football Sector-Fatf Report, July 2009

It is good to be aware that money laundering in sports covers a wide area as the business involving football industry is large.One of the largest industry that have billions of dollars at stake is the advertising industry of the football events. As of FIFA 2006, the expenditure of advertisement in Malaysia only has reached the staggering amount of RM55 million as reported in the year of 200514.The other area of importance is the sponsorship profit that the sports club attained. As recorded in 2001, Manchester United obtained a gross sponsorship profit of 11.1m. Money could be laundered through the sponsorship transaction. Nevertheless, as recent years, a lot of popular football and sports clubs had starting to venture into merchandising and branding where a large sum of money and transaction is recorded. One of the greatest sports association is the NBA which gains a steady merchandise profit from China exceeding $10million annually as for the products sales15 .This has very much proven the massive flow of money in merchandising. It would be wise to actually view into the possibilities of money laundering via this area of business. Not only that, another area of business that sports clubs largely involved is the ticketing revenues, television and radio deals where major clubs will gain a handsome sum of revenues. As the attention to NHLs famous Packers, they were recorded to have generated $147million merely on ticketing , television and radio deals16.This might be an issue of concern especially when there are so many owners or main figure influential in these great sports clubs around the world who are also influential businessmen whom involved largely in the mass media industry such as
14

Nielsen Media Research (Bradsher, 2007; Business Wire, 2008)

15 16

Scully, Gerald W. Sports. The Concise Encyclopedia Of Economics. 2008. Http://Www.Econlib.Org/Library/Enc/Sports.Html

Thaksin Shinawatra as well as other form of economic entities. Money flows that was recorded above opens up the possibility of money laundering.

Another method of money laundering in sports is by the online betting.It has been a recent issue of the sudden booming of online betting website especially in the area of sports which covers NHL, NBA and even the FIFA and UEFA. Betting on games is nothing new but online betting is another issue of a total difference. It provides a great opportunity and avenue for money launderer to launder the money by transferring money online via wire or even online banking and other method. In many cases, there will be a middleman company whom will act to receive the money and create a virtual online cash account where it could be then cash out for betting purposes. This very much gave the opportunity to launder the money as there yet to have restrictions and supervision on the transfer of money for the usage of online betting. The booming of online website conducting betting also arises from the offshore companies which are set up offshore for example in Cyprus and Carribean countries where the control on Anti-money Laundering is not well extended17. Money laundering is often described as occurring in three stages, placement, which refers to the initial point of entry for finds derived from criminal activities. Secondly, the layering, which refers to the creation of complex networks of transactions which attempts to obscure the link between the initial entry point and the end of the laundering cycle and finally, the integration which refers to the return of funds to the legitimate economy for later extraction. Font must be consistent Based on the reportss analysis of the use of the football sector as a vehicle for laundering the proceeds of criminal activities, a variety of money flows
17

General Accounting Office, Report To The Ranking Minority Member, Permanent Subcommittee On Investigations, Committee On Governmental Affairs, Us Senate, Money Laundering: Rapid Growth Of Casinos Makes Them Vulnerable, Gao/Ggd-96-28, P. 4.

involving various financial transactions increase the risk of money laundering.18 These are related to: Ownership of football clubs The transfer market and ownership of players Betting activities Image rights, sponsorship and advertising arrangements PEP- politically exposed person- examples and whether PEPs are involved? The report further suggests that the FATF have over the years compiled evidence of money laundering through the football sector, ranging from simple cases of smuggling large amounts of cash that seem to be derived from illegal transactions, to complex international money laundering cases. These money laundering activities were collected from the responses to the FATF questionnaire, cases presented at the 2008 FATF/MONEYVAL Typologies .The only way in attracting government official in getting the greet on the level of government is through a pseudo business within a professional football team and players transfer, in which it will profit more towards the the official government (Corruption). In doing this, this kind of person (a pseudo businessman) may actually make a direct contact in public interest through the team matches and thus gain a direct command or chain of power among the government officials. We can see below how, is it possible money laundering can actually become a mechanism in Football Sector (Brazil). The purchase of a club, which is vital, whereby the amount of money turnover can flourish the club through facilities, salary of players, amount of players and also the club entities which basically were formed from corrupted money launderers.

18

Ibid, Pg 17

Where a vulnerable manipulation actually stimulate the big turnover of cash in a club by a pseudo business can actually involve political person to be in charge of a club (i.e Thaksin Shinawatra, Roman Abromovich). Most cases identify pure money laundering. Some cases that are presented below also focus on other predicate offences in connection to football.19 PROBLEM STATEMENT Firstly, there are virtually no proper laws in place to combat money laundering in the international sports industry. Most of the laws in most countries only cover the main gate which is banking transactions (limited focus). Although there are stringent measures being introduced in few other areas apart from banking, it can be argued that the international sport industry is nonchalantly used by these money launderers. As such, the FATF recommendations do not cover money laundering activities in international sport. Areas like Ownership of football clubs, the transfer market and ownership of players, betting activities, image rights, sponsorship and advertising arrangements are boasting a preponderance of money laundering activities and authorities are looking the other way, or even where they are concerned, there is simply no blueprint or guide to regulate and combat such activities. This thesis will suggest recommendations to regulate the international sports industry. Secondly, the current regulations in force in international sport law do not have any enforcement measures in place to bring money launderers to justice. There are no security watchdogs that have been set up to seriously monitor the money flows in the international sports industry. This thesis will examine how such recommendations will be slotted in current sport

19

Ibid, Pg 17

policies and what enforcement measures are to be carried out in the event of a money laundering crime in this industry.

In here, we will focus much deeper in the area of Football as football is part f a major entertainment in the world. From money laundering in illegal drug trafficking, human trafficking and many more till the transfer of player in football area, I believe it is crucial for us to investigate this unanswered question. As for the enforcement, today the existence of Financial Action Task Force (FATF) had actually led a crucial development on policies to be incorporated within the member of the countries throughout the World. Again, in my opinion will it be executed? Knowing the fact that each nation is sovereign with its own law and order (Parliament as example in making the law) Here, are some of the discoveries and suggestion I will marked in this paperwork, Scope: First, by checking the policies and international recommendations made by FATF (since we are focusing more in the area of football, the implementation of the policies should be only applicable within the member of the UN or under FATF and not NCCT) Second, by dissecting each of the report by FATF (GAFI) and through there, begin with the banking sector which actually is the co-founding on money laundering activities in football. The resolution between FATF with the World Bank (i.e affairs, objectives, project, implementation and else) .Non-profitable organizations which actually funding the through many occasion (in here sports are also include) wire transfer as well as the insurance (the same in the players transfer for each and every one of the football association).

Third, the law and statutes which govern the International Football, which in this case will be FIFA. Whether the rule in the constitution of the association mention on money laundering activities and purchase of any entities of club, relentless on country.Whether the asset of each one of the club in the world (from infamous to influential and major) has been inspected of its value i.e the source of the club income, the validity of agreement or the activities which allows the income, is it legal or is it not. From the law and policies govern through FIFA, we will then dissect all the law and statute which govern the other Major Football Association, i.e Asian Football Confederacy, Football Association (England), Football Association of Malaysia (FAM) and UEFA. Thus from here we will know what is the law that govern Money Laundering, whether its implemented or was it not. The question, on ownership of club (in basic the from the foundation of the club). In more towards the matter of Finance and activities in controlling it. For all we know, each report (particularly released by FATF) did not mention much on the Sport sector, but it did mention football to be part of major industry in money laundering. How is this possible? Again, by looking through the amount of societies interest in sport or favorite, and football became one of the top sports. With the amount of registered professional players reach 265 million, it is truly to be believed it came in together with the amount of large advertisement, insurance and this does not exclude the factor of ill gotten money for menacing purposes. FIFA effort in combating money laundering FIFA has come out with a new transfer player system which called as the Transfer Matching System or TMS.TMS was made compulsory for all transfer and the clubs will have to key in details of the possible transfer electronically. The details will include the contract details, agent payment and bank details.

The next step is to compare the two sets of data and if any flaw of matching, then the transfer will not be proceeded. One of the motives of TMS is to provide a transparent process of the transfer of players20. The general manager of TMS Mark Goddard added on that TMS was formulated in order to curb money laundering via transferring of phantom players21. Anecdotal evidence tells us that it [money-laundering] is probably quite a massive problem. We know of transfers of imaginary players by third parties and other groups using football in order to wash it and turn dirty money into legitimate funds. Now in a deeper sense of money laundering in football of its reason why to be vulnerable, among the aspect which I discovered is: First, the professionalism in terms of management, this is obvious by looking through on how the management of clubs being handled including the factor being handled by neither inexperienced volunteers nor professional. Second, by recent development of Football associate in many countries, the market became easily penetrable22. Look it through it this way, many secret meetings or maybe a hidden agenda could be done (i.e. with just attending the stadium for a match) and then an agreement which actually allows the money laundering to take place without being apprehended by the authority. Third, the financial status or the need of money by a club. Every club in the world will require their fund. And most of them is in a bad shape in terms of financial, and this will allow them to receive any some of money by any party who are willing to sponsor them. (Another problem in tracing the legality of the money)

20 21

Circular 1174 - Fifa Transfer Matching System - Directive From The Fifa Executive Committee Robin Ooi, Are New Transfer Rules A Step In The Right Direction? <Http://Www.Footballfancast.Com/2010/10/Football-Blogs/Are-New-Transfer-Rulings-A-Step-In-The-RightDirection> 22 Money Laundering Through Football Sector By Fatf Gafi, July 2009

Forth, there are considerable sums of involvement in the transfer market and ownership of players. The amount of money is high, this may cause questionable in terms of the acquiring of money. Not to forget that the money flow that happen rapidly across the world may actually fall outside the control of both National and International market (not to forget mentioning the tax revenue being collecting through selling of tickets, event marketing and so on). Course of direction of this paperwork in Money Laundering of Football: 1. Locate and dissect what did the FATF recommendation actually purports the football industry to do. 2. Locate and thorough check under the Football association in the world (began with FIFA) 3. Understand the concept of money laundering activity in football industry ( from the Law itself) 4. Suggest any course action or any direct method in implementing the law. 5. Cases on ML in Football, the Law, The mechanism/ model to curb the flow in and out of cash 6. Focus more in evaluating the recommendation and what is the significance of such recommendation. 7. Transparency. OBJECTIVES OF THE STUDY (Other regulation in international sports law)to examine the FATF recommendation in international existing regulations and policies to combat

In making out an example, let us look through into the UEFA association in preventing it23, some counter measure in reliance with the FATF GAFI as such include: 1) trafficking young players 2) cooperation with non governmental and governmental organization 3) The existence of Players Ethic 4) Establishment of an Institution or Commission in for each and every club in the world (through respective country or state). 5) Administration of FIFA through the worlds largest Football Regional Association as in AFC, CONCACAF i.e. The main objective of the proposed research is to analyze and critically evaluate the FATF recommendations and other regulations under international sport law in relation to money laundering. Secondly, an improved mechanism model to combat money laundering in the sports industry by the necessary authorities governing international sport law as well as domestic authorities governing national sports law.

SCOPE OF STUDY What is the connections The scope of this study is limited to the regulations/laws available in the international conventions, treaties, the FATF recommendations and internationally recognized sports legislations.The study would also be limited to the cases and laws of anti money laundering with an emphasis of the sports industry post Sept 11, 2001 with reference to the Vienna Convention (1988), The European Council Convention (1991) and the Palermo Convention ( 2001).
23

Conference/Workshop Transparency International, Henri Roemer Advisor To Uefas

SIGNIFICANCE OF STUDY There are no regulations and unfair advantages Create awareness in legal fraternities theres a need to control in this area. How this will be workable - enforcement and mechanism We will implement and modify the mechanism from diff industry First of all, as the above analysis that the present law existed globally does not have a good coverage of a wide variety of issues. Therere no regulations and control towards the possibilities of money laundering in the area of football. There are so many different types of areas in the sports arena that give the opportunists to venture. Hence, this study will absolutely a great pioneering deliverance in giving an awareness to the legal professionals as well as the lawmakers around the world of the current trend of money laundering activities in an area yet to be taken into a full attention. The significance of this study will be to protect, control and supervise international sports law in relation to money laundering. As it stands, the sports industry is experiencing very high activity of money laundering. Current regulations do nothing or provide very little resistance to international money launderers heinous activities. Nevertheless, the study will be deemed to be complete to provide the society the mechanism of enforcement needed to intervene with the ongoing money laundering activities. Suggestions of implementations and necessary modifications to the current law will be provided to heighten the security gates to any further money laundering activities in sports. It is intended to remedy the inadequacy of the current regulations and open the field for further research on its viability. Therefore this legal research will be of great significance and benefit to the international sports industry.

METHODOLOGY As what most of the legal research been done, all the sources would be on articles, journals, encyclopedias, cases, statute, treaties, convention and many more law oriented material which will be required in assistance in an aid of expanding the and reconstructing this paperwork (which include interviews and many more official information gathering throughout the research capability). Despite FATF existence is to curb Money Laundering from becoming a serious threat into many sectors of the world (i.e. sports, economy, business, entertainment, war and else) this is still new to most of the third world country. Thus, in order to understand the FATF GAFI and on how the implication towards the international football (FIFA,AFC,UEFA,FA English) we must dissect the content of the regulations of the Football Association and also the FATF recommendations (40+9) of its adaptation. Is it applicable with the policy or not, it will be the amount of sources which will be acquired to make a deep research in answering this method. Thus, within a restricted amount of sources and also insufficient amount of expertise in this area, it is still possible to actually find new discoveries or method for legal reform to be made. Furthermore, data information which had been conceived will actually form a new extensive area which some may not be able to cover. In order to establish, a clear explanations to all the legal research been done inside this paper work, a guidance and also an analytical skills in comparison can actually make it possible to achieve the target. Many more cases and references in law particularly can be adjust in a point of economics view to know the extra details. In engaging the problem, an appropriate legal studies should be done in extracting on how Money Laundering affect the world with its issue (i.e drug trafficking, human trafficking). All the sources, whether primary or

secondary was supplement in this paper to stimulate a much more decisive and accurate result. With a proper preparation and understanding in this area, not to forget more guidelines to be obtained, a guide as addition can actually make it possible. A better insight of this paper can only be done, if more field work, interview, legal issues and problems to be identified by implementing both the FATF GAFI and FIFA regulations (this can also mention football clubs) into a test. By doing this, a test can actually make it possible for the paper work to know the foundation and core for this problem. It is the aim of this paper work to explore the complexity of a dangerous act which threatening the world without realizing its major damage for the development of a clean and zero corruption. The methodology for this research work is essentially library based, i.e. analytical and qualitative. Materials are sought to be obtained from available literary works which include books, papers, articles and internet sources. For each of the sources used, relevant and unbiased works will be consulted to ensure the dependability of this research. The overall methodological approach of the study will involve three components: data collection and analysis; review of documentation and literature. The data collection and analysis forms a critical empirical basis for the reports overall conclusions. Hence the study of the relevant Protocols and Conventions, the relevant statutes related to AML and CFT, the relevant international sports regulations as well as the data and figures collected from studying recent cases being heard in the courts of law shall assist in the discovery of the adequacy or inadequacy of the current regime.

CONCLUSION International Sports Law as it stands today is an easy prey for money launderers as there are no proper regulations and enforcement measures being practiced. As demonstrated, the cash changing hands in this industry is by far one of the biggest and as a result money launderers are very attracted to wash their money over here. It is because of this, it is vital that this industry be tightly regulated with the most viable enforcement measures introduced so that money launderers will not be able to exploit this very commercial and reputable industry. As what had been suggested on the reference before, and also some alternatives, FATF report and FIFA regulation should be dissect and be pin point the exact allocation in making it possible for Money Laundering to be eradicated. A total eradication is not possible. But, the least on the source would have able to stop the critical impact on Money Laundering. By reducing the activities the possibility of curbing it also may actually curb terrorism financing (i.e the supply of weapon during cold war in 1980s between the United State and Soviet Union, in Afghanistan can be related into this matter. How? the involvement of International laws and existence of of treaties had actually made Money Laundering to get a hold in international sector, including entertainment, and this case in Football.