part two of important work

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1INTRODUCTION

Money laundering as a crime only attracted interest in the 1980s,

essentially, within a drug trafficking context. It was from an increasingawareness 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 themoney, 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 Hell’s 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 there’s 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

2Monroe, 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 EastIs Helping Chinese Organized-Crime Gangs To Gain A Lucrative New Foothold In This Lawless Territory” .FarEastern Economic Review. October 02, 2003



III-The Palermo convention, 2000

What’s the role of OECD?

OECD or Organisation for Economic Co-operation and Development whichmainly promote the policies to improve the standard of living of the peoplearound the globe. The relationship of OECD in the issue of moneylaundering in sports is that OECD work hand in hand with Financial Action Task Force to examine the co-operation between tax and anti moneylaundering experts that involved in the sports money laundering. Jointworkshops between OECD and FATF had been carried out to gatherintelligence and share experiences on some common practices of bothparties4.

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 The (40 + 9) Recommendations of the

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

sports law regulations.

Regional Level Sports

International level sports could be divided into two different types which arethe regional competition and worldwide competition. Regional competitionis only open to countries of a certain region for instance: ASEAN which is

4OECD Official Website <Http://Www.Oecd.Org/Pages/0,3417,En_36734052_36734103_1_1_1_1_1,00.Html>

Accessed On: 14 TH

June 20115The (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

http://www.oecd.org/pages/0,3417,en_36734052_36734103_1_1_1_1_1,00.html

http://www.oecd.org/pages/0,3417,en_36734052_36734103_1_1_1_1_1,00.html



only applicable for South East Asian Countries whereas Worldwidecompetition is open to all countries in the world but commonly restrictedwith 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 orstates will be gathering to compete. Common practise is that the winner of the national level competition will be representing the country forInternational Competition. National level sports are for example: Super Bowlin United States for the American football and National Open FencingCompetition in United Kingdom.

BACKGROUND OF THE STUDY

statistics and case name

Thaksin Sinawatra’s case

Roman ‘s chelsea ownerExample 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 thesports 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 isof 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 anti-

money 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 andmore 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 PrimeMinister of Thailand ,Thaksin Shinawatra whom are also famous for theallegation of corruption in his home country and fled to United Kingdomafter the coup de’tat began in Thailand.Subsequently, he had taken over

6Resolution 1993/3o

7 Resolution L994/13

8This Amount Can Be Confirmed By Referring To Http://Www.Deloitte.Com/View/En_Ie/Ie/News/Ie-Pressreleases-

En/8b54bcb8e5cca210vgnvcm2000001b56f00arcrd.Htm

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 theclub 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 incorruption or other illegal proceeds. To add to the funnel of money

laundering in taking over clubs, the famous case of Roman Abramovichwhom currently own the Chelsea Football Club would have been of crossfire when comes to money laundering in sports10.The French authority hadlaunched inquiry into Russian investments in France which includedAbramovich in order to prosecute the Russian investor guilty of moneylaundering.This has been closely related to the activities involving ChelseaFootball Club.As there are an incidentally significant rise of tycoons recentlywhom purchase the major football clubs such as above mentioned as wellas Westham and also the Italian Football Clubs and Bulgarian FootballClubs11.

Nickolay Gigov who is known involving the arm dealings in Bulgaria, ownsLokomotive Sofia of Bulgaria.Aside from football, the latest scandalinvolving money laundering in sports is the Indian Premier league in thesports of cricket. The Indian authority launched investigation and found thereal beneficiaries of Rs. 1.25 million payoff made by the cover companyBritish 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 Islands-based company Park House Holdings Limited for TV rights of the Indian

Premier League (IPL) cricket series. This money is said to be part of theRs42.5 billion ($94 billion) facilitation fee that was allegedly paid for TVrights by Multi Screen Media, Singapore, to Mauritius-based World SportsGroup (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

9 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 R. Tieman, “Abramovich Under Probe” ,Evening Standard.3rd Of June 2005.11

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-Grey-

Area.Offshore-Journals.Com/British-Virgin-Islands-Based-Firm-To-Be-Investigated-By-Indian-

Agencies-500.Html >

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



http://www.iplt20.com/


http://bvi-grey-area.offshore-journals.com/british-virgin-islands-based-firm-to-be-investigated-by-indian-agencies-500.html










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 inMalaysia 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 NHL’s 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 Research15

(Bradsher, 2007; Business Wire, 2008)

16Scully, 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 reports’s 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 OnInvestigations, Committee On Governmental Affairs, Us Senate, Money Laundering: Rapid Growth Of CasinosMakes Them Vulnerable, Gao/Ggd-96-28, P. 4.



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 launderer’s 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).



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 phantomplayers21.“Anecdotal evidence tells us that it [money-laundering] is probably quite amassive problem. We know of transfers of imaginary players by thirdparties and other groups using football in order to wash it and turn dirtymoney 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 Circular 1174 - Fifa Transfer Matching System - Directive From The Fifa Executive Committee21

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-Right-

Direction>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 outsidethe 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 players2) cooperation with non governmental and governmental organization

3) The existence of Player’s 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 world’s 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).

23Conference/Workshop Transparency International,

Henri Roemer Advisor To Uefa’s



SIGNIFICANCE OF STUDY

There are no regulations and unfair advantages

Create awareness in legal fraternities there’s 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. There’re 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 launderer’s 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 onarticles, 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 report’s

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.

part two of important work

Documents