In this episode of Integrity Insights, host Filip Brokes is joined by Professor Niels Appermont, a professor of economic law at Hasselt University in Belgium, and an expert in sports law. Neils discusses his research into money laundering in football, with a particular focus on Belgium’s fight against corruption and the broader challenges of enforcing anti-money laundering (AML) regulations in the sport.

Niels shares insights into the Operation Zero scandal, a 2018 Belgian investigation that exposed widespread corruption, money laundering, and match-fixing in professional football. The investigation led to reforms in Belgium's legal framework, including the introduction of AML regulations for football clubs.

Key themes discussed:

• The scope of money laundering in football: Neils explains how football has long been a target for illicit financial flows, with many clubs and agents using shell companies, false invoicing, and match-fixing to cover up corruption and illegal activities.
• The Belgian response: After Operation Zero, Belgium introduced AML regulations that cover professional football clubs, making them responsible for client identification, beneficial ownership checks, and monitoring potentially suspicious transactions.
• Key challenges: Neils discusses the practical difficulties Belgian football clubs face when implementing AML measures designed for the financial sector. These include issues with defining who qualifies as a “client” and dealing with the complexity of football transactions such as player transfers and sponsorship deals.
• International lessons: We also compare Belgium’s experience to the upcoming EU-wide AML regulation for football clubs, set to take effect in 2029. Neils explains the key differences and areas where Belgium has been a pioneer in implementing AML measures in football.

Key Takeaways:

• Money laundering in football is a significant problem, but it's hard to quantify due to the opaque nature of the sector.
• Belgium's proactive stance on AML in football makes it one of the few countries in the EU to regulate football clubs under AML obligations.
• Football clubs face unique challenges when trying to implement AML measures due to the complex nature of football transactions and the international scope of the sport.
• The upcoming EU-wide AML regulations for football clubs could lead to a fragmented approach that may not fully address the sector’s risks.

Listen now to explore the intersection of football, corruption, and financial crime and learn more about the evolving regulatory landscape in European football.

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In this episode of Integrity Insights, Filip is joined by Michael Hornsby and Elisabetta Marinoni, researchers working with Transparency International and the Anti-Corruption Data Collective (ACDC), to discuss their new study: the Opacity in Real Estate Ownership (OREO) Index.

The conversation explores how opaque real estate ownership structures enable corruption and money laundering, why data and legal frameworks both matter, and what their assessment of 24 jurisdictions reveals about global weaknesses in this sector.

Key themes discussed:

Why real estate matters for financial crime

Real estate remains a preferred vehicle for laundering illicit funds. High-value transactions and the ability to hide behind corporate structures make it attractive to corrupt actors and criminals.

What the OREO Index measures

The index evaluates 24 jurisdictions, including G20 economies and major financial hubs such as Hong Kong, Singapore, Panama and the UAE.
It assesses two pillars:

• Data – the availability, completeness and openness of property and ownership data.
• Legal framework – the strength of AML rules governing real estate transactions and professionals.

The biggest loophole: missing beneficial ownership data

Most countries do not collect beneficial ownership information when property is registered.
This means properties can be owned anonymously through companies, especially foreign companies, making it extremely hard for authorities or journalists to trace real ownership or identify patterns of suspicious acquisitions.

Cross-border gaps and obstacles for investigators

Foreign companies can often buy property without any local presence, meaning no local BO disclosure. Investigators must then rely on the rules—and cooperation—of the company’s home jurisdiction, which is often limited or opaque.

Cash purchases and absence of gatekeepers

Some countries allow property purchases in cash and do not require involvement of notaries or lawyers.
This bypasses banking-sector AML controls and removes an important oversight layer.

Uneven AML obligations for real estate professionals

While most countries extend AML requirements to real estate agents, developers and lawyers are often excluded, creating entry points for money laundering.
In some jurisdictions, lawyers can even refuse to submit suspicious transaction reports due to client-privilege provisions.

Weak supervision and fragmented oversight

Supervision is often fragmented across many bodies—Germany, for example, has over 300 supervisory authorities in the non-financial sector—making consistent enforcement difficult.

How jurisdictions compare

• South Africa ranks high on paper, but enforcement gaps remain.
• Germany scores well legally but poorly on data transparency.
• Singapore and Hong Kong perform relatively well, though Hong Kong maintains weaker BO rules.
• The UAE scores poorly, reflecting high anonymity and the “open door” model that has historically attracted illicit funds.

Future outlook: risks of backsliding

Despite years of debate, there is still no global consensus that beneficial ownership transparency in real estate is essential.

Read the full report here: https://www.transparency.org/en/publications/opacity-in-real-estate-ownership-index-2025

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In this episode of Integrity Insights, Filip is joined by Daniel Shkedi, Head of Product Marketing and Strategy at Refine Intelligence, a fraud prevention company. He is also a fraud and threat intelligence researcher specializing in cybercriminal activity on the dark web and Telegram. His publications cover a wide range of topics, including online fraud prevention (in banking, eCommerce, and payments), identity validation, emerging threats in underground forums, and AI-driven fraud and eCrime.

The conversation dives deep into the emerging field of Money Laundering as a Service (MLAS) and how cybercriminals are adapting their operations. Daniel provides insights into his research, the typologies of money laundering services offered on the dark web, and why financial institutions need to pay attention to this growing threat.

Key themes discussed:

Money Laundering as a Service (MLAS)
Daniel describes his recent project, where he mapped out how organized criminal groups provide money laundering services to fraudsters on platforms like Telegram and the dark web. This “business” mirrors legitimate financial services in sophistication and scale, making it a rapidly growing problem for financial institutions.

Typologies of Money Laundering
Through his research, Daniel identified several key typologies of money laundering services, including:

• Bank Drops: Rented or sold bank accounts used for cash-out services.
• Bank Loaders: Criminals who move funds onward to bank drop accounts.
• End-to-End Money Laundering Services: Criminal enterprises offering full money laundering packages, including layering and integration.
• Shell Companies and Insider Services: Fraudsters offering to set up fake companies or bank insiders selling stolen financial data.
• Street-Level Cash Outs: Basic services where criminals withdraw funds using stolen or fraudulently obtained bank accounts.

Global Scope of Money Laundering
Daniel shares his findings on how these services are not limited to a single region, but are a global phenomenon. The services are available across North America, Europe, Latin America, Asia, and the Pacific, with different nuances depending on the jurisdiction.

Why Institutions Should Care
Beyond regulatory compliance, Daniel emphasizes that money laundering and fraud expose financial institutions to serious reputational risks, financial losses, and operational disruptions. Criminal enterprises are evolving, and financial institutions must adapt by building proactive threat intelligence programs.

The Role of Threat Intelligence
Daniel outlines how threat intelligence plays a pivotal role in understanding fraud enablers, monitoring their infrastructure, and predicting where future attacks might come from. By gathering data from multiple sources, including the dark web and Telegram, financial institutions can develop comprehensive threat intelligence strategies to stay ahead of cybercriminals.

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