The Financial Conduct Authority has pressed football clubs—including many in the Premier League—to treat shirt sponsorship deals with crypto exchanges and trading platforms as regulated-market business, not mere marketing. In a June letter and accompanying press campaign, the watchdog said unauthorised firms may be using badge prestige to reach fans with products that cannot legally be promoted in Britain, and that clubs themselves could face criminal and money-laundering risk if due diligence fails.
What the FCA actually said
The regulator's public release stressed that a logo on a shirt means the firm paid for placement—not that the FCA has authorised the underlying business. Director of consumer investments Lucy Castledine argued fans trust their club's crest and should use the Firm Checker before buying financial products tied to sponsors. The FCA expects ongoing diligence, not a one-off legal review at contract signing, and said it has already contacted clubs where it identified concerns.
Reuters reported that unauthorised platforms may breach financial promotion rules despite high-profile partnerships, exposing clubs to reputational damage as well as legal liability. Freeths' client note on the letter warned that club-produced content promoting a partner's tokens or trading apps could itself constitute an unlawful financial promotion under the Financial Services and Markets Act 2000, separate from the sponsor's own adverts.
Due diligence the FCA wants
Global Regulation Tomorrow summarised the steps clubs should take before renewing or signing deals: verify FCA authorisation or anti-money-laundering registration, search the Warning List, assess geo-blocking and financial-promotion approval chains, and scrutinise whether sponsorship funds could be criminal property under the Proceeds of Crime Act 2002. The FCA is also coordinating with the Premier League and the emerging Independent Football Regulator, whose licensing window opens later in 2026.
IFR and information sharing
Commentary from Global Regulation Tomorrow notes that information gateways between the emerging Independent Football Regulator and the FCA mean sponsorship choices may feed licensing decisions when the IFR application window opens in November 2026. Clubs treating sleeve deals as pure commercial revenue may find regulators treating them as conduct data.
Why crypto keeps appearing on kits
Industry surveys cited in law-firm briefings suggest a large share of Premier League clubs have held at least one crypto or trading partnership as firms chased visibility before the UK's broader crypto authorisation regime fully bites in 2027. The FCA's intervention is preventive: it wants boards to show red cards to partners that cannot demonstrate lawful UK operations.
Proceeds of Crime angles
Law-firm notes on the FCA letter highlight Proceeds of Crime Act risk if sponsorship cash originates from unlawful promotions abroad that are merely laundered through a UK-facing brand deal. Clubs are not banks, but boards still need source-of-funds narratives that would satisfy a suspicious activity review. The regulator's Warning List remains the quickest public screen for partners that have already drawn scrutiny.
What security and compliance desks should track
The FCA has not published a charge sheet against individual clubs; instead it has created a paper trail that will matter if fans lose money after clicking a sleeve QR code. Compliance officers should archive sponsor attestations, monitor partner marketing in UK geos, and escalate any Warning List hits to the board audit committee. Fans deserve clarity; clubs need defensible files before the next transfer window brings another wave of crypto logos—and before the Independent Football Regulator starts sharing information with Threadneedle Street.
The June press release remains the authoritative public statement: unauthorised firms must not use badge prestige to sell products in Britain, and clubs share responsibility for checking partners before kick-off. Retail investors should still use the Firm Checker and Warning List regardless of what appears on a shirt. The FCA said it will act where action is needed, but the public materials stop short of naming individual clubs as wrongdoers.
