The 2026 World Cup Draw: A New Risk Map for UK Sanctions and AML Compliance

From the perspective of a United Kingdom lawyer, the 2026 World Cup, hosted by the United States, Canada, and Mexico, is much more than just a global sporting event. With forty eight teams, sixteen host cities, and large amounts of money moving quickly across borders, it presents a complex, multi jurisdictional challenge for sanctions compliance, anti money laundering requirements, and professional conduct obligations. 

The central question is not simply which teams have qualified, but which higher risk countries are present, where the movement of fans and finances will cluster, and how the structure of the tournament may concentrate risks at particular locations and during specific periods. One effective approach is to view this as a league of countries with elevated risk operating beneath the tournament, setting the landscape for financial crime exposure.

At the top of this league are countries on the Financial Action Task Force’s call for action list along with those subject to broad sanctions by the United States, the European Union, and the United Kingdom. For 2026, Iran is a prime example. The Financial Action Task Force has placed Iran on its black list and has called for strict countermeasures due to major shortcomings in anti money laundering, efforts to counter terrorism financing, and measures against financing the spread of weapons. At the same time, Iran faces widespread sanctions that cover banking, energy, shipping, and other sectors, and it appears on the United Kingdom, United States, and European Union sanctions lists. 

For United Kingdom lawyers, any link to Iran must be assessed under your own firm’s risk framework, the United Kingdom sanctions regime, guidance from the Office of Financial Sanctions Implementation, and the Money Laundering Regulations.

Iran’s involvement in the tournament is likely to lead to a mix of entirely legitimate and potentially questionable financial flows. This may include travel, accommodation, logistics, team operations, hospitality, sponsorship, media rights, and personal spending by officials or associated people. Because direct banking channels are limited, funds linked to Iran may move through regional intermediaries, front companies, informal value transfer networks, or digital currencies. For example, a national football federation may end up paying a North American hotel using a company from a different country, or a cultural organisation may send money for fan engagement projects through an offshore account. 

Even if the main purpose, such as buying tickets, booking hotels, or arranging corporate hospitality, is legitimate, the path the money takes can be unclear. For any United Kingdom regulated firm, any matter involving a connection to Iran should be considered high risk as a starting point. This requires thorough screening for sanctions, detailed analysis of beneficial owners, and clear records that can stand up to review from both the Solicitors Regulation Authority and the National Crime Agency.

In the next tier down are those countries on the Financial Action Task Force’s grey list that have qualified for the tournament. These are jurisdictions the Financial Action Task Force says are under increased monitoring due to weaknesses in their anti money laundering and counter terrorism financing measures. At this point, three grey listed countries are expected at the 2026 tournament: Algeria, Côte d’Ivoire, and Haiti. Common issues in these locations include lack of transparency regarding beneficial ownership, limited supervision of banks and professionals in relevant sectors, and weak enforcement. For United Kingdom lawyers, this does not mean avoiding all work related to these countries, but it does mean heightened awareness. Criminals have more opportunity to take advantage of your practice or your clients, especially as the World Cup increases transaction volumes and cross border payments.

In practice, these grey listed countries bring many challenges that are well known in anti money laundering work. There will be greater volumes of remittances and fan travel, much of it moving through money transfer businesses, small financial institutions, and informal networks where controls may not be reliable. Communities from these countries living in the United Kingdom, continental Europe, and North America may use the event as a reason for large transactions, such as buying property, luxury items, or expensive travel, where the origin of the funds can be difficult to verify. For lawyers in the United Kingdom dealing with property or private client matters, this may show up as new instructions funded by or linked to individuals or entities from these countries and their expatriate communities. 

There may also be politically exposed persons, high level officials, leaders of state owned enterprises, and their associates visiting as part of delegations, sponsor groups, or business entourages. All of these scenarios require increased diligence and a risk based approach, as required by the Money Laundering Regulations. It is important to avoid both indiscriminately turning away work and being complacent.

Beyond the Financial Action Task Force lists, every institution and law firm in the United Kingdom with anti money laundering obligations will have a third group of other countries considered relevant to risk, based on the United Kingdom’s National Risk Assessment, various indices measuring corruption, local sanctions, and experience within the firm itself. Some countries in this group will also be represented at the tournament. The concept of a high risk league gives focus by identifying a small set of countries flagged by international authorities that are expected to generate dense clusters of financial activity at clearly defined times and in specific locations because of the tournament. For lawyers in the United Kingdom, this model can help in discussions with clients and compliance teams around why certain client instructions or money flows get extra scrutiny.

The actual draw for the World Cup is where these concerns become operational. Once the groups and venues are confirmed, it becomes possible to see which high risk countries will be associated with which host cities, on what dates those places will face especially high demand, and which payment corridors are likely to show increased activity. If, for example, Iran’s group will play mostly in two United States cities, you can expect a surge in visa fees, travel arrangements, hotel bookings, and spending focused on those cities, often by means of funds routed through third country accounts. If Algeria or Côte d’Ivoire are scheduled to play in certain major North American cities, you can expect increased financial flows from those countries and their huge communities living abroad, with growing demand for short term rentals, hospitality services, and foreign exchange. Criminals make use of the volume of legitimate activity to hide their own deals. In effect, the fixture list of the World Cup serves as a timetable for both those seeking to exploit weak controls and those tasked with detecting such threats.

This timetable coincides with other recognised categories of risk. Illegal betting markets, much of them controlled by organized crime, regularly act as channels for money laundering. The SOGA operations undertaken by INTERPOL have found repeated patterns of illegal football gambling and its links to laundering around global tournaments. Holding a forty eight team World Cup in three countries, with participation from countries subject to Financial Action Task Force black or grey lists, creates a major risk for this type of activity. This is especially true if funds route into or through high risk countries or affiliated intermediary jurisdictions. Most law firms in the United Kingdom will not be handling betting money directly, but they may see client accounts, company structures, or disputes that are actually funded by gambling proceeds.

The real challenge for United Kingdom lawyers is to turn this concept of a high risk league into practical steps for daily work. The first step is aligning your firm’s internal country risk model with this tiered structure. Countries on the Financial Action Task Force’s black list and those under heavy sanctions, such as Iran, should be automatically graded as highest risk, requiring additional detailed diligence and sign off at partner level for new matters. The second tier should cover present grey listed countries like Algeria, Côte d’Ivoire, and Haiti, with stronger risk scores, more demanding requirements for the evidence of a client’s wealth and the source of their funds, and a lower appetite for doing work that carries these types of risks. The third tier will be other high risk countries as flagged in the United Kingdom National Risk Assessment and from your own case history. It is a good idea to state clearly in your firm’s risk assessment how the World Cup will temporarily increase your exposure to all three tiers through extra movement of people, cash, and cross border activity.

Another sensible approach is to look at each new matter and ask if there is a connection to the World Cup during the months leading up to and including the tournament. When new client work arises, ask whether the client, counterparty, or their business is a national federation, a sponsor, an agent, a media partner tied to a country in the high risk league, or a travel, ticketing, concierge, or events company serving fans or teams from those countries. 

Also consider charities and non governmental organisations raising money for or partnering with projects related to the event. If there is a World Cup connection, take additional steps to understand the ownership and control, check for sanctions, and weigh whether the ownership structure and money flows make sense. Sometimes, it may be best to refuse a client or mandate, while in other cases, you may proceed if you can clearly document how you are mitigating the risk and file a report to the National Crime Agency if appropriate.

It is equally important to remember that United Kingdom lawyers, conveyancers, estate agents, and providers of corporate services are regarded as designated non financial businesses and professions. As a result, they are attractive targets for those looking to move money that comes from higher risk sources. In the specific context of the World Cup, these risks could include buying property in host cities or international cities paid for out of entities registered in high risk countries, business vehicles created to own hospitality privileges or tournament related assets, or vague consultancy or marketing agreements with bodies that are linked to governments in the top risk category. Your tiered approach to country risk should drive decisions about which matters to accept and the detail required in verifying the origins of both wealth and funds, all in keeping with your regulatory and professional responsibilities.

Viewed in this way, the 2026 World Cup fixture list is much more than just a set of scheduled matches. For United Kingdom lawyers, it should be seen as an evolving map of concentrated risk by country. A small group of especially high risk countries will bring increased anti money laundering and sanctions exposure into already intricate North American financial systems. You can expect surges in transaction volume, cash use, and the movement of funds across borders in ways and at times that are both predictable and relevant for lawyers in London, Manchester, Edinburgh, or anywhere else in the United Kingdom. 

There is no doubt that criminals will seek to exploit this rush, whether through illegal betting, the use of complicated company structures, or inappropriate use of travel and hospitality arrangements. The firms that handle this most effectively will not react with alarm. Instead, they will rank countries following the high risk league approach, apply this to the draw and match schedule, and adapt their client onboarding, due diligence, and ongoing checks as needed. By doing this, you reduce your own risk and are far better placed to answer regulators, your professional body, or your compliance officer when asked how you managed what is likely to be one of the largest anti money laundering real world stress tests of the decade.