Category: 3. Business

Trevor Watkins and David Thorneloe of Pinsent Masons were commenting after the IFR opened a consultation on establishing the new licensing regime.

This consultation seeks views around how the licensing process will operate and about the relevant documentation clubs will need to compile when applying for a licence.

Clubs will need to apply for their first licenses by February 2027. Unless one is granted to them by the start of the 2027-28 season, they will be unable to field a team that season. A provisional licensing regime will operate initially, providing clubs with a window of three years from being granted a provisional licence to meet the conditions of a full licence.

The IFR will set clubs a set of mandatory conditions to meet to become fully licensed, including around financial planning, corporate governance and fan consultation. The IFR will have powers to impose further discretionary conditions on individual clubs if they are considered “at risk” – including, for example, specific steps and monitoring to restrict their expenditure.

Included in the consultation paper are the IFR’s proposed principles to shape its approach to financial regulation – an issue brought into sharp focus recently by the situation at Sheffield Wednesday.

With those principles, the IFR endorses the concepts of forward-looking risk management and board-level responsibility for financial soundness of clubs and puts an emphasis on financial reporting to help clubs manage their own risks.

These principles are all reflected in some of the licensing obligations clubs will face. For example, to support their application for a provisional licence, clubs will be expected to prepare, among other things, a strategic business plan, which will need to include a forecasted profit and loss statement, balance sheet and statement of cash flows, as well as details on the source of funding. Clubs will also be expected to answer “standardised questions” on issues such as their business operations, fan engagement and corporate governance, and include “forward-looking information” – including about their finances – that covers up to the end of the 2027-28 season.

In relation to financial regulation, the IFR also made clear that it will not take a ‘one-size-fits-all’ approach, instead promising to “set high level expectations that clubs can apply in ways best suited to their own business models” and to tailor its intervention to address “specific risks”.

The IFR intends to focus its resources on clubs it considers to be at greatest risk of financial distress and failure and, while it said its “focus will be on prevention and addressing the root causes of financial instability, rather than penalising clubs”, it gave examples of licence conditions it could decide to impose on clubs in financial distress. These include requiring clubs to maintain a cash liquidity buffer in a separate account; placing limits on debts that clubs can incur; and placing restrictions on a club’s expenditure.

More detailed rules and guidance regarding financial regulation will be developed for separate consultation in 2026.

Watkins led a fan buy-out of AFC Bournemouth in 1997, when the club faced bankruptcy, and went on to become club chairman and a divisional director to the EFL board. He said English football is on the cusp of a major regulatory overhaul. Having established Supporters Direct with the UK government, Watkins believes the IFR creates a tipping point for owners, investors, funders and executives of clubs,

“The new regulatory regime represents major change for the football industry in England,” Watkins said. “While the action continues apace on the pitch, football clubs in England have work to do off it to prepare for the new regime taking effect next season. As the IFR’s consultation makes clear, there are significant steps to take to meet the new licensing requirements which are intertwined with the financial regulations that clubs will also be subject to. The current investment, financial and operational models of clubs are going to be tested and with real consequences if breaches occur.”

The IFR will take over the main responsibilities for regulating the finances of football in England from the footballing authorities. The establishment of the IFR is provided for under The Football Governance Act 2025, which came into force during the summer.

The IFR’s main objective is to ensure the financial stability and sustainability of English football, ensuring that clubs have sound corporate and financial governance in place. In total, 116 clubs across the Premier League, the Championship, and divisions one and two of the English Football League (EFL), as well as the National League, are subject to its oversight. Safeguarding ‘the heritage of English football’ is also a statutory objective of the IFR.

While the Act sets the framework for independent regulation, the detailed rules and requirements for the new regulatory regime will be set out by the IFR. The regulator has already been consulting on different aspects of the new regulatory framework that will operate – including now the licensing regime.

Thorneloe, who specialises in public law, said: “The IFR’s statements make clear it intends to focus its efforts on monitoring clubs most closely where there is evidence a club is in financial distress, or at risk. Its consultation offers clubs an opportunity to influence the new rules and guidance, to ensure the IFR takes a sensible and pragmatic approach.”

Squire Patton Boggs has advised JTC PLC on the acquisition of Kleinwort Hambros Trust Company (CI) Limited and its subsidiaries from Swiss private bank Union Bancaire Privée (UBP). The acquisition, which was first announced in July 2025, completed on 31 October 2025 following receipt of change of control and other regulatory approvals.

The Squire Patton Boggs team advising JTC on the transaction was led by London Corporate director James Bradshaw and partner Julian Thatcher, assisted by Isabelle Sadler, Tom Currie, Sim Basran and Hetty Tomlin.

FTSE-listed JTC is a global professional services business with deep expertise in fund, corporate and private client services. This latest acquisition for JTC’s Private Capital Services division will bring further scale to its operations in the Channel Islands and the UK, including adding a UK trust business for the first time, and reinforces JTC’s market position as the leading independent provider of trust services globally.

The same Squire Patton Boggs team advised JTC on its acquisition of independent professional services firm Hanway Advisory in July 2024, enhancing and adding further scale to JTC’s Global AIFM Solutions business.

The following article is based on a press release issued by Circana on November 3, 2025.

From January through September 2025, U.S. toy industry dollar sales increased 7 percent, units sold were up 3 percent, and average selling price (ASP) grew by 4 percent, compared to the same 9-month period in 2024, according to Circana.

Growth is largely being driven by collectibles (+33 percent) and licensed toys (+14 percent). Standout performers included strategic and sports trading cards and action figure collectibles, while licensing trends centered on sports, witches and wizards, animals, movies, and gaming franchises.

Seven of the 11 supercategories Circana tracks posted dollar growth, with six of them also showing unit growth. Games/puzzles grew the fastest, with Pokémon as the main driver of growth. This was followed by explorative & other toys, where sports trading cards continue increasing sales, and building sets, where Formula 1 was the biggest contributor to growth. The industry’s steepest declines came from outdoor and sports toys, plush, and dolls.

“The U.S. consumer, and their willingness to absorb tariffs, will be the key factor shaping Q4 performance,” said Juli Lennett, vice president and toy industry advisor at Circana. “The toy industry has a unique advantage and tends to be resilient in turbulent times as toys serve as emotional anchors for families, offering joy and a welcome distraction in our lives. The industry also benefits from trends like adult self-gifting, nostalgia, and digital wellness – factors that are expected to influence holiday purchases.”

Federal Decree Law No. 10 of 2025 overhauls the UAE’s AML, CTF and proliferation financing framework. It repeals and replaces Federal Decree Law No. 20 of 2018, reinforcing the UAE’s commitment to the Financial Action Task Force’s (FATF’s) 40 Recommendations, which are the global standard for combatting money laundering, terrorist financing, and the financing of weapons of mass destruction.

The new law creates new offences related to financing terrorism through digital systems, virtual assets or encryption technologies; lowers the threshold for evidence relating to money laundering, terrorism funding and proliferation funding; introduces larger fines and prison sentences; launches a new oversight body; increases investigative and enforcement powers for authorities; and expands compliance obligations for organisations.

Marie Chowdry, a financial services regulation expert at Pinsent Masons, said that with the new law, the UAE “has taken a decisive step in fortifying its financial integrity”.

“By expanding the scope of predicate offences, lowering evidentiary thresholds, and integrating digital assets into the AML/CTF framework, the law reflects a sophisticated understanding of emerging financial risks.”

“The inclusion of virtual assets and the extension of limitation periods in the UAE’s new AML law are game-changing developments,” she said.

“As digital finance continues to evolve, the law’s broader scope ensures that virtual asset service providers (VASPs) are now firmly within the regulatory perimeter. This is a critical step in closing gaps that previously allowed illicit actors to exploit emerging technologies.”

The new law clarifies that terrorism funding offences can be committed by anyone through digital systems, virtual assets or encryption technologies if they know, even if implied, that the funds will be used for terrorism, aiming to ensure that crypto, fintech and dual-use goods businesses are within the scope of the UAE’s counter-terrorism framework.

Fines for organisations have been expanded from AED50 million (approx. US$13.6 million) to AED100 million and individuals can be imprisoned for up to 10 years under the new, tougher penalties. There is also no limitation period for money laundering, terrorism funding and proliferation offences.

Chowdry said: “The extension of limitation periods for prosecuting AML offences reflects a more realistic approach to complex financial investigations, which often span years and jurisdictions.”

“This means greater exposure and longer liability windows, making it essential to maintain rigorous compliance and documentation practices,” she said.

“These updates not only enhance the UAE’s global standing but also signal a more assertive enforcement environment. Businesses should act swiftly to align with the new standards.”

Under the new law, “sufficient evidence or circumstantial evidence” is enough, and knowledge can be inferred from the “factual and objective circumstances”. This means that money laundering, terrorism funding and proliferation funding offences can be committed if a person knew, or should have known, that an offence would be committed, aligning the UAE with other jurisdictions such as the UK.

Financial institutions, designated non-financial businesses and professions (DNFBPs) such as lawyers and accountants, VASPs and non-profit organisations are also now subject to mandatory beneficial ownership and risk assessment requirements.

Lana Akkad, a financial regulation expert at Pinsent Masons, said: “By lowering the evidentiary threshold and expanding the scope of criminal liability, the law empowers enforcement agencies to act more decisively against financial crime.

“For financial institutions, DNFBPs, and VASPs, this means a heightened need for robust compliance frameworks, especially around digital assets and cross-border transactions,” she said.

“Businesses should immediately review their AML policies, enhance due diligence procedures, and ensure their teams are trained on the new legal standards.”

The law creates a new ‘supreme committee’ to oversee the National Committee for Combatting Money Laundering and the Financing of Terrorism and Proliferation, which has the mandate to introduce national strategies to improve regulatory compliance, assess crime risks, exchange information with domestic and international authorities, propose relevant regulation and represent the UAE internationally.

Akkad said: “The creation of a Supreme Committee also signals a more coordinated national approach, which will likely lead to increased scrutiny and enforcement. Proactive compliance is no longer optional: it’s a strategic imperative.”

Under the law, the Financial Intelligence Unit, a central agency responsible for gathering, analysing and disseminating intelligence related to suspicious transactions, can now freeze funds for up to 30 days compared to the previous seven, and suspend transactions for up to 10 business days without prior notice.