The Financial Conduct Authority’s warning to football clubs over sponsorship deals with unauthorised crypto exchanges and trading platforms is less a bolt from the blue and more a late acknowledgement of a long-running consumer protection failure.
On 3 June 2026, the regulator said it had written directly to clubs, mainly in the Premier League, because unauthorised firms were using football sponsorships to target “unwitting” fans. It also said some of those firms may be operating unlawfully in the UK and fans who use them risk losing all their money.
That warning is welcome. But it is also overdue.
A regulatory problem years in the making
The basic regulatory problem has been plain for years. In 2018, the UK Cryptoassets Taskforce found that misleading advertising and insufficient information were some of the key consumer protection issues in crypto markets.
In 2021, the FCA launched its Consumer Investments Strategy and published its Discussion Paper 21/1 to tighten the financial promotions framework for high-risk investments.
In 2022 and 2023, it consulted on, and then implemented, a tougher crypto financial promotions regime, under which promotions to UK consumers must be clear, fair and not misleading, include prominent risk warnings and avoid inappropriate incentives.
By October 2023, when the regime went live, the FCA issued 146 alerts in the first 24 hours alone. Analysis published in February 2025 showed that 19,766 financial promotions had been amended or withdrawn in 2024 and highlighted continuing concern about crypto promotions and younger consumers being targeted online.
How football sponsorship transfers trust and legitimacy
In other words, the regulator has long known retail consumers were being drawn into risky and sometimes unlawful products through mass marketing, social media and brand-led trust. Football sponsorship is simply another distribution channel, albeit an especially potent one because millions of supporters instinctively associate a club badge with legitimacy. The FCA now says exactly that: a shirt logo can confer legitimacy on firms sitting outside the regulatory perimeter.
It warned clubs that sponsorships may facilitate offences under sections 19 and 21 of the Financial Services and Markets Act 2000, that clubs’ own sponsor-related communications may be unlawful financial promotions, and that sponsorship monies can raise financial-crime questions under the Proceeds of Crime Act 2002.
The harm is not theoretical. In 2022, the ASA upheld complaints against Arsenal Football Club’s fan-token advertising because the ads trivialised investment in cryptoassets and failed to make clear both the risks and the lack of regulation.
Newcastle United’s official partnership announcement with VT Markets said the firm would use the club’s global reach and exposure to build its brand in multiple international markets, while the FCA’s Warning List states that VT Markets / www.vtmarkets.com is not authorised or registered by the FCA.
That is precisely the sort of trust transfer the FCA is now worried about: club credibility being used to accelerate customer acquisition.
The consequences of regulatory grey areas
There is also a broader pattern of sports-adjacent consumer harm. Football Index, although licensed as gambling rather than regulated by the FCA, collapsed with over £124 million in consumer losses and led to an independent review that identified lessons not just for the Gambling Commission but for the FCA as well, including faster responses and clearer messaging on where regulatory responsibility sat.
That episode matters because it demonstrates what happens when a football-branded, investment-like product grows in a grey area while regulators debate the perimeter. Consumers do not experience those gaps as jurisdictional niceties; they experience them as life-changing losses.
Moving from regulatory warnings to enforceable standards
What should happen next?
First, the FCA should move beyond sector letters and into a visible escalation framework. Where a sponsoring firm is already on the Warning List, or where the FCA has informed a club there are credible concerns of unlawful UK-facing activity, the expectation should not merely be “enhanced due diligence.” It should be suspension or termination, unless the firm can demonstrate a lawful basis for UK promotion. If the FCA was prepared in 2026 to bring proceedings against HTX, seek social-media blocking and request app-store removal, it can and should apply the same urgency where football sponsorship is being used to funnel consumers into unlawful products.
Secondly, football needs a binding sponsor-governance rule rather than continued reliance on voluntary prudence. The FCA has already said it is engaging with the Premier League and the Independent Football Regulator. That should become a formal standard requiring clubs to check FCA authorisation status, review Warning List entries, verify geo-blocking and onboarding controls, assess whether any communication made by the club could itself be a financial promotion, and obtain specialist legal advice where the perimeter is unclear. Board-level attestation and contractual termination rights should be mandatory. The Premier League’s commercial power and the Football Governance Act 2025’s new regulatory architecture make this more than a theoretical possibility.
Thirdly, the FCA should use its existing recovery powers more aggressively. FSMA already provides for injunctions and restitution, and agreements made by unauthorised persons or resulting from unlawful communications can be unenforceable, with rights to recover money and claim compensation.
That is a stronger toolkit than public debate sometimes suggests. The problem is not the complete absence of powers but the inconsistent speed and visibility with which they are used.
Recovery, private prosecutions and meaningful consumer protection
Finally, the government should examine whether victims need a more realistic route to pursue criminal recovery when regulators do not act quickly enough. Private prosecutions are not a simple answer. Section 6 of the Prosecution of Offences Act 1985 preserves the general right, but the Supreme Court in R (on the application of Gujra) (FC) (Appellant) v Crown Prosecution Service (Respondent) [2012] UKSC 52 confirmed that the DPP can take over and discontinue cases, and section 401 FSMA means that FSMA offences require regulator action or DPP consent.
Even so, the law contemplates a meaningful role for private prosecutors in some contexts, including confiscation. In R (Virgin Media Ltd) v Zinga [2014] EWCA Crim 52, the Court of Appeal confirmed that a private prosecutor could institute confiscation proceedings by inviting the court to proceed under section 6 of POCA.
Moreover, criminal courts can make compensation orders under sections 133–146 of the Sentencing Act 2020. If ministers want private prosecutions to form part of the response to unauthorised-platform losses, they would need a more structured model: for example, a DPP-consent protocol for defined categories of unlawful investment fraud, clearer routes to compensation and confiscation, and rules preventing duplication where the FCA is already acting.
The FCA is right that clubs should not allow unauthorised firms to exploit fan loyalty. But if this is all the episode amounts to — another letter, another expectation, another reminder to “check the register” — then it will merely confirm the impression that the regulator sees harm clearly, but too often only after the marketing machine has already done its work.
The tougher and more credible answer is to make football sponsorship by unauthorised financial firms commercially unworkable, legally hazardous and quickly reversible. That is what real consumer protection would look like.
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