Partner and Head of White Collar Crime and Investigations, Chris Roberts, discusses the freezing of Premier League’s funds amid a criminal investigation into Sorare.com, in PLC Magazine.

Chris’ article first appeared in the October 2026 issue of PLC Magazine, here.

The National Crime Agency (NCA) has frozen more than £10 million in a bank account belonging to the Premier League, after Westminster Magistrates’ Court recently granted an additional four-month freeze on the account. District Judge Sam Goozee said this was “necessary and proportionate” to prevent dissipation of funds and enable a proper investigation.

That investigation is being undertaken by the NCA and Luxembourg authorities into fantasy football Non-Fungible Token (NFT) player cards issued by crypto-gaming firm Sorare.com, the Premier League’s former fantasy football game partner.

Integral to its free-to-play online fantasy football game, French-based Sorare had a licence deal to release digital cards of Premier League players. Cards were made available for purchase, via credit card or cryptocurrency, on Sorare’s online platform – either through an auction or an instant buy feature. They could then be re-sold to other Sorare customers: sellers set the price, underpinned by a scarcity level which the platform set each season.

In 2021, the Gambling Commission launched an investigation into whether these trades constituted a form of gambling. This was followed by the NCA’s investigation which resulted in the initial freezing of Premier League funds in January 2025. Its purpose, according to the NCA, is “to prevent dissipation of the funds while the NCA investigates any potential links between those funds and alleged third-party criminality.”

When freezing assets, the NCA typically targets crime through intelligence-led operations and international partnerships. Amidst growing scrutiny around gambling and digital assets involving large sums of money, its investigation into Sorare demonstrates the acute level of scrutiny and enforcement approaches which commercial organisations can face when these elements are combined.

Under the Crime and Courts Act 2013 and the Proceeds of Crime Act 2002 (POCA), the NCA has a wide range of law enforcement, asset recovery, and investigative powers.

These include Account Freezing and Forfeiture Orders (AFOs), which allow its officers to freeze and forfeit funds held in bank accounts reasonably suspected of representing the proceeds of crime or intended for unlawful use. Such orders can help to preserve funds for potential recovery if a subsequent prosecution proves to be successful.

Invariably, the size of the sums involved can influence the authorities’ level of response. Although the minimum threshold to apply for an AFO in a Magistrates’ Court remains at a modest £1,000 on the aggregate balance of specified accounts, the NCA’s willingness to deploy enforcement tools at this threshold is often more limited.

Instead, the agency tends to focus on enforcement involving larger amounts. This is evident from data published in the Joint Asset Recovery Database (JARD), managed by the NCA, which tracks the seizure, freezing, and forfeiture of the proceeds of crime across all UK law enforcement agencies.

Data collated by the NCA is used by the Home Office to publish the annual Gov.uk Asset Recovery Statistics, which track both the volume and aggregate value of civil freezing and forfeiture orders. In the financial year ending March 2026, there were £345.3 million of assets recovered from confiscation, forfeiture and civil recovery orders – which represents an increase of 20% compared to the previous financial year.

So, what role have the Premier League’s compliance procedures played in the Sorare investigation? Although details of its internal procedures are confidential, reports from the Magistrates’ Court application hearing indicate that the Premier League had started to move Sorare funds and direct future payments into a ring-fenced account two years ago.

They also revealed that, in December 2024, the Premier League made an “authorised disclosure” to the UK Financial Intelligence Unit. The NCA’s counsel, Andrew Bird KC, told the hearing that the Premier League “did the right things” by voluntarily ring-fencing the funds and making a suspicious activity report.

However, the delay between directing funds into a ring-fenced account and submitting a Defence Against Money Laundering does, absent more detail, raise eyebrows. Authorities rely on not only effective but timely reporting to enable them to identify and respond to potential wrongdoing promptly.

Further, the robustness of the Premier League’s due diligence would appear to need to be strengthened. According to the judgment, the Premier League’s due diligence at the outset of the relationship with Sorare included obtaining the summary of a legal opinion which Sorare had received which appears to have been of the conclusion that Sorare’s activities were not a form of gambling. The Court noted the legal opinion clearly stated, “it should not be relied upon by any third party”.

Of course, the Premier League is a substantial, sophisticated and very high-profile organisation, which generated a record revenue of £3.66 billion during the 2024/25 financial year. Whether the system works as effectively when the organisations involved are less high profile and the sums involved are considerably smaller is open to question. Equally questionable is whether comparable activity would be identified and acted upon in a smaller organisation.

There are wider implications for organisations of every size in handling digital asset transactions. Ideally, they should move beyond reliance on traditional financial controls and integrate specialised on-chain screening, AI-driven monitoring, advanced technical safeguards, and strict internal governance.

In practice, that means leveraging appropriate technology and enhancing levels of human oversight. To enforce internal governance requires establishing clear and robust operating procedures and comprehensive audits as standard.

The NCA investigation into Sorare.com has not yet concluded, but from what the agency has done so far is arguably emblematic of the increasing vigilance of the NCA and other enforcement agencies.

In paying tribute to its 6,000 officers earlier this year, NCA Director General Graeme Biggar noted that “the criminals we face in 2026 are faster, more connected and more technically sophisticated.” Every penny of the announced governmental increases in the NCA’s £1 billion budget up to 2027/28 will be needed to keep pace with them. Simultaneously, companies will also need to step up in ensuring that their compliance protocols and procedures meet the highest standards, wherever possible.