Premier League account freezing order extended: lessons on suspicion, damls and the limits of the S.308 POCA defence. In National Crime Agency v The Football Association Premier League Limited, the Westminster Magistrates' Court decided to extend an account freezing order ("AFO") covering approximately £10 million received by the Premier League from NFT fantasy football operator, Sorare. The decision provides a noteworthy illustration of important issues that all businesses should be thinking about in the context of counterparty due diligence and managing risks under the Proceeds of Crime Act 2002 ("POCA"), but which are rarely publicly discussed by the courts or regulators. Background The ongoing proceedings concern payments made by a company, Sorare SAS, to The Football Association Premier League Limited under a November 2022 licensing agreement. Sorare obtained rights to produce and market Premier League-themed NFT fantasy football products (NFTs are non-fungible tokens). In return, Sorare agreed to make substantial royalty and minimum guarantee payments to the Premier League. By July 2024, the Premier League had received £17.5 million under the arrangement. On 4 July 2024, Sorare informed the Premier League that it had been charged by the Gambling Commission with offences relating to the provision of allegedly unlicensed gambling facilities. The prosecution alleges that aspects of Sorare's fantasy football model amount to betting activities requiring an operating licence under the Gambling Act 2005; a failure to obtain such a licence is a criminal offence. Those criminal proceedings remain ongoing. Following notification of the prosecution, the Premier League took steps to ring-fence payments received from Sorare and subsequently made a defence against money laundering ("DAML") disclosure to the NCA expressing concern that it might be holding criminal property. The NCA later obtained an AFO over the account containing the ring-fenced funds. The NCA's Application The NCA sought a further four-month extension of the AFO to permit the continuation of ongoing tracing enquiries, including the obtaining of banking evidence from Luxembourg. The NCA contended that there were reasonable grounds for suspecting that the frozen funds constituted "recoverable property" because they were ultimately derived from revenues generated by Sorare's allegedly unlawful gambling activities in Great Britain. The frozen balance represented approximately £10 million received after July 2024. Earlier payments had already been removed from the scope of the order following a previous variation, the NCA having accepted that those earlier funds were likely protected by the operation of section 308 POCA (under which property ceases to be recoverable property if obtained by a person in good faith, for value and without notice that it was recoverable property) because they had been received before the Premier League became aware of the criminal proceedings against Sorare. The Premier League's Defence The Premier League argued that there were no reasonable grounds for suspecting that the funds were recoverable property. It emphasised that it had acted lawfully throughout, had provided genuine value under the licence agreement, and had undertaken due diligence before entering into the arrangement. It further argued that the funds fell within the protection afforded by section 308 POCA. The Premier League also contended that the NCA had failed to establish any meaningful evidential link between funds earned from UK consumers and the monies ultimately paid under the licence agreement. The Court's Decision The question for the court in deciding whether to approve the AFO extension was whether there remained reasonable grounds for suspecting that the funds were recoverable property. The court concluded that there were. First, the court considered the Premier League's own conduct following notification of the criminal proceedings. The decision to establish a ring-fenced account, together with the contents of the DAML disclosure, demonstrated that the Premier League suspected that the funds were criminal property. The court regarded this as powerful evidence supporting the existence of reasonable grounds for suspicion sufficient to justify extending the AFO. Secondly, the court accepted the NCA's evidence that Sorare had continued to operate in Great Britain following the commencement of the Gambling Commission prosecution and that financial intelligence indicated a connection between payments received from UK consumers and the monies ultimately transferred to the Premier League. Although the tracing exercise remained incomplete, the court considered the available evidence sufficient at the investigative stage. Finally, the court rejected the argument that the section 308 defence provided a basis for discharging the AFO; a recipient who suspects that property may be criminal property cannot generally rely upon the statutory good-faith exception. In light of the Premier League's expressed concerns and DAML disclosure, the court considered it unsustainable for the Premier League to argue that it lacked the necessary notice or suspicion. It is worth noting that, while the decision relates to funds received after the notification of the Gambling Commission's charges against Sorare, the Premier League had been told about the prior investigation into Sorare at the time of contracting. Judicial eyebrows were raised at the Premier League's decision to proceed without further due diligence at that time: "In view of the millions of pounds which was at stake, and a public announcement by a gambling regulatory body that Sorare was not licenced and meant activity being completed on the site by consumers in Great Britian may be outside of the gambling regulations that a licenced operator should comply with, one might question why they did not seek their own legal opinion to protect their interests." Key Takeaways * The range of conduct that can give rise to "recoverable property" is very broad and can include strict liability / 'regulatory' offences by a commercial counterparty. * If a person files a DAML in relation to their knowledge or suspicion of funds from a counterparty, a subsequent attempt to resile from that knowledge/suspicion (to assert the funds are not recoverable property or, presumably, not criminal property) is unlikely to be successful. The contents of DAMLs should be accurate and considered carefully before they are filed. * For businesses receiving funds from counterparties, particularly those operating in regulated or legally uncertain sectors, the case underlines the great importance of initial and ongoing due diligence to mitigate the risk of becoming concerned in money laundering (including the recovery by the NCA of profits of an otherwise legitimate commercial bargain). If you would like to discuss the implications of these developments, please contact Andrew Matheson, Guy Bastable, or Sam Aldous in Burges Salmon's Corporate Crime & Investigations team.

Sorare secures fresh backing worth tens of millions as it targets profitability by 2027. Last Updated: September 22, 2026 * Sorare (official site) has pulled in tens of millions of euros from its current investors to bankroll its strategic growth plan. * The firm is now aiming to reach profitability by the end of 2027, with its new free-to-play Arcade mode as the main engine. * Legal troubles have not gone away, among them a prosecution brought by the UK's Gambling Commission over alleged unlicensed gambling activities. Funding round details Following an announcement on September 3, Sorare locked in further capital from existing backers, a group that includes Benchmark, Accel, Partech, and Kibo Ventures. Co-founders Nicolas Julia and Adrien Montfort also put money into the round, which Julia said amounted to tens of millions of euros. The initial tranche is closed, though more investment is expected to follow. The company did not reveal a valuation. Growth momentum In the first half of 2026, Sorare posted an 85% year-on-year rise in net revenue, with more than 100,000 users buying cards. According to Julia, the company is now working toward profitability by the end of 2027, moving the target from the one it had set in late 2025. At the heart of the plan sits Arcade, a free-to-play mode in which fans collect football cards, form teams, and participate in challenges based on real-match performances. Packs can be earned through play or unlocked by buying premium currency to build out a collection. Julia forecasts that Arcade could bring in between €15 million and €20 million in net revenue over 2026. Restructuring efforts The new money arrives five years on from the $680 million Sorare raised at a $4.3 billion valuation. In the years since, the company has struggled to sustain expensive licensing deals as customer spending came in below expectations. In response, Sorare cut its annual licensing commitments by more than €500 million through renegotiations and contract withdrawals, and it has consolidated operations in Paris after shutting its New York office. Product expansion and challenges Arcade is designed to reach a wider audience by letting users engage with no upfront spend, but whether it works depends on sustaining repeat play and turning that activity into revenue. The pivot follows the company's migration of its games and NFTs to Solana in October 2025. On the legal side, Sorare is being prosecuted by the UK's Gambling Commission for allegedly providing unlicensed gaming services. It has pleaded not guilty, with a trial scheduled for June 7, 2027. Separately, roughly £10 million paid to the Premier League is under examination as part of a National Crime Agency investigation. Even with these headwinds, Julia says his attention remains fixed on getting the company to profitability.

Sorare has raised tens of millions of euros from existing investors including Benchmark, Accel, Partech and Kibo Ventures as the Paris-based fantasy sports company works towards profitability. Co-founder Nicolas Julia told Maddyness that net revenue increased 85% year-on-year in the first half of 2026, with over 100,000 users buying cards. The company now targets profitability by end-2027. Central to its strategy is Arcade, a free-to-play mode where users collect football cards and compete based on real match performances. Julia expects Arcade to generate €15 million to €20 million net revenue in 2026. Sorare has cut annual licensing costs fivefold and moved operations to Solana. However, it faces prosecution from Britain's Gambling Commission, with trial scheduled for June 2027.