On Friday 11 September 2026 District Judge Sam Goozée, sitting at Westminster Magistrates’ Court, extended by four months an account freezing order over £10,024,041.33 standing to the credit of the Premier League, together with accrued interest. He found nothing to suggest that the League had itself engaged in unlawful conduct. He continued the freeze regardless. The judgment repays reading by anyone whose business involves taking substantial sums from a counterparty operating at the edge of a licensing regime, because it shows how little the recipient’s innocence contributes once the statutory machinery engages.[1]
The money is licence income. On 1 November 2022 the League entered into a licence agreement with Sorare SAS, the Paris registered fantasy football platform, under which Sorare became its official fantasy football NFT licensee, paying royalties on net revenue from sales of licensed products together with annual minimum guarantees for each season. The League received £15m for the 2023/24 season and five instalments of £2.5m across 2024/25 and 2025/26.[2] By the date of the agreement the Gambling Commission had been examining Sorare for more than a year. It charged the company in July 2024 with three offences of providing facilities for gambling without an operating licence under the Gambling Act 2005, and the trial is listed at Birmingham Magistrates’ Court for June 2027.[3]
The order, and its ceiling
Account freezing orders occupy Chapter 3B of Part 5 of the Proceeds of Crime Act 2002, inserted by the Criminal Finances Act 2017. An enforcement officer may apply where he has reasonable grounds for suspecting that money held in an account is recoverable property or is intended by any person for use in unlawful conduct, and the magistrates’ court may make the order on the same test. Nothing in the scheme requires an allegation against the account holder. Suspicion attaches to the money. That is why Judge Goozée could find no suggestion of wrongdoing by the League while holding that “the freezing of accounts is necessary and proportionate to prevent dissipation of funds which are suspected to be the fruits of criminal conduct and enable proper investigation by the authorities”.[4]
The order has now been extended to the full statutory limit. It remains in force until 15 January 2027. It was made on 16 January 2025 for nine months, extended in July 2025 for a further ten, varied by consent in May 2026, and extended again by consent to 14 September 2026. Section 303Z3(4) provides that the period specified may not exceed two years starting with the day the order was made.[5] The extension granted on 11 September takes it to that ceiling and no further.
The League should take limited comfort from the arithmetic. Section 303Z3(3) preserves the operation of section 303Z14, and section 303Z14(6) provides that where an application for forfeiture is made the freezing order continues to have effect until the time referred to in subsection (7)(b) or (8), which is to say until the application is determined and, on a forfeiture order, until the money has been transferred.[6] An application made before the order lapses therefore carries the freeze beyond the two-year period. Forfeiture is decided on the balance of probabilities by the same magistrates’ court, and the judge has reserved any such application to himself for judicial continuity.[7] It does not wait upon the criminal trial of anyone. The order expires in January 2027. Sorare is not tried until June.
What section 308 has already done
Section 308(1) provides that recoverable property ceases to be recoverable where the person who obtains it on a disposal does so in good faith, for value and without notice that it was recoverable property. The provision is not merely a point reserved for any forfeiture hearing. It has already altered the order once, while the judge refused to allow the League to rely on it at the investigatory stage for the later receipts.
On 8 May 2026 the order was varied by consent to reduce the frozen sum from £16,273,678.43 to its present figure. The judge records that the National Crime Agency accepted the funds released were not recoverable property by operation of section 308, because up to 4 July 2024 the League had received them in good faith, for value and without notice.[8] 4 July 2024 is the day Sorare telephoned to say it had been charged. Everything now frozen is money received after that call.
For the receipts after it, the judge found the exception could not be sustained at this investigatory stage. He applied the Court of Appeal in R (World Uyghur Congress) v National Crime Agency, where Dove J, giving the judgment of a court including the Lady Chief Justice, held that payment of market value is not by itself enough and that “[a] person who suspected that it was would not be able to rely on s.308”.[9] What defeated the League was its own paperwork. On 6 December 2024 it filed a defence against money laundering disclosure recording that it “is concerned that it may hold criminal property” and that it “retains concerns that it could be in possession of criminal property”. Asked in cross-examination whether the disclosure set out the League’s suspicions, its Director of Legal answered “Yes it is”.[10] The judge found any attempt to distance the League from that suspicion implausible, and treated the arguments about actual and constructive notice as a layer of unnecessary complexity he did not need to enter.[11]
The steps taken to protect the League, ring-fencing the money and notifying the authorities, also evidenced the suspicion that prevented it from relying on section 308 at this stage. The judge noted that the League has not sued Sorare for a further £7.5m owed for over a year, which he said gave greater credence to its suspicions.[12]
The diligence the judge criticised
The notice analysis makes the earlier history worth setting out, though it goes to the judge’s criticism rather than to any finding that the League was on notice in 2022.
On 8 October 2021 the Gambling Commission published a consumer information notice stating that Sorare.com was not licensed by the Commission, that activity by consumers in Great Britain therefore fell outside the gambling regulations a licensed operator must comply with, and that it was carrying out enquiries into whether an operating licence was required.[13] The League met Sorare four days later and asked for a revised offer and a legal opinion. In November 2021 it received three legal notes obtained by Sorare, including one from Memery Crystal Limited, to the effect that no licence was required and that the Commission had erred in its reading of the Act. The summary on which the League relied stated in terms that it should not be relied upon by any third party.[14]
The League took no independent advice. Judge Goozée found that it had undertaken some due diligence, and then observed that the opinion “clearly would have been self-serving to Sorare”, that it appeared to have been accepted at face value, and that “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 ... one might question why they did not seek their own legal opinion to protect their interests”.[15]
Advice obtained by a counterparty is prepared for that counterparty’s purposes. Where it disclaims third-party reliance, it cannot substitute for advice addressed to the party carrying the commercial and regulatory risk.
The anterior question
Underlying all of this sits an issue no court has decided. Whether Sorare’s product constitutes gambling within the 2005 Act is the anterior question. Without unlawful conduct there can be no recoverable property, although tracing and section 308 would remain separate questions in any forfeiture application. The Commission’s position is that the game structure amounts to a betting prize competition under section 11(1) of the Act irrespective of the entry method, and it has prosecuted on that footing. Sorare denies it and says its game rewards skill. Judge Goozée expressly declined to decide the point, holding only that Sorare has been prosecuted by a regulatory body in circumstances where the evidential test has been met.[16] The trial is in June 2027. The order expires five months before it.
One point of precision deserves recording, because much of the coverage has obscured it. The frozen asset is not cryptocurrency. It is a sterling balance, quantified by the court to the penny, held in an ordinary bank account. Whatever Sorare’s cards may be, what the Agency has restrained is a licensee’s payment in conventional money.
An adjacent dispute in the United States
A related classification dispute is being fought in the United States. The Third and Ninth Circuits have divided over whether the Commodity Exchange Act prevents state gambling regulators from applying their laws to sports event contracts offered by a federally regulated exchange. New Jersey petitioned for certiorari on 2 September 2026 in Flaherty v KalshiEX LLC. The petition was docketed on 8 September as No. 26-299.[17]
The statutes and procedural questions are different. The common feature is the attempt to fit a digital product within competing legal categories. Kalshi characterises its contracts as federally regulated derivatives. State regulators characterise them as sports wagers. Sorare says its game rewards skill. The Gambling Commission says its structure amounts to a betting prize competition.
The label chosen by the operator does not decide the legal classification. Until the courts do, counterparties accepting money generated by these products carry a risk that extends beyond the contract itself.
Notes
1. National Crime Agency v The Football Association Premier League Limited, District Judge (Magistrates’ Courts) Sam Goozée, Westminster Magistrates’ Court, 11 September 2026, at [1], [71], [83] and [85]. Available at https://www.judiciary.uk/wp-content/uploads/2026/09/NCA-v.-Football-Accn-Premier-League-Ltd-11.09.2026.pdf.
2. Judgment at [9], [13], [14] and [15].
3. Judgment at [18], [22] and [27]. The three charges relate to periods between February 2022 and April 2024. Sorare pleaded not guilty at Birmingham Magistrates’ Court on 4 October 2024.
4. Judgment at [83]. Sections 303Z1 and 303Z3, Proceeds of Crime Act 2002.
5. Section 303Z3(4), Proceeds of Crime Act 2002. Procedural history at judgment [1].
6. Sections 303Z3(3) and 303Z14(6) to (8), Proceeds of Crime Act 2002.
7. Judgment at [86].
8. Judgment at [1], [29] and [70].
9. R (World Uyghur Congress) v National Crime Agency [2024] EWCA Civ 715 at [46], cited at judgment [64].
10. Judgment at [35], [72], [73] and [74].
11. Judgment at [76] and [77].
12. Judgment at [84].
13. Gambling Commission, consumer information notice, Sorare.com, 8 October 2021. Judgment at [9].
14. Judgment at [10] and [42].
15. Judgment at [71].
16. Judgment at [12] and [69].
17. Flaherty v KalshiEX LLC, No. 26-299 (US), petition for a writ of certiorari filed 2 September 2026, docketed 8 September 2026. KalshiEX LLC v Flaherty (3d Cir, April 2026). KalshiEX LLC v Assad, No. 25-7516 (9th Cir, 28 August 2026).