Are you a club owner looking for how to bend the rules of multi-club ownership? Just ask Uefa, and they will tell you how to circumvent their own rules.
By Philippe Auclair
“No one may simultaneously be involved, either directly or indirectly, in any capacity whatsoever in the management, administration and/or sporting performance of more than one club participating in a UEFA club competition“.
“No individual or legal entity may have control or influence over more than one club participating in a UEFA club competition“.
(Regulations of the Uefa Champions League – Article 5: Integrity of the competition/multi club ownership, 2025)
Clear enough? It should be, but it isn’t.
On one hand, Crystal Palace have just been demoted to the Uefa Conference League because key shareholder John Textor, who also owns Olympique Lyonnais, failed to divest from the London club before Uefa’s 1 March deadline.
Two other clubs which had qualified for the 2025-26 Conference League, Irish side Drogheda United FC and the Slovakian club DAC 1904 Dunajka Streda, have been kicked out of that competition by Uefa when they were found to be in breach of those MCO regulations (*).
On the other, had Nottingham Forest managed to hang on to a top 5 spot in the Premier League, they’d have been admitted in the Champions League despite being owned by shipping magnate Evangelos Marinakis, who also controls newly-crowned Greek champions Olympiacos. AAnd had Manchester United not endured awful seasons and missed out on Europe, they would have been allowed to participate in the same Uefa competition as Lausanne Sport, who qualified for the Europa Conference League, despite Ineos boss Jim Ratcliffe (lead photo) calling the shots at both clubs.
Yet here we are, in July 2025. Marinakis still owns Nottingham Forest and Olympiacos (as well as Portuguese Primeira Liga club Rio Ave), and Ratcliffe still exerts significant control over Manchester United and Lausanne Sport (and Ligue 1 OGC Nice). How can it be that, unlike Drogheda, Dunajka Streda and, maybe, Crystal Palace, their clubs would have been allowed to play against each other in Uefa competitions if results had gone the way they hoped last season?
Is it not the case that “no one may simultaneously be involved, either directly or indirectly, in any capacity whatsoever in the management, administration and/or sporting performance of more than one club participating in a UEFA club competition” and that “no individual or legal entity may have control or influence over more than one club participating in a UEFA club competition“?
They did, and still do. That was not a problem for them because they used a mechanism which enabled them to maintain control over their clubs whilst complying with the restrictions put in place by Uefa. Though “complying” does a lot of heavy lifting in this context, and “bypassing” might be a more appropriate choice of word.
And Josimar can confirm that the man who engineered this legal trick is none other than the chairman of Uefa’s Club Financial Control Body since 2021, Sunil Gulati, the former US Soccer Federation president and Fifa council member.
Sunil Gulati, Afc president Sheikh Salman Bin Ibrahim Al-Khalifa and Uefa president Aleksandr Čeferin, at a New York City FC home game in August 2018.
Blind trusts
The trick is to use “blind trusts”, which can be defined as trusts in which the ultimate beneficial owner – the trustor – gives control of the assets to a third party – the trustee – who manages them “at an arm’s length”, without the trustor’s implication. This system has been in use in the Anglo-Saxon world for a while and has recently gained currency in European countries such as France. Politicians such as Canadian prime minister Mark Carney have been known to use it to avoid potential conflicts of interest once they assume office. In principle, the third party should have no pre-existing personal or professional relationship with the beneficiary, and the trustor, who remains the owner of the assets, should have no knowledge of how the trustee will manage them, save for a basic quarterly statement outlining their financial performance. This mechanism can be used in a virtuous way, to prevent insider dealing, for example. But when it comes to football, it is just as easy to see how the original purpose of the mechanism can be twisted to eschew MCO regulations.
In football, setting up a “blind trust” enables the ultimate beneficial owner of a club to transfer the control of his equity in the club in question to a third party of their choice for as long as it suits them, as those blind trusts are unilaterally revocable by the original owner at a time of their choosing. But a club is much more than a financial asset. Who could possibly expect hands-on owners like Marinakis and Ratcliffe to somehow entrust the operational control of Nottingham Forest and Lausanne Sport to an independent third party which could then do as it pleases?
Anyone who saw Evangelos Marinakis haranguing Forest’s manager Nuno Espirito Santo on the pitch at the conclusion of his club’s 2-2 draw with Leicester City on 11 May will be in no doubt as to who remained in charge at the City Ground, blind trust or no. The club also briefed reporters in private that “nothing had changed”.
Altercation between Nuno Espirito and Evangelos Marinakis at the conclusion of Forest’s home draw with Leicester City, May 2025.
How it works
The process is remarkably simple. In Forest’s case, the British registry of companies shows that the “ownership” of NF FOOTBALL INVESTMENTS LIMITED, the company which controls the club, passed from Marinakis to an ad hoc company called Pittville One Ltd on 29 April 2025.
Once Nottingham Forest had missed out on Champions League qualification, the transfer was reversed, on 6 June 2025. Ownership and voting rights which had been assigned to Pittville One Ltd reverted to Marinakis. The blind trust had served its purpose. It can be assumed that Forest had taken care of informing UEFA of the operation before the 1 March deadline.
Pittville One Ltd, which is registered as a “dormant company” in the UK, was set up specifically for this operation, with a capital of three pounds sterling. Its “director” and “person with significant control” is a 43-year old English solicitor, Matthew Peter Shayle, who also holds directorships in 21 other companies, some of which at least appear to be blind trusts as well.
Director for hire
Matthew Peter Shayle, briefly “person with significant control” of Nottingham Forest’s holding company.
According to Tax Journal, Shayle is “a partner at tax and private client boutique law firm Wiggin Osborne Fullerlove”, specialising “in giving advice on tax and private wealth issues for ultra-high net worth international families and their advisers”.
Shayle is also no stranger to the football world, and it is not the first time that an owner has turned to him to comply with Uefa’s multi club ownerships regulations. What he did for Evangelos Marinakis he had already done for the City Football Group (CFG), Manchester City FC’s holding company.
In 2024-25, Manchester City found themselves drawn in the Champions League alongside another CFG-controlled club, Girona. Following advice given by UEFA, three of Girona’s board members, John MacBeath, a former interim CEO of City who served on the CFG and City boards, CFG’s general counsel Simon Cliff and Ingo Bank, a director of City Football Investments Ltd (alongside Cliff), made way to convince UEFA that the group would no longer exert significant control over the Spanish club, whose qualification for the Champions League had taken everyone by surprise. About a quarter of CFG’s stake in Girona was transferred to a blind trust. Matthew Shayle was called in to take one of their spots on the board, the other two being offered to Edward Hall and Paul Hunston – who also happen to work for the law firm Wiggin Osborne Fullerlove.
As Girona failed to qualify for the 2025-26 UEFA Champions League, there was no need for Shayle to stay on, and he vacated his seat on the Girona FC board (which is presided over by Pep Guardiola’s brother Pere) on 1 June 2025.
A Girona FC Extraordinary Shareholders’ Meeting held on 1 July 2025 then announced the appointment of three “new” directors – none other than Simon Cliff, John MacBeath and Ingo Bank. Job done.
The unknown
In Marinakis’s case, the “blind trust” trick was played in full view, and the names of the persons and entities which took part in the process were a matter of public record. Things are different when it comes to Ratcliffe’s (**).
The name of the British company used by the Monaco tax exile has not been made public. Josimar contacted Lausanne Sport and received the following answer: “the club does not wish to communicate the name of the independent company”.
Josimar also approached the Swiss League, Ineos and Uefa with a list of detailed questions, but we received no reply to our inquiries. Swiss media outlets which tried to find out the identity of Lausanne Sport’s new (and ephemeral) “owner” also met with the same silence.
There was an almost farcical element to the “transfer of ownership” which affected the Swiss club and was announced on 1 March, just in time to meet the Uefa deadline. In order to “avoid any conflict of interest”, Lausanne’s president Leen Heemskerk resigned from his position that day, to be replaced by his vice-president Vincent Steinmann. The rest can be guessed. As soon as it became clear that there would be no “conflict of interest”, as Lausanne Sport did not qualify for any European competition, Ratcliffe reasserted control of the club, whilst Heemskerk got his presidency back, with Steinmann resuming his duties at Number 2.
At which point does the ‘letter of the law’ become a meaningless charade?
The architect
It could be said that Marinakis and Ratcliffe (and those who are bound to use the same trick in the future) were smart enough to beat the system at its own game, and that it is the system itself which is culpable. The door was left ajar – all they did was to push it open.
The problem is, however, that it is Uefa which unlocked it. More than that, it had signposted the exit.
Multiple sources have now confirmed to Josimar that the “blind trust” mechanism is the brainchild of Sunil Gulati, the very man who is supposed to be the gamekeeper in all things financial for Uefa. Gulati, an M.Phil in economics trained at Columbia University, is a close friend of president Aleksandr Čeferin, with whom he served on the Fifa council. Their families are said to have holidayed together, and Gulati’s son Emilio, now working for MLS, also did an internship in the finance division of the European confederation in 2018.
Josimar asked UEFA whether it was correct that it was them who had told specific clubs and owners in potential breach of MCO regulations how to circumvent them, and which role Mr Gulati had played in these exchanges. Those questions were sent four weeks ago, but we received no reply.
We also asked UEFA how the use of “blind trusts”, which they actively promote as a “solution” for MCO entities and the non-disclosure of the identity of the trustees conformed with the stated objectives of UEFA’s United For Success strategy plan for the 2024-2030 period, which states that UEFA is committed “to open competition and the European sports model, to transparent decision-making [our italics] and to staging the best sporting events in the world”. No response was given either.
In practical terms, in the current state of things, there is no longer any real obstacle put in the way of MCO entities wishing to see as many of their clubs compete in Europe. It has been clear for a few years now that Aleksandr Čeferin, once an MCO sceptic, had warmed to the idea of giving those entities a freer rein. Gone, it seems, are the concerns articulated in UEFA’s 2019 Together For The Future of Football policy document, in which one could read that “multi-club ownership within and across European leagues, has increasingly become a means of hoarding players and can affect the integrity and competitiveness of all competitions”.
The Red Bull franchises RB Salzburg and RB Leipzig had successfully pleaded that there were enough degrees of separation in their day-to-day operations to warrant inclusion in European tournaments. More recently, in 2023, Čeferin had said that “[UEFA] shouldn’t just say no [to] the investments, and for multi-club ownership; but we have to see what kind of rules we set in that case, because the rules have to be strict”.
Just do what you’re told, and you’ll be fine.
Which is exactly what Nottingham Forest and Lausanne appear to have done, as Girona and OGC Nice had done before them.
(*) Drogheda’s owner, the Trivela Group, also has a majority interest in Danish outfit Silkeborg, whilst Dunajka Streda and Hungarian club Győri ETO both are the property of businessman (and friend of Hungarian PM Viktor Orbán) Oszkár Világi. As Silkeborg and Győri ETO, which had also qualified for the Conference League, have a higher UEFA ranking, they were given the green light to take part in that tournament to the detriment of their sister clubs.
(**) Jim Ratcliffe had already used this trick with OGC Nice last season, when the French club competed in the UEFA Europa League alongside Manchester United. The name of the company used in that operation was not made public either.
