The shareholder lists of Colombian football teams make for interesting reading — if you're reading them from an anti-money laundering point of view. These lists can sometimes include hundreds of shareholders with no national identification numbers. One list shows an instance where in excess of 1,000 shareholders were listed at the same address.

While pro sports stars are considered PEPs (Politically Exposed Persons) in Colombia, the people who own the clubs are not and, therefore, aren't subject to any specific additional scrutiny. However, any such large pool of wealth ought to be considered as a tempting target for financial crime.

As Willie Sutton, a prolific U.S. bank robber, once said when asked why he robbed banks, “because that’s where the money is.” So, too, regulated firms should cast their lines in well-stocked waters where the “big fish” likely are rather than limit themselves to the narrow confines of the regulatory requirements.