Sorare, 10M£ Frozen Since January 2025
What Is the NCA Really Investigating?
Another layer of uncertainty in the Sorare story
The UK’s National Crime Agency (NCA) has frozen in January 2025 10M£ in Premier League funds as part of an investigation into partner Sorare. For the full story (published on 31 Aug 2026), read the report at The Sun.
UPDATE (Sept 1, 2026) — Sorare’s response:
Shortly before publishing, Sorare CEO publicly responded on X. He states that the reporting is inaccurate, that Sorare is not under investigation by the UK National Crime Agency (NCA) and that the freezing order concerns funds held in an account that does not belong to Sorare. On the separate Gambling Commission matter, he reiterates that Sorare firmly denies being a gambling product under UK law and intends to keep operating in the UK.
I include this response in full fairness. It is worth noting that it is totally consistent with what my article already states: the frozen funds were reportedly held in the Premier League’s account, not Sorare’s, and my article makes no allegation of wrongdoing against Sorare. A freezing order tied to funds is not the same as a company being a suspect (a distinction I try to respect throughout).
There is one point that needs to be made immediately: a freezing order is not a criminal conviction.
It is not, by itself, proof that Sorare committed a criminal offence. It is not proof that the Premier League committed any wrongdoing. And it certainly does not allow anyone to invent facts that investigators themselves have not made public.
But at the same time, an Account Freezing Order obtained under the UK’s Proceeds of Crime Act is not something that happens because the NCA finds a commercial partnership “interesting”.
The UK NCA obtained an order in January 2025 freezing 10,024,041.33£ held in an account belonging to The Football Association Premier League Limited. The money is understood to be linked to Sorare initial payment under its Premier League licensing agreement (agreement that ended last season, 2025–2026).
The NCA explanation was deliberately brief:
“The purpose of the order is to prevent dissipation of the funds while the NCA investigates any potential links between those funds and alleged third-party criminality.”
The NCA did not specify what alleged criminality it is investigating.
It did not publicly identify the third parties concerned.
And it did not explain the alleged path connecting those funds to that criminality.
So before going any further, it is important to separate what we know from what we do not.
What we know is that 10M£ was frozen under a legal framework designed to deal with suspected proceeds of crime or funds intended for unlawful conduct.
What we do not know is precisely why.
What does an Account Freezing Order actually mean?
Under the relevant provisions of the Proceeds of Crime Act framework, law enforcement can seek an Account Freezing Order where there are reasonable grounds for suspecting that money held in an account is either recoverable property or intended for use in unlawful conduct.
“Recoverable property” is, broadly speaking, property obtained via unlawful conduct or property representing the proceeds of such conduct.
That does not require a criminal conviction before an account can be frozen.
The threshold for obtaining a freezing order is not the same as proving guilt at a criminal trial. The purpose of the measure is, among other things, to prevent funds from disappearing while investigators establish where they came from and whether they may ultimately be subject to recovery or forfeiture.
That is why both of the following statements can be true at the same time:
A freezing order is not proof that Sorare committed a crime.
And:
The existence of a 10M£ freezing order connected to funds reportedly paid by Sorare is still an extremely serious development that deserves scrutiny.
Both things can be true.
An investigation is an investigation. A freezing order is a freezing order.
The words “third-party criminality” matter
“Potential links between those funds and alleged third-party criminality”.
What does “third-party” mean?
The obvious temptation is to conclude that the NCA is saying that neither the Premier League nor Sorare is the suspected originator of the alleged criminality.
That may be one possible interpretation but we should be careful.
The phrase does not publicly clear Sorare of anything. Nor does it accuse Sorare of anything.
It tells us only that the NCA is investigating potential links between the frozen funds and alleged criminality involving third parties.
That leaves several possibilities.
The alleged criminality could potentially concern the source of funds received by Sorare. It could concern particular transactions. It could concern users, counterparties, intermediaries, investors or other entities entirely. It could involve a specific financial flow that has little or nothing to do with Sorare’s ordinary marketplace revenues.
Or, it could involve a much broader investigation whose full context has simply not been made public.
We do not know and anyone claiming to know exactly what the NCA is investigating is currently going beyond the publicly available information.
But there is one hypothetical scenario worth discussing, not because it has been proven, but because it illustrates why platforms like Sorare operating at the intersection of crypto, digital assets and financial transactions inevitably face complex questions about the origin of funds.
Could illicit crypto have entered a platform and become part of legitimate corporate revenue?
In theory, yes.
But theory is not evidence.
Imagine a hypothetical situation: a third party possesses cryptocurrency derived from criminal activity. That individual uses the cryptocurrency to purchase digital assets or services on a platform. The platform receives the value from that transaction. That money becomes part of the broader financial ecosystem of the company. It may be converted, transferred, consolidated with other revenues or held alongside legitimate funds. The company then makes an entirely legitimate commercial payment to a third party.
Could questions arise about whether some of the money moving via that system originated in unlawful conduct?
Of course. That is one of the fundamental challenges of financial crime enforcement.
Digital assets do not magically become legitimate simply because they have passed via multiple transactions.
At the same time, it would be irresponsible to jump from that general principle to the assertion that this is what happened at Sorare. Like I said, we do not know that.
The structure of digital asset platforms creates obvious challenges around tracing the origin of funds, particularly when large volumes of transactions involve cryptocurrencies and assets that move between users.
And that is precisely why the NCA wording raises legitimate questions.
Questions are not accusations but they are still questions.
Crypto is not a footnote here
For anyone who has followed Sorare from the beginning, crypto is not some minor detail that can be added to the story as an afterthought.
It is part of the platform’s DNA (or, today, what it’s left 🥲).
Sorare eventually evolved. Fiat transactions became accessible. The product expanded. The user experience became less dependent on an explicit understanding of crypto.
But that does not erase where the platform came from or the financial infrastructure around which its original ecosystem was built.
And anyone who has spent more than five minutes looking at the history of cryptocurrency knows something else:
Since roughly the early 2010s, crypto has attracted not only genuine technological innovation and legitimate investment. It has also attracted fraudsters, hackers, criminal organizations, money launderers and every imaginable form of financial abuse.
That does not mean everyone using crypto is a criminal. And it certainly does not mean every crypto company is laundering money.
But it does mean that platforms handling significant volumes of crypto-related value operate in an environment where AML controls and source-of-funds questions are not theoretical issues. They are part of the landscape.
Which brings us back to the 10M£ question. If the NCA is investigating potential links between these specific funds and alleged third-party criminality, what exactly is the alleged connection?
(At the time of writing, we simply do not know).
The Premier League is not accused of wrongdoing
The reporting makes clear that there is no suggestion of wrongdoing by the Premier League itself.
The Premier League entered into a commercial licensing agreement with Sorare. The existence of a legitimate commercial relationship does not itself create criminal liability. Nor does receiving payment under such an agreement automatically mean the recipient knows anything about the ultimate history of every pound used to make that payment.
This is precisely why the situation is interesting from a legal and financial perspective. The frozen funds were reportedly sitting in the Premier League’s account. The money had already moved. The commercial transaction had taken place.
Yet, the funds were subsequently frozen while the NCA investigated potential links to alleged criminality.
Again, this does not tell us who did what but it demonstrates something important:
Following the money does not necessarily stop at the first legitimate-looking commercial transaction.
That is the entire point of proceeds-of-crime legislation.
The date is the most fun part of the story
An interesting detail is not even the amount. It is the date:
January 2025.
The freezing order reportedly existed for well over a year before the public learned about it.
Think about everything that has happened around Sorare since then. The continued transformation of the product (🤕). The evolution of its game economy (😬). The growing emphasis on new reward mechanics. The debate around in-season cards (🤢). The DNP solution (😉).
The progressive marginalization of what many early users considered the core identity of the platform. The increasing importance of maintaining engagement. The regulatory developments in different jurisdictions.
The JONUM framework in France. And, of course, the ongoing UK Gambling Commission case.
All while this 10M£ freezing order reportedly existed in the background.
I am not saying Sorare was hiding a criminal offence. There is no basis for claiming that. But it does mean that the public story surrounding Sorare was potentially incomplete.
Even if Sorare is a private company, users, collectors and investors have spent years trying to understand what Sorare actually is becoming.
A fantasy game? A collectibles platform? A blockchain company? A gaming company? A gambling-adjacent product? A Web3 marketplace? A free-to-play mobile-style game with monetized progression systems?
I believe the answer appears to be:
All of the above, depending on which part of the product you are looking at.
And that complexity creates risk.
This is why I wrote “Sorare: A Legal Time Bomb?”
When I wrote Sorare: A Legal Time Bomb?, I was absolutely not claiming to know the future.
I was certainly not claiming to know that a specific criminal investigation would emerge.
The point was much broader.
Sorare had accumulated an extraordinary number of potential pressure points:
The gambling question. The regulatory question. The crypto question. The business model question. The rewards question. The speculation question. The licensing question.
Add to that:
The question of whether digital cards should be treated primarily as collectibles, game pieces or financial assets.
The question of what happens when a platform built around scarcity progressively changes the economic value proposition of that scarcity.
The question of what happens when users are encouraged to chase rewards whose value increasingly depends on the platform’s own economic decisions.
The question of how sustainable a product becomes when it constantly needs new mechanisms to retain engagement.
All of that was my real concern. It was not just one single catastrophe.
The accumulation of risks.
That is what makes the latest revelation so striking. The UK Gambling Commission prosecution was already one major legal cloud hanging over Sorare.
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Now we learn that, since January 2025, more than 10M£ linked to the Premier League payment has reportedly been frozen while the NCA investigates potential links to alleged third-party criminality.
These are separate issues and they should not be artificially merged into one accusation.
The Gambling Commission case is not proof of financial criminality and the freezing order is not proof that Sorare operated an illegal gambling service.
But together they illustrate something:
Sorare does not face one isolated question.
It faces an ecosystem of questions.
And the more those questions accumulate, the harder it becomes to dismiss every single one as irrelevant.
The gambling case is still there
This is another point that should not be forgotten.
The freezing order story does not replace the Gambling Commission case.
It exists alongside it. Sorare has firmly denied that its product constitutes gambling under UK law and maintains that its game is based on skill rather than chance.
That legal argument will ultimately have to be tested via the judicial process. But the practical reality is that the case has been hanging over the company for years.
The proceedings have been pushed back again, with a trial now expected in the summer of 2027. That means the uncertainty is not disappearing tomorrow.
Sorare may continue operating for many more months with one major unresolved legal question still hanging over the business.
Now add the NCA freezing order to the broader picture.
Again:
These are not the same case. One does not prove the other.
But from a business and reputational perspective, companies do not operate in legal silos.
Users see the headlines. Partners see the headlines. Potential investors see the headlines. Regulators see the headlines.
And every new legal or financial development becomes part of the broader perception of risk. I believe, that matters.
A collectibles platform that forgot the collectors
For me, the irony is that the legal and financial questions surrounding Sorare are only one part of the story.
The other part is the product itself. Over the years, I have written extensively about what Sorare has progressively become.
In Sorare: A Collectibles Platform That Forgot the Collectors, I questioned whether the company had moved away from the very people who helped build the original ecosystem.
In Classic Cards Aren’t the Past. They Are the Point, I argued that the obsession with constantly pushing users towards the newest cards misunderstands what made collecting meaningful in the first place.
In my work on the JONUM decree, I looked at the increasingly complex regulatory environment surrounding monetizable digital objects in France, where Sorare HQ is located.
And more recently, I have written about Sorare’s World Cup strategy and what it says about the direction of the product.
These articles are not all about the same issue but they are about different pieces of the same puzzle:
The product. The economy. The regulation. The cards. The rewards. The monetization. The identity crisis. The legal environment. The future of digital ownership.
For years, Sorare has been trying to reinvent itself. Perhaps that was inevitable.
The problem is that every reinvention creates new questions.
And sometimes, in trying to solve one problem, a company creates another.
The transformation of Sorare economy
One of the biggest changes has been the gradual transformation of what participation in Sorare actually feels like.
The original appeal was relatively straightforward.
You collected scarce digital cards. You built teams. You competed. Your cards had utility. And they also had an identity beyond the next competition. They were collectibles. They could be held / traded / sold. Used across seasons. The relationship between the user and the asset was supposed to be central.
That philosophy became difficult to maintain as the platform evolved.
New seasons required new demand. New cards required utility. Reward structures required constant balancing.
The distinction between old and new cards became increasingly important.
And eventually, the product began moving closer to an economy in which constant participation and progression mechanisms became central.
Rewards. Essence. Crafting. Prize pools. In-season utility. Sealed experiences. Free-to-play mechanics. Boosts. Credits.
What is Sorare actually trying to optimise?
Collecting? Competition? Engagement? Retention? Revenue? User acquisition?
All businesses need revenue.
But the way revenue is generated inevitably influences the design of the product.
And that brings us to Sorare Set.
The irony of Sorare Set
There is something almost darkly amusing about the timing of all this.
While major legal and regulatory questions remain unresolved, Sorare has increasingly developed game modes that can generate revenue via systems that are much easier to understand from a traditional gaming perspective.
Sorare Set is interesting because it represents a different economic model.
Free-to-play access. Also, clearly P2W. Digital progression. Monetised boosts. Gems. Raffles. Limited-time events.
Mechanics that look increasingly familiar to anyone who has spent time around modern mobile games 🙃.
And from a business perspective, it creates direct monetisation opportunities. It reduces dependence on the traditional secondary-market economy. It potentially allows Sorare to monetise a much larger audience.
And unlike a traditional marketplace model, the company has far more direct control over the flow of value.
So yes, there is an irony here.
While the original Web3 model faces questions about regulation, speculation, gambling and now an unexplained freezing order involving a 10M£ PL payment, Sorare has now other ways to generate revenue.
Perhaps that is not an accident and it is simply the natural evolution of a company trying to survive in a much more difficult environment than the one in which it was born.
And now, uncertainty
Investors can analyze a bad quarter. Companies can adapt to a new regulation. Businesses can settle disputes.
Users can decide whether they accept a particular product.
But prolonged uncertainty is corrosive and Sorare has accumulated a hell amount of it.
Will the UK courts ultimately agree that Sorare falls within gambling legislation?
How will regulators interpret monetisable digital objects in different jurisdictions?
How will the JONUM framework affect the French market?
What is the long-term role of crypto within the company?
How sustainable is the card economy?
What happens to the value proposition of older (aka Classic) cards?
How much can Sorare rely on new monetisation systems?
What does “collecting” even mean in the modern Sorare ecosystem?
And “now” (bis):
What exactly is the NCA investigating in relation to the 10M£ frozen in the PL account?
This is not a conviction but it is not nothing
There will inevitably be two predictable reactions to this story.
The first will be outrage.
People will say that the freezing order proves everything they have ever suspected about Sorare.
It does not.
The second will be dismissal.
People will say that because there has been no conviction and no detailed public accusation, the story is meaningless.
That is equally absurd.
A 10M£ freezing order obtained by the NCA under proceeds-of-crime legislation is not a meaningless event.
The fact that investigators reportedly considered it necessary to prevent the dissipation of the funds while examining potential links to alleged criminality is notable.
The fact that the order reportedly dates back to January 2025 is significant.
The fact that the NCA has not publicly identified the alleged criminality makes the situation more (not less) worthy of careful scrutiny.
Legal time bomb
Looking back at Sorare: A Legal Time Bomb?, the phrase “time bomb” can easily be misunderstood.
People imagine one dramatic moment.
One court decision. One regulatory ban. One scandal. One collapse.
In my opinion, the real danger is slower. More complicated and much more difficult to solve.
A company does not necessarily collapse because of one problem.
Sometimes it is the accumulation.
A regulatory dispute here. A declining marketplace there. A legal case that takes years to resolve. A constantly changing product economy. Users losing confidence in the long-term value of their collections. The need to introduce increasingly aggressive engagement mechanisms. New regulatory frameworks. New compliance costs. New questions from commercial partners. New doubts from users.
One issue can be managed. Several issues can be managed.
But eventually, management itself becomes the business.
And that is where my “legal time bomb” analogy kicks in.
I never asked if Sorare would suddenly wake up one morning and disappear.
I just wanted to know if Sorare could continue carrying an ever-growing number of unresolved risks without one of them eventually becoming impossible to contain.
This article follows my previous notes on Sorare. I make no allegation that Sorare, the Premier League or any individual has committed a criminal offence in connection with the NCA freezing order. The analysis above is based on publicly reported information and the legal framework governing Account Freezing Orders in the United Kingdom. The specific alleged criminality referred to by the NCA has not been publicly identified at the time of writing (Aug 31, 2026).
