The documents on agent fees stem from inquiries made over several months in 2016 and 2017 by Kimberly Morris, the head of FIFA TMS Integrity and Compliance department, which monitors transfer activity and ensures football authorities meet transparency rules.

FIFA enacted new reporting procedures in April 2015 that required all licensed football associations, such as the TFF, to provide annual information on every individual who benefited from work as an intermediary – the official term for a player’s agent.

The following March, as the deadline for the first data release passed, the Turks failed to comply with these rules. On 6 July, 2016, Morris writes to Evrim Tarlig, the federation’s TMS manager, reminding him that the organisation is “required to make publicly available on an annual basis… the names of all intermediaries your association has registered as well as the single transactions in which they were involved.”

A few weeks later, the federation finally published some details on its website, but had clearly taken a narrow view of the rules, opting to obscure the value of each agents’ commission. It instead listed the “total amount of all remunerations made to Agents.”

Privately, the TFF had easy access to the full data. On the same day, 20 July 2016, that it issues partial information on its website, the federation’s general secretary Kadir Kardaş replies to Morris with a letter containing a list of 18 payments made to Turkish agents: 1.18 million in euros and 2.90 million in Turkish lira.

The correspondence includes a second document showing that, in fact, clubs paid at least three times more in fees, but these were, Kardaş writes, “payments made to the intermediaries who are not registered to the TFF and involved in transactions with Turkish clubs”. The real figure is €4.31 million and 5.37 million Turkish lira.

FIFA requires that any person acting as an agent in any capacity must register as an intermediary with an appropriate body. Therefore any agent carrying out domestic transfers in Turkey must be licensed in this country. Foreign agents involved in international transfers with a Turkish club must sign a FIFA ‘intermediary declaration form’ and certify that they are a licensed agent, and ensure that a copy of the intermediary agreement with the player is submitted to the TFF.

Morris informs the TFF's Tarlig that the federation is “required to register an intermediary each time that an intermediary is involved in a specific transaction.”

The Turkish Football Federation, as all FIFA-licensed associations, must sign off on all transfer documentation and input it into the TMS – Transfer Matching System – designed to promote transparency in the game.

“According to your information,” Morris continues, “it appears that payments have been made to intermediaries who are not registered with the Turkish Football Federation but who were involved in individual transactions.” She then asks for a “report of all intermediaries who are not registered with the Turkish Football Federation and who were involved in transaction with Turkish clubs. The report should contain the intermediary’s name as well as the single transaction in which he was involved.”

Kardaş then admits that the TFF had “knowledge of the transactions with unregistered intermediaries, when the relevant clubs submit their payment information to the TFF” and supplies a list of 30 transactions between agents and clubs, concluded in 2015 and 2016. These agents, he writes, “have neither applied for license or registration to TFF nor submitted signed intermediary declaration form.”

Sports law professor at Loughborough University in the UK, Serhat Yilmaz, told The Black Sea that it is the responsibility of all parties to make sure that the paperwork is correct:

“All the submitted transfer data goes from the club level to the federation level,” he said. “If all the transfer documentation from both sides matches, and there are no conflicts, then the federation proceeds to request the transfer certificates. The responsibility of the federation is to check and verify all the submitted information and documentation.”

The document Kardaş provides to Morris and FIFA specifies that the 30 questionable payments were made by five clubs: Antalyaspor (in the city of Antalya), Akhisar Belediye Gençlik ve Spor (Akhisar), Bursaspor (Bursa), Çaykur Rizespor (Rize) and Fenerbahçe (Istanbul).

According to the data, Antalyaspor made the highest number, with fifteen payments. These totalled €2.1 million - more than 7 million Turkish lira, according to 2015 rates. The bulk of this money, over €1.06 million - 3.5 million Turkish lira - went to MEC Management Consultancy, the offshore company of Turkish agent, Metin Korkmaz, based in the Marshall Islands, where corporation tax is zero (the company was closed earlier this year). The fees were for services provided during the transfers of players Ramon De Moraes Motta, Omer Hasan Sismanoglu, Yekta Kurtulus, Sahin Aygunes and Charles Fernado Basilio da Silva.

Antalyaspor also paid €300,000 to the company of Korkmaz’s business partner Özkan Doğan, for his part in bringing Cameroon striker Samuel Eto’o to the club. It is not clear in what jurisdiction Doğan’s company, Coach Sport Management, is based. But Doğan and his firm were not named on Eto’o’s employment contract, as required by FIFA rules.

On this contract there is also no mention of Eto’o’s regular agent, Wilfried De Happi, whose CPWS Global Management appears on the list of supposed non-registered agents along with a payment of €200k. A further €120,000 commission for the transfer of Cameroonian central midfielder, Jean II Makoun, which the TFF claims was not properly registered. Di Happi did not reply to questions by the The Black Sea.

Antalyaspor made other problematic payments. The TFF states that the club facilitated a commission of €90,000 – listed as 295,000 Turkish lira on the documents – to Refleks Menajerlik Ltd. Sti, owned by Olgun Peker. Also not a licensed agent, Peker has a long-standing connection to Turkish organised crime, specifically though the Turkish mafia figure, Sedat Peker, whose surname Olgun adopted out of admiration. Sedat has for years been accused of running Turkish illicit sports gambling as well as other criminal activities. FIFA rules state that agents should have an “impeccable reputation”.

Olgun himself was arrested in 2012 over allegations he supplied copies of the TFF exam to prospective Turkish agents. He was later acquitted, as were others accused in the case.

There are also concerns over the paperwork for commissions to two companies during Antalyaspor’s transfer of the Brazilian attacking midfielder Guilherme: €179,625 to Brazilsport, the firm of Spanish agent Ivan Suarez; and €235,732 to El Reda Management. El Reda appears to be based Lebanon, has an unclear owner, and seems to be linked to an individual, Mohamad Reda, who could not be reached for comment.