Under the Fraud Act 2006, dishonestly making false representations with intent to gain or avoid loss can result in up to 10 years’ imprisonment and unlimited fines if charges are proven.
Lord Cruddas, a banker and businessman, stated, “The Manchester City findings now appear to be a police matter.”
He added, “If accounts were falsified and auditors misled, this becomes a potential criminal matter. Auditors would involve the police, and directors bear personal liability for fraud involving a UK company, regardless of foreign ownership.”
For the matter to escalate beyond football misconduct, a formal investigation by the relevant authorities would first be required.
UK bodies authorized to investigate potential financial crimes include regional police forces, the National Crime Agency, HMRC, and the Serious Fraud Office.
BBC Sport contacted each agency and received no indication that an investigation had commenced, though some do not routinely confirm inquiries due to confidentiality protocols.
Former Manchester City chairman David Bernstein, who departed the club five years before its current ownership took over, raised this possibility during a BBC Radio 5 Live interview.
“This is very serious, and I wonder whether some of these issues need to be referred to authorities beyond the league,” Bernstein said.
His immediate concern was whether the board could remain in place and whether those involved should be suspended without delay.
Football finance expert Kieran Maguire believes a broader investigation is unlikely.
“HMRC might consider it, but there is little to act upon,” he said. “There is certainly no corporation tax to recover. Football clubs operate at a loss, and City would have lost more without those activities.”