The Fraud Act 2006 states that dishonestly making a false representation with the intention of making a gain or avoiding a loss can lead to individuals being imprisoned for 10 years and facing an unlimited fine, if charges are brought and proven.
“Surely the Man City findings are now a police matter,” said Lord Cruddas, a banker and businessman.
“If accounts have been falsified and auditors have been misled then it is potentially a criminal matter. The auditors will call in the police, directors are personally liable for any fraud of a UK company even if it is foreign-owned.”
For the case to move from football wrongdoing to something more, there would first need to be an investigation by the relevant authorities.
The bodies who can investigate potential financial crimes in the UK include regional police forces, the National Crime Agency, HMRC and the Serious Fraud Office.
BBC Sport has contacted each of those bodies and been given no indication that any kind of investigation has begun, but some do not routinely confirm investigations owing to confidentiality.
But former Manchester City chairman David Bernstein – who left the club five years before its current owners took control – raised the possibility during an interview on BBC Radio 5 Live.
“This is very serious and I wonder whether some of these issues might need to be referred to authorities outside of the league,” Bernstein said.
“My immediate thoughts are – can the board of directors continue and should the people involved be suspended immediately?”
Football finance expert Kieran Maguire feels wider investigation may be unlikely.
“HMRC might consider it but there is not a lot for them to go on,” he said. “There is certainly no corporation tax to recover. Football clubs lose money and City would have lost more money had it not been for the activities it undertook.”