UNODC Releases a Report on Corruption in Sport

The Global Report on Corruption in Sport was prepared under the overall guidance of the United Nations Office on Drugs and Crime with the financial support of the Russian Federation and Norway and the participation of over 180 experts from across the world and sectors, including representatives of governments, international and sports organisations, and the private sector, as well as experts of the Anti-Corruption Centre of the National Research University “Higher School of Economics”.

The authors of the Report stress that corruption in sport is not a new phenomenon: fraudulent activities have been documented since the times of the Ancient Olympic Games. However, it is in the recent decades that a considerable multiplication of criminal activities has been registered in this area due to globalization, significant investments, primarily in professional sports, fast growth of legal and illegal betting, as well as rapid development of ICTs.

As a consequence, corruption in sport is becoming an ever more important topic attracting close attention in different international venues: international organisations are gradually moving from isolated general statements expressing commitment to the fight against corruption in this area to the adoption of dedicated documents centered on safeguarding sport from corruption. In particular, the Conference of the States parties to the UN Convention against Corruption (UNCAC) adopted resolutions 7/8 on corruption in sport and 8/4 on safeguarding sport from corruption in its sessions in 2017 and 2019 respectively. Additionally, the G20 summit in 2021 concluded with the endorsement of the High-Level Principles on Tackling Corruption in Sport. Furthermore, different analytical papers addressing this subject are being released.

The content of the new comprehensive study prepared by UNODC covers ten areas. Each section of the Report can be downloaded as a separate file.

1. Evolutions in sport related to corruption

This section of the Report explores key trends in sport, including the impact of globalization, economic and technological innovations on it. The section also provides a summary of corruption risks in the three most relevant areas - competition manipulation, corruption within sports organisations, corruption risks linked to criminal infiltration (these practices are addressed in further detail in other sections of the Report) – along with the main reforms undertaken by international sports organisations to tackle them.

2. Applying the United Nations Convention against Corruption to Sport

This section analyses the applicability of UNCAC provisions to offences in sport. These include, in particular:

1) Corruption prevention measures, including the development of general anti-corruption policies, implementation of standards of conduct, adoption of good governance and transparency measures, anti-corruption safeguards in procurement and hosting of sporting events, anti-corruption training etc.;

2) Criminalisation of corrupt practices and enforcement of relevant provisions also through the criminalisation of corruption in the private and public sectors, establishment of corruption in sport as a separate corpus delicti, enforcement of fraud and money laundering provisions;

3) Law enforcement, including the establishment and operation of competent bodies, implementation of mechanisms for reporting offences to competent authorities, use of special investigative techniques, enforcement of extraterritorial anti-corruption legislation;

4) International cooperation in different lines of action against corruption, including prevention, investigation and prosecution of perpetrators.

The authors of the Report stress that not only the States parties but also sports organisations can refer to the UNCAC provisions in the fight against corruption in sport, adapting them to their context to create their own prevention, detection, investigation and sanctions systems.

Additionally, this section provides recommendations on how to apply the UNCAC to the sports sector:

Governments can do this by:

Effectively implementing the UNCAC;
Developing comprehensive policies on anti-corruption in sport based on an assessment of the corruption risks faced, including where applicable, but not limited to, those related to the organization of major sports events, competition manipulation and illegal betting, and those that negatively impact children, young athletes and other vulnerable groups;
Establishing a body or bodies that have responsibility for the prevention, detection, investigation and sanctioning of corruption in sport;
Supporting programmes, projects, task forces, expert groups and existing initiatives that promote and enhance cooperation and the exchange of information and good practices among law enforcement agencies, criminal justice authorities, corruption prevention authorities, lawmakers and policymakers;

2.Sports organisations can achieve this goal by:

Reviewing and updating, where necessary, their rules and regulation to align with the principles of the United Nations Convention against Corruption;
Including public reporting on corruption risks in their organization as part of their information disclosure policies;
Developing comprehensive anti-corruption policies based on an assessment of corruption risks faced by their organizations;
Developing, implementing and simplifying their mechanisms for reporting acts of corruption, including the possibility of anonymous reporting;
Providing staff with access to services that can provide confidential advice on ways to prevent, mitigate and remedy conflicts of interest;
Developing and implementing procedures for the selection of individuals for positions considered especially vulnerable to corruption;
Establishing a body or bodies that have responsibility for the prevention, detection, investigation and sanction of corruption. These bodies should be provided with the necessary independence, training and resources required to carry out their functions.

3. Overview of international initiatives to tackle corruption in sport

This section provides information about initiatives aimed at countering corruption in sport that either operate at the national level or are implemented by international organisations.

The Report, in particular, provides the following examples:

1) Dedicated laws, codes of conduct, anti-corruption policies of different countries, such as Mozambique’s Code of Ethics and Sporting Conduct that establishes guiding principles for athletes, coaches, referees, sports managers and administrators, spectators, organizers of sporting events and volunteers; good management practices adopted by the Estonian Olympic Committee the adherence to which affects the decision on funding of sports organisations; Samoa National Sports Framework 2018-2028 that provides, among other things, for the establishment and strengthening of systems for record-keeping, financial management, accountability and data management in national sports organizations etc.;

2) Countries’ approaches towards the implementation of institutional and coordination mechanisms to tackle corruption in sport. The authors highlight that most counties opt for the approach based on the establishment of a central body, such as a working group or a task force, to serve as a focal point for the development, implementation and monitoring of policies designed to tackle corruption in sport such as Angola’s National Council for Discipline and Ethics in Sport responsible for settling administrative conflicts, the Sport Integrity Unit of the Japan Sport Council whose activity covers monitoring of sports organizations and implementation of programmes to prevent improper activities or behaviour that threaten the integrity of sport (for example, the provision of education programmes for sports organizations); in Australia, there is Sport Integrity Australia, a dedicated body in charge of developing a comprehensive approach to fighting corruption in sport etc.

The part focused on international initiatives provides detailed information on the guidance and useful publications on the fight against corruption in sport released by the United Nations, Council of Europe, European Union, G20, OECD, Interpol, FATF, International Partnership Against Corruption in Sport (IPACS), and Sport Integrity Global Alliance (SIGA).

Additionally, the section contains recommendations on how to improve the action of governments and sports organisations in tackling corruption in sport:

Assessing risks of corruption in sport and developing, implementing and monitoring risk mitigation strategies and plans;
Establishing a specialist body or bodies that have a responsibility for the prevention, detection, investigation and sanctioning of corruption in sport;
Establishing and supporting programmes to provide training and education, ensuring that such programmes are tailored to the specific needs and characteristics of different actors, particularly children, young athletes and vulnerable groups;
Publishing the reports of existing specialized bodies to increase understanding of how they function and identify and share good practices.

4. Detecting and reporting corruption in sport

Section four of the Report is centered on the use of different mechanisms for detecting corruption offences that have actually proven to be difficult to detect due to the fact that those involved in a corruption-related act employ sophisticated methods to conceal their activities, whereas the persons aware of corrupt practices may not disclose this information out of fear of reprisal. The detection mechanisms can be either proactive (for instance, betting monitoring and alert systems that highlight incidences of competition manipulation or breaches of betting rules, undercover investigations, investigations by journalists) or reactive (investigations in response to a report of corruption, and reporting of alleged acts of corruption).

This section explores, in particular, different reporting mechanisms, including those employed by sports organisations, measures to protect whistleblowers, opportunities provided by ICTs to detect offences and report them (for example, many sports organisations have access to the databases monitoring licenced and unlicenced betting markets thereby identifying incidences of “suspicious betting activity”), proper regulation of activities of investigative journalists etc., as well as examples of initiatives aimed at detecting corruption in sport implemented by different countries.

For instance, the Government of India requires national sports federations to publish a calendar of their competitions on their websites, indicating the venues and dates of the competitions and the selection criteria for participation in these competitions; furthermore, the Government has appointed National Observers in select sports that are responsible for ensuring the fair and transparent selection of players and teams, and for examining complaints from players and other stakeholders, and when appropriate, for addressing the issues with the relevant national sports federations. The Brazilian Football Confederation operates a reporting channel (the Brazilian Football Ethics Channel) that receives corruption-related complaints, and has also established the Brazilian Football Ethics Committee. New Zealand has established an independent Integrity Working Group to look at how the country’s sport integrity institutional arrangements might be improved.

In order to improve the mechanisms for detecting and reporting instances of corruption in sport the authors of the Report recommend the following.

1) Governments can achieve these objectives by:

Providing adequate training, resources and equipment for investigators from relevant law enforcement and criminal justice authorities working on corruption in sport cases;
Encouraging and enabling free and independent media and investigative journalism;
Establishing mechanisms at the national level, such as specialized units, national platforms, task forces and working groups, to act as information and exchange hubs and points of contact for international cooperation to support proactive and reactive detection activities;
Establishing and maintaining mechanisms for reporting of corruption and for the effective protection for reporting persons, as well as witnesses and victims, their relatives and other persons close to them;

2) Sports organisations can strengthen the detection and reporting of corruption by:

Developing and implementing effective systems for reporting wrongdoing;
Establishing focal points, specialized units and sufficient internal controls to assist in preventing, detecting and investigating acts of wrongdoing, including corruption;
Periodically reporting on activities, undergoing independent auditing, considering the use of external specialist service providers and developing codes of conduct and conflict-of-interest policies for relevant members, in particular those in receipt of public funds etc.

5. Gender and corruption in sport

The section addresses issues related to gender inequalities in sport, including the lack of women in sport governing structures, pay gap, different abuses, including abuse of functions and sextortion etc.

In order to solve these problems the authors of the Report recommend, in particular:

1) As regards governments:

Increasing investment in the development of women’s sport and supporting equal opportunities for girls in sport;
Strengthening legislation to prevent and respond to violence against women and girls in sport, including sextortion;
Conducting studies to enhance understanding of the risk factors, social norms and cultural traditions that influence women’s participation in and resistance to different forms of corruption in sport etc.;

2) As regards sports organisations:

Promoting women to decision-making roles and increasing training opportunities;
Implementing policies aimed at eliminating harmful gender stereotypes and promoting positive role models;
Increasing opportunities for female athletes to benefit from sponsorships and ensuring an equal living wage for women in sport etc.

6. Organised crime and sport

The section explores the exploitation of sport by organised criminal groups and the measures to counter related crimes.

In particular, the provisions of international treaties (the UNCAC and the UN Convention against Transnational Organised Crime) applicable to the fight against organised crime in sport, the characteristics of involvement of organised crime in illegal activities in sport, key issues, trends and main forms of such illegal activities are analysed. Organised criminal groups can, in particular:

infiltrate in sport organizations, especially football clubs of minor or non-professional leagues, to exert influence and launder money, including through fake sponsorships;
exercise control over illegal betting;
be involved in competition manipulation;
manipulate public procurement processes for the construction of sport infrastructure etc.

Besides that, the paper provides cases of liability of organised criminal groups for corruption crimes in sport in specific countries. For instance, the authors provide details of a case related to Kenya where a former Minister of Sport and three other officials in the Ministry of Sport, together with the former President of the National Olympic Committee of Kenya (NOCK) and three other NOCK officials were charged with embezzlement relating to funds for the 2016 Olympic Games; in Turkey, 61 individuals were arrested, including club managers and national team players, on suspicion of being involved in the fixing of 19 football matches; an investigation by the Moldovan National Anticorruption Centre, with the support of Europol, revealed that half of the teams in the Moldovan top league were involved in the fixing of around 20 football matches: criminals would influence the outcome of the games and bet mostly on the Asian market.

In order to counter organised crime in sport, the authors put forward the following recommendations:

1) For governments:

Implementing the provisions of the abovementioned UN conventions;
Undertaking comprehensive organised crime and corruption threat assessments in sport at local, national, regional and global levels;
Creating specialised bodies to tackle organised crime in sport, providing them with appropriate financial, technical and human resources and implementing training programmes;
Establishing cooperation mechanisms between law enforcement, sport organisations and related stakeholders to facilitate the exchange of information and good practices in the prevention and adjudication of organised criminal groups exploiting sport;

2) For sports organisations:

Enhancing transparency and accountability in relation to the transfer of athletes and by establishing control and voluntary disclosure mechanisms for managers, employees and athletes and by regularly assessing their specific risks of infiltration by organised crime;
Conduct due diligence of investors, commercial partners, agents and intermediaries involved in activities and transactions which are exposed to heightened risks of corruption, money-laundering and other economic crimes;
Publishing annual reports and information on revenues and expenditures etc.

7. Corruption and abuse in sport

The section is devoted to the issues of abuse and violence in sport, including sexual exploitation, as well as to the matters of abuse of functions, bribery, and protection of whistleblowers, experts and victims.

The authors make the following considerations in this regard:

1) Addressed to governments:

Developing and implementing legislation making it mandatory for all sports institutions to have safeguarding policies and procedures in place, in line with the Guiding Principles on Business and Human Rights, including undertaking background checks of any individual working with children in sport as a requirement to receive public funding;
Ensuring timely and effective investigations and prosecutions of and judgments on individual perpetrators and any legal person responsible for acts of abuse in sport;
Providing all-encompassing services for survivors, including health care, social services, victim support, protection, and legal aid etc.;

2) Addressed to sports organisations:

Enhancing governance, transparency and accountability mechanisms to promote integrity and to effectively tackle abuse in sport;
Adopting a zero-tolerance policy on any form of abuse by developing codes of conduct, rules, regulations and conflict-of-interest policies;
Consulting with survivors to develop survivor-centred policies and protocols;
Establishing operational-level grievance mechanisms for individuals and communities affected by abuse and violence in sports etc.

8. Manipulation of sports competitions

The section analyses one of the most widespread corrupt practices in sport, i.e. manipulation of sports competitions. The authors highlight that manipulation can provide a sporting advantage (for instance, to ensure a perceived advantageous competition draw) or ensure a pre-determined outcome, on which a bet is placed. Given that few jurisdictions criminalise this kind of misconduct (as highlighted in a UN report, 45 countries have introduced such corpus delicti in their legislation so far), individuals and organised criminal groups operating outside sports disciplinary framework can carry out these unlawful activities. Furthermore, the growth of e-sports and virtual gaming that have already become subject to manipulations with no single governing body that would exercise their regulation and monitor the compliance with the law pose even bigger challenge.

The section explores specific instruments that can be employed to counter the manipulation of sports competitions at the international and domestic levels, as well as at the level of sports organisations, along with national practices in detecting and disclosing, monitoring and investigating instances of competition manipulation and sanctions imposed. In Romania for instance, a whistle-blower protection law was adapted to cover reporting in sport. To bring its practices in line with the new law, the Romanian Football Federation established a multi-actor platform entitled Clean Football to allow staff, athletes and match officials to report corrupt acts using institutional channels. Police of Victoria, a state in Australia, established a Sporting Integrity Intelligence Unit which is responsible for investigating match-fixing and corruption linked to sports betting, preventing illegal betting and disrupting organized criminal networks.

To counter the manipulation of sports competitions, the authors of the report make the following recommendations:

1) As regards governments:

Supporting more effective application of existing legislation to the manipulation of sports competitions or, where appropriate, supporting the development of specific legislation to criminalise the manipulation of sports competitions;
Organising awareness-raising sessions for officials from relevant government entities, sports organizations and related stakeholders on the threat posed by competition manipulation;
Ensuring the existence of adequate regulatory powers to compel betting operators to have in place robust suspicious-betting monitoring mechanisms and obligations to report such information, or disclose it when demanded, in support of investigations etc.

2) As regards sports organisations:

Establishing and implementing rules, standards and regulations on tackling competition manipulation that comply with the Olympic Movement Code on the Prevention of the Manipulation of Competitions;
Establishing and implementing sports integrity programmes for members and relevant stakeholders, including the prioritizing of awareness-raising among sports persons and other personnel, developing and implementing reporting mechanisms in sport, and promoting existing mechanisms among relevant stakeholders;
Ensuring strict security measures are employed at sports venues and the hotels used by key actors during matches and competitions to stop approaches by those engaged in competition manipulation etc.

3) As regards betting operators:

Supporting sports organizations and government agencies in their fight against competition manipulation using investigation and intelligence tools;
Establishing and implementing compliance programmes for members and relevant stakeholders, including conflict-of-interest and inside-information provisions;
Establishing suspicious betting monitoring mechanisms and reporting such suspicious activity to relevant government authorities.

9. Illegal betting and sport

This section analyses the characteristics of legal and illegal betting on sports events, their connection with money laundering and misuse by organised criminal groups. The Report stresses that the following categorizations can be used to describe sports betting activity: white market (betting operators licenced to operate in all jurisdictions in which they take bets), grey market (betting operators licenced in at least one jurisdiction but take bets in areas where the betting product is illegal), and black market (unlicenced betting operators that operate in multiple jurisdictions and can be understood as a form of transnational organized crime). Illegal betting operators are subject to none of the anti-money-laundering oversight measures present in the legal betting or financial industries (such measures make it possible to prevent the use of betting to conceal the transfer of proceeds of corruption). Yet another challenge is that many betting operators exist only virtually and accept cryptocurrencies for betting.

This section also provides some examples of the initiatives and legal provisions of different countries and sports organisations aimed at countering illegal betting. Malta, for instance, has a three-tier framework of gambling legislation based on the Gaming Act, regulations published by the ministry responsible for gaming and directives for licencees and rules published by the Malta Gaming Authority; in 2018, a dedicated unit was set up in the Authority and was tasked with the carrying out of supervisory examinations to ensure that gaming licence holders have the necessary policies, measures, controls and procedures in place and that these are effectively being implemented to prevent their businesses from being misused for money-laundering purposes. The Swiss Federal Gaming Commission is responsible, among other things, for blocking access to illegal online offers and prosecuting criminal offences involving illegal gambling.

In order to counter illegal betting and related crimes the authors put forward the following recommendations:

1) For governments:

Ensuring national legislation includes laws that appropriately criminalise illegal betting and related manipulation of sport competitions, including obliging betting operators that offer betting on sports events to report instances of suspicious betting to regulators;
Developing regulations that require licenced betting operators to publish an official list of shareholders, parent companies and subsidiaries, to make clear the identity of their owners;
Encouraging relevant law enforcement and criminal justice authorities to consider illegal betting activities that involve laundering proceeds from illegal and criminal activity as dealing with the proceeds of crime etc.;

2) For betting regulators:

Establishing anti-money-laundering units to encourage an enhanced holistic view of licenced gaming operators from a supervisory and monitoring perspective;
Ensuring that anti-money-laundering controls include the following: anti-money-laundering requirements that follow Financial Action Task Force guidelines; the banning of the use of anonymous payment processing firms by betting operators; the recording of customer identification and betting data; the reporting to financial crime authorities of suspicious transactions and instances when a certain large bet threshold has been breached by an individual or a multiple associated transaction.

10. Major sports events and corruption

The last section of the Report is centered on corrupt practices and related planning and delivery of large-scale sporting events.

The authors of the Report stress that major sporting events, which require substantial amounts of funds, complex logistical arrangements and the co-operation of a varied group of stakeholders, are vulnerable to such violations as manipulation of host selection processes, financial kick-back schemes involving the use of public funds in the development of major sports events-related infrastructure, conflicts of interest involving international sports organizations, reselling of event tickets by event organizers for personal gain and corruption linked to sponsorship opportunities and the acquisition of media rights for major sports events.

In order to prevent these violations, the Report provides the following recommendations:

1) To governments:

Identifying and mapping the roles and responsibilities of stakeholders in the delivery of sports infrastructure, including implementing agencies and construction suppliers, as well as architects or project managers and other actors involved;
Developing strategies aimed at centralising information pertaining to the development of sports-related infrastructure;
Conducting thorough needs assessments in the planning stages of hosting an major sports event, and ensuring that no external (or inappropriate internal) stakeholders influence the results;
Developing and implementing a code of conduct to guide the behaviour of the various stakeholders involved in the delivery of a major sports event etc.;

2) To sports organisations:

Regulating the use of commission-based payment systems involving stakeholders related to major sports events and ensuring that codes of conduct govern the conduct of delivery authority personnel and consultants involved in procuring goods and services from third-party suppliers;
Adopting and publishing a clear set of criteria that guides both bidding parties;
Publishing bid evaluations and making them easily accessible to all stakeholders, including the public;
Establishing ethics commissions that can conduct background checks on the various stakeholders involved in the major-sports-event selection process etc.