Competition manipulation in international sport federations’ regulations: a legal synopsis

Abstract

Manipulation of competitions has long plagued the sport industry, affecting almost every sport over time. While sharing certain common features, the regulatory provisions and procedural responses to this phenomenon by international federations (IFs), sports’ governing bodies, vary on many aspects, including the definition of the specific offence of “competition manipulation” itself, scope of application, especially in relationship to betting, categories of participants, mens rea elements such as recklessness and negligent behaviour, reporting obligations, aggravating and mitigating factors, and applicable sanctions across sports and within a sport/discipline. More nuanced items within internal disciplinary procedure also vary across federations, such as standard of proof and evidence. The purpose of this study is to offer a comparative synopsis of the regulations of 43 IFs governing Olympic and certain non-Olympic sports, to provide a critical overview of specific aspects of the above mentioned factors in the regulations and to identify areas of improvement for the future.

1 Introduction

1.1 Context and relevance of study

Manipulation of competitions has long plagued the sport industry, affecting almost every sport over time,¹ propelled in particular by certain factors such as volume of bets and quantum of money involved, inconspicuous nature of certain leagues or matches, advent of the internet, ineffective state and other legislation and, most recently, spurred on by pandemic-related economic effects.²

For manipulation offences in sport, primary action, whether or not in parallel with state authorities, is ordinarily initiated by the respective governing body in the sport (“sport justice”) against an actor engaging in such an offence.³ Initially, manipulation was an offence grouped with general corruption within codes of conduct or ethics, if at all—no consistent approach across federations was present. With the increase in prevalence and of its profile as a threat to integrity, as well as endeavours such as the IOC’s issued studies,⁴ and 2015 Olympic Movement Code on Prevention of the Manipulation of Competitions (“IOC 2016 Code”) serving as a model set of regulations compliant with leading international standards codified within the Council of Europe’s Macolin Convention,⁵ a number of international federations (“IF”s), adopted dedicated provisions or the IOC 2016 Code itself as a whole, such provisions continuing to apply to date.

Studying these IF’s regulations and trends across them thus assumes immense importance, in no small part as their frequent application in the first instance often results in severe consequences in long-term ineligibility for athletes, often final or not appealed from, as seen below. The specificity of drafting within provisions has important implications, including for certainty of defining an offence and its elements (for instance, including reporting obligations or negligent behaviour); types and consistency in awarding sanctions across sports and within a sport/discipline for the same offence; as well as for more nuanced items within procedure such as evidence, notoriously problematic due to the clandestine nature of acts and limited investigative ability of sporting bodies compared to state bodies. This in turn is regularly seen to have implications within adjudication on elements such as standard of proof applicable, also increasingly codified, and when the burden of proof might shift from one party to another.

1.2 Scope

This study is limited to a review of IF regulations, and specifically the definition of manipulation therein, of all IFs with disciplines currently within the Olympic or Paralympic Games (a sub-set of all the federations recognized by the International Olympic Committee (“IOC”)) as well as, for completeness and based on prevalence of relevant offences, a few additional bodies’ regulations, international and regional.⁶ Definitions of ancillary, but connected offences usually found defined together with the “core” offence of manipulation in applicable regulations, including (illegal) betting, (dealing in) insider information, (engaging in) corrupt conduct, failing to report and cooperate are briefly looked at, without particulars of specific regulations applicable and regulating betting or reporting regulations, where present, for example.

Cumulatively, 43 IFs (Olympic/Paralympic and Non-Olympic),⁷ 1 regional governing body’s regulations (Union of European Football Associations, “UEFA”) and certain other miscellaneous regulations such as the IOC 2016 Code and Tokyo 2020 Regulations are studied. All graphs include these 43 IFs studied. The study takes into account specific decisions issued by IF internal adjudicatory processes where relevant.

Each sport, IF, abbreviation for each IF, respective relevant applicable regulation (and provision therein, if needed), and its source are systematically listed in the Annex to this article. The study below looks at IF regulations as effective in December 2020.⁸

1.3 Analysis method

Each IF’s regulations (both specific to manipulation but also provisions from general procedure as would be applicable to manipulation offences) were assimilated and then comparatively analysed for elements within the definition (Part II below), parallel offences (Part III), sanctions (Part IV) and particulars of the specifically applicable dispute resolution processes (Part V). Statistical trends through noting common factors across these elements are represented as graphs to assess common features in how governing IFs regulations treat the same offences.

2 Definition of competition manipulation by International Sports Federations

2.1 Existence of specific regulations for the offence of manipulation

The vast majority of IFs studied have specific regulations on the manipulation of sports competitions even if, for some of them, these specific rules are limited to a few behaviours and provide that, for the rest, the IOC’s 2016 Code applies (Fig. 1). Federations that do not have specific dedicated regulations of their own generally refer to the IOC’s 2016 Code, by incorporation or through adoption of its provisions verbatim either in entirety or in part (ICF,⁹ FIG,¹⁰ IHF,¹¹ ISSF,¹² WCF,¹³ WBSC¹⁴ and WS¹⁵).

Fig. 1

IFs with/without specific rules against manipulation of competitions

Only four federations do not provide for any specific rules in terms of the manipulation of sports competitions (IBSF, FIL, WDSF and IFSC) – which does not mean they do not punish match fixing categorically. Of these, one (FIL¹⁶) nevertheless incorporates the IOC 2016 Code for limited purposes, another (IFSC¹⁷) makes a reference to the IOC 2016 Code on its website as part of consent terms for athlete participation, and a third one includes certain provisions in its code of ethics (WDSF¹⁸).

Most IF regulations defer to applicable rules at a “major event” (as defined),¹⁹ such as any edition of the Olympic or Paralympic Games or a specific sport’s world cup, for governance of offences occurring at that sport. For example, at the Tokyo 2020 summer Olympic and Paralympic Games of June 2021, the issued set of “ethics” incorporated in their entirety the IOC 2016 Code,²⁰ this code having been first applied at the games in Rio de Janeiro in 2016.²¹ Thus, a manipulation offence would be treated under definitions provided by the code, as well as procedure specified therein.

2.2 Sanctionable behaviour: the “manipulation”

At the outset, it is important to note that terms such as “manipulation”, “match fixing” and “competition fixing” are often used interchangeably at the international level both in legislation and academically,²² and this further differs at the national level.²³

Generally, it has been noted by several authors,²⁴ but also in jurisprudence at the federation level as well as the CAS level that many different behaviours might be brought under the term “manipulation”, both ratione materiae and personae,²⁵ including conduct which might not otherwise be illegal,²⁶ or simply raise presumption of commission of an offence.²⁷ Across IFs studied, the term “manipulation” is widely used alongside other offences, with two basic types of definitions of structures for the specific offence, whether or not termed “manipulation” can be observed, while some, and notably prominent, federations, maintain unique definitions.

The first broad type reflects wording in the IOC 2016 Code²⁸ and the Macolin Convention,²⁹ making an offence any act or omission involving (as well as complicity—aiding, abetting, encouraging, conspiring or attempting an act which could “culminate” in an offence) the alteration of the course or result of a sporting competition or a part thereof, to remove whole or part of its unpredictable nature, whether or not for or any benefit (as defined) to the actor, or to a third party, and whether or not done intentionally, negligently or fraudulently.³⁰ Factors not relevant to this determination are usually listed including participation/attendance in the same event, outcome of event, nature of such outcome, receipt of consideration, effect on an actor’s performance and violation of any technical rules.³¹

The second type of definition which many federations have typically exist within older policies encompassing all types of conduct or ethics within which manipulation can be brought, even if framed after 2016.³² Finally, there exist miscellaneous definitions, which are important to mention as they are notably present among IFs which see a large number of cases, such as FIFA³³ and ITF,³⁴ certain others which have high profile,³⁵ and new federations such as WDSF.³⁶ In case of the ITF’s Tennis Anti-Corruption Program, 2020 (“TACP, 2020”), the manipulation offences are laid down as instances of common occurrences within the sport of tennis based on how matches are often manipulated.³⁷

2.2.1 Active/passive

Regulations studied contain both active as well as passive manipulation of sports competitions. Moreover, 39 of the 43 federations include omission within punishable behaviour.³⁸ The IOC 2016 Code also has language that includes this which has then been adopted by IFs who have incorporated the code or adopted similar language.³⁹

In certain instances, common language is used across disciplinary offences or other violations to include within all of them the omission or passive contributions, bringing within its ambit aiding, abetting, other complicit, encouraging, inciting, inducing, assisting or concealing behaviour.⁴⁰

2.2.2 Intention/negligence

An intentional act is behaviour committed with conscience and will; conversely, negligent behaviour is committed without conscience and/or without will, while nevertheless remaining at fault through culpable improvidence that can be blamed on the perpetrator.⁴¹

If intention is provided for by all the IFs that have regulated the manipulation of competitions (the only unclear situation being the IFSC⁴²), only some of them also incriminate negligent behaviours, either explicitly or through other texts (such as a code of ethics, for example) extending the scope of application to negligence (Fig. 2).⁴³ Among the IFs that do not expressly provide for negligence, some nevertheless provide for the punishability of negligence when certain conditions are met, such as a serious damage to the reputation of the sport or the concerned federation (IBSF⁴⁴), or by stating, for instance, that “ignorance” or “having made a mistake” are not a defence.⁴⁵

Fig. 2

Subjective conditions in IF regulations

2.2.3 Result of competition/other parts of the event/course of the competition

Save for one IF (IFSC) where the applicable provisions are general ones not defining manipulation,⁴⁶ all applicable federation regulations contain language which covers offences related to manipulation which affect not only the final result of the event, competition or other activity participated in or bet on, but also the course or a component of such result of events, components of events or competitions, whether affected or not.⁴⁷

2.2.4 Financial/non-financial purpose and definition of “benefit”

The question arising here is whether the regulations aim to punish only those acts of manipulation that produce financial results or whether the punishability is extended to acts without immediate financial consequences. These include, for example, acts committed with the sole aim of obtaining a qualification or setting a record.⁴⁸Certain instruments, such as the Macolin Convention bring intangible benefits such as advancing in competition within “manipulation”.⁴⁹ Yet, there remains is varying opinion on criminalization of acts such as tactical losses.⁵⁰

The study of IF regulations shows that both financial and non-financial objectives are in IF regulations’ sights (usually present in the definition of “benefit”; Fig. 3). This aspect is usually a component of the definition of “benefit”. Many IFs, particularly those having incorporated the IOC 2016 Code,⁵¹ have definitions including the elements of (i) the direct or indirect (ii) receipt or provision of (iii) money or the equivalent.⁵² Even those IFs which do not adopt the IOC 2016 Code definition strictly might still use this same definition of benefit.⁵³

Fig. 3

Purpose of manipulation—financial and non-financial

IFs which structure their regulations more uniquely, including those whose regulations are prominently applied, may (or may not) have alternative ways to define and apply the term “benefit”. FIFA, for instance, does not include the element of “benefit” within its definition of manipulation at all,⁵⁴ while the ITF’s TACP, 2020 defines the more limited term “Consideration”,⁵⁵ and ICC uses “Reward”.⁵⁶

2.2.5 Participants, connected persons and beneficiaries (for own/for others)

Across the IFs, either the term “Participants”,⁵⁷ “Connected Persons”⁵⁸ or alternative terms⁵⁹ might be used for the purposes of limiting which persons (and sometimes bodies) might be brought under the scope of the respective regulation, or could commit an offence thereunder. Some use a combination thereof, where the definition of a “Participant” will include that of a “Connected Person”, but be a sub-set of “Persons” as defined, which in turn might be a sub-set then of a wider term encompassing additional persons who could commit manipulation (or other integrity offences).⁶⁰

The actors which might be brought under manipulation regulations or definitions vary across IFs; whether or not an exhaustive list of entities to who the regulations are applicable, and might extend from parties ranging from continental and member federations to individual athletes, judges/referees right up to anyone authorized to “co-operate, collaborate or participate” in a sport’s activities.⁶¹ Parties that aid, abet, encourage conspiring or contribute by their behaviour are also usually included within the scope of application.⁶² Finally, certain IFs have extended possibility to bring additional persons within the ambit of their provisions, such as the ICC’s Excluded Persons Policy, 2021.⁶³

Finally, ratione personae, through adjudicated IF decisions and on appeal, have been seen to include a range of actors as noted by authors before.⁶⁴ This could include both natural and legal persons, with clubs, often held strictly liable for acts of their personnel or representatives, as seen most recently in the case of Kenyan club Zoo FC⁶⁵ and confirmed in other cases by CAS awards on appeal.⁶⁶ This distinction/categorization is also used in certain regulations to vary which sanctions are awarded for the same offence.⁶⁷

These actors, i.e. those to be proceeded against committing prohibited acts, might, or might not be “beneficiaries” of such conduct. Thus, as regards the beneficiaries of the manipulation, the question arises as to whether the act is punishable only if it brings a benefit to the perpetrator (as defined) or if it is also punishable when it is committed for the benefit of a third party. Such distinction is either found in the within the definition of the term “manipulation” itself,⁶⁸ or through the language of the provision implicitly.⁶⁹

Here again, the intention of most IFs is clearly to target both situations in their regulations (Fig. 4).

Fig. 4

Beneficiaries of manipulations—self and/or others

Connected to the definition of a “Participant”, and relevant to where/the jurisdiction in which manipulation offences take place, is the definition of what type of situation such regulations come into play. Certain IFs bring all types of activities within their purview,⁷⁰ while others limit operations of manipulation specific regulations only to certain “Competitions”.⁷¹ Finally, as also mentioned above many IFs make deference to major event rules for manipulation offences there.⁷²

2.2.6 Relationship to, and definition of “betting”

It is observed that most IFs punish manipulation-related offences in both betting and non-betting sporting contexts (Fig. 5),⁷³ and usually, betting-related offences are independently defined within the same set of regulations,⁷⁴ with the act of betting itself being an independent defined term, whether termed “bets”, “betting”, “sports betting” or “wager”.⁷⁵ In only few instances, betting specific regulations are present without there being a corresponding wider provision to define or sanction all other forms of manipulation.⁷⁶

Fig. 5

Inclusion of sporting and/or betting events

2.3 Other offences related to the manipulation of a sport competition

Under the provisions of regulations applicable to manipulation offences, most federations also define connected, overlapping or other corruption-related offences or sanctionable behaviour. In some cases, it is an overarching previous provision found within applicable regulations such as a code of ethics, prior to a specific set of regulations on competition manipulation being issued. These provisions remain most relevant in situation where no independent manipulation provision is yet defined.⁷⁷ These could include behaviour under “bringing the sport into disrepute”, “serious misconduct”, and similarly worded behaviour.

Very notably, ITF, under the TACP and the ITF Constitution brings all connected conduct under a robust definition termed “Corruption Offences” which includes as well all the ancillary sanctionable conduct described below. Article D.1 of the TACP reads:

“Corruption Offences: …d. No Covered Person shall, directly or indirectly, contrive the outcome, or any other aspect, of any Event. e. No Covered Person shall, directly or indirectly, facilitate any Player to not use his or her best efforts in any Event. f. No Covered Person shall, directly or indirectly, receive any money, benefit or Consideration on the basis of not giving their best efforts in any Event and/or negatively influencing another Player’s best efforts in any Event. g. No Covered Person shall, directly or indirectly, offer or provide any money, benefit or Consideration to any other Covered Person with the intention of negatively influencing a Player’s best efforts in any Event. …”⁷⁸

Usually, the offences of betting on competitions defined to be of a specific interest to the subject of the regulation (see above), corruption or corrupt conduct through the acceptance of a defined set of “benefits” whether or not connected to manipulation, and (dealing in—including using, disclosing or receiving any benefit in connection with) insider information are separately defined, over and above the above described offence of competition manipulation. To note, is the distinction made between betting in general and the specification of only certain kinds of betting as prohibited.⁷⁹ Certain federations also bring under the same regulations the prohibition of receipt of gifts or benefits by officials, often above a certain value.⁸⁰ Finally, failure to report, disclose and cooperate with investigations are also independently defined as a related offence across many federation regulations.⁸¹

In some instances, the offence might be specific to the sport—a relevant recent example is WDSF, where the margin of subjectivity in awarding scores across disciplines is policed specifically to curb the ability for manipulation to occur, through a common applicable code of ethics, with an independent provision within the code prohibiting direct or indirect influence of the course or result of a competition as well.⁸² Another example of specific provisions is the prohibition from participation in events organized by betting operators by the ISU.⁸³

Finally, it is worth making note of the structure under UEFA’s regulations due to the sheer number of cases adjudicated under their rules as applicable to clubs.⁸⁴ Independent provisions remain present for other actors,⁸⁵ with connected liability for clubs.⁸⁶ Before 2007, manipulation was proceeded against under common disciplinary rules,⁸⁷ where a residuary provision captured all offences not specifically defined.⁸⁸ Determined to not see clubs involved in manipulation participating in the League without consequence,⁸⁹ since 2007, UEFA tied eligibility to prior involvement in fixing introducing a two-stage process: a primary administrative/eligibility measure, excluded a club for a single season of competitions;⁹⁰ and a secondary disciplinary/sanctionary measure, which has no maximum duration in sanction, the primary being awarded impact on the latter.⁹¹

3 Sanctions

3.1 IOC’s sanctioning guidelines

To achieve some degree of harmonization among the very disparate IF regulations, the IOC has published in 2018 Guidelines for Sports Organizations on the Sanctioning of Competition Manipulation (the “IOC Sanctioning Guidelines”).⁹² This document proposes a coordinated approach on key aspects, such as factors which influence sanctions for match fixing (aggravating and mitigating), and importantly, on the level of sanctions for four key offences: betting, manipulation of sport competitions and corrupt conduct, inside information and failure to report and/or to cooperate.

For example, for the “core” offence of manipulation of sport competitions and corrupt conduct,⁹³ the IOC Sanctioning Guidelines recommend a sanction of “approx. 4 years ban and fine” for the betting-related offence, and “approx. 2 years ban and fine” for the non-betting-related offence. Also, under the IOC Sanctioning Guidelines, recommended aggravating/ mitigating factors globally to consider are: (1) whether the Participant is betting on a competition she/he is participating in; (2) the number and size of the bets; and (3) addiction to betting or other specific personal circumstances.⁹⁴

Another offence considered in the IOC Sanctioning Guidelines is the failure to cooperate, which has two faces: (1) failure to report, meaning that the participant has failed to report, at the first available opportunity, full details of any approaches or invitations received by himself or by another participant to engage in conduct or incidents that could amount to match fixing (Article 2.5 of the IOC 2016 Code), and (2) failure to cooperate with authorities during the investigation, including obstructing such investigation (Article 2.6 of the IOC 2016 Code). For failure to report or to cooperate, the IOC generally recommends a sanction of “0–2 years ban and a fine”; however, for obstructing the investigation (including concealing, tampering with, or destroying any relevant documentation or other information), the recommended sanction is slightly more severe, i.e. “1-2 years ban and a fine”. Naturally, mitigating/aggravating factors may apply.

These recommendations have had an important impact on the sanctioning regime applied by Olympic and non-Olympic IFs, many of which have chosen to incorporate them in their own regulations on match fixing. This is explained in details hereinafter.

3.2 Types of sanctions in IF regulations

3.2.1 General sanctions

The sanctions provided for by the various regulations of the international federations are of several kinds. They range from warning (with or without a period of probation) to exclusion for life, including reprimand, disqualification, return of award, fine, suspension,⁹⁵ among others (Fig. 6). Most include provisional suspension pending investigation.⁹⁶ Sanctions could also be categorized or listed differently for when applied to a natural person or to a legal persons/entity.⁹⁷

Fig 6

Types of sanctions and measures

Fines are foreseen in almost all the IFs’ regulations to sanction competition manipulation. Sometimes its amount is fixed according to the advantage received by the offender,⁹⁸ sometimes it is limited by a maximum amount (which can vary according to whether it is imposed on a natural person or a legal entity⁹⁹ and/or according to the seriousness of the act committed¹⁰⁰) and sometimes it is unlimited/unspecified in amount.¹⁰¹ Furthermore, some regulations provide that it may be combined with other sanctions,¹⁰² or factors like financial hardships should be factored into the amount.¹⁰³

Under the terms ban, suspension or ineligibility, one means a ban on participating in the future sporting events or administrative functions, a future that may be very limited in time but also very distant, if not unlimited.¹⁰⁴ All the IFs know such suspensions that can range from temporary to perpetual, including suspensions whose duration is fixed or proportionate to the fault committed, sometimes limited in terms of both their minimum and maximum.¹⁰⁵ These suspensions can also be total (in the sense that they apply to any activity related to the sport supervised by the federation)¹⁰⁶ or partial (i.e. limited to certain activities supervised by the federation).¹⁰⁷

Annulment of the result, deductions of points, return of awards and/or expulsion from the current competition, bans from venues or removal from held positions/membership from a body are also widely known sanctions in the regulations of the federations.¹⁰⁸

In addition to this, some federations now award restitution, education and rehabilitation programmes, social work, reprimands (sometimes public ones), payment of procedural costs, compensation to victims, an administrative fine (independent of the fine imposed as a penalty), etc. The most “positive” measures envisaged (in the sense that they encourage the promotion of human beings rather than their stigmatization, elimination and punishment), i.e. rehabilitation programmes, education and social work, are provided for by the FINA,¹⁰⁹ FIFA,¹¹⁰ IBU,¹¹¹ WKF¹¹² and UEFA.¹¹³

It is important to note that the type of sanction present in regulations of IFs assumes significance as it is, in most cases, deemed final even if appealed from (usually to the CAS).¹¹⁴ It is not interfered with based on the rationale of IF having expertise in the field unless found to be grossly and evidently disproportionate or irrational,¹¹⁵ the CAS having upheld a majority of decisions appealed to it from the IF dispute resolution mechanisms, including life bans.¹¹⁶

3.2.2 Specific sanction of life bans

The question of life bans assumes importance given this finality in awarding such bans. Recent (2021) manipulation-related decisions at the IF level have mostly seen life bans or very long, career ending bans—this is at least the case across the most prominent sports/IF from a match-fixing perspective being FIFA,¹¹⁷ ITF (5 life bans in 2021)¹¹⁸ and the ICC.¹¹⁹ BWF, for example, has also awarded life bans (to a sponsor/brand representative and three athletes for coordinating and organizing the fixing) and lengthy bans (six to 12 years with fines to other involved athletes),¹²⁰ which are most certainly also career ending for an elite athlete, though similar bans for retired athletes, but who are likely to be involved in the sport as coaches, administrators in the future, could be argued to be insufficient as a deterrent. The most severe sanctions outside of sport (life terms, for example) are often awarded based on the gravity of a crime and only in the rarest of rare circumstances (or equivalent jurisdictional test)—thus the regularity of these in sport, if equivalent, may be debated, and has been applied with more nuance or limited to a range for other disciplinary offences, such as for doping, for example.¹²¹

Further, it is noted that, from a comparative perspective, life bans are similar to certain criminal or administrative sanctions, such as the interdiction to practice one’s profession or, to some extent, to lifetime detention. A lifetime ban in this context hence equals a type of “sporting death” of the respective person. However, unlike in most similar cases in criminal/administrative law, in sport there are no possibilities to periodically review the sentence with a view to reducing it and to reinserting the banned persons into their sport, nor is there a possibility to obtain grace, in exceptional circumstances. Mutatis mutandis, one may recall that, according to the jurisprudence of the European Court on Human Rights Article 3 (interdiction of torture and of inhuman or degrading treatment or punishment) of the European Convention of Human Rights must be interpreted as requiring reducibility of the sentence, in the sense of a review which allows domestic authorities to “consider whether any changes in the life prisoner are so significant, and such progress towards rehabilitation has been made in the course of the sentence, as to mean that continued detention can no longer be justified on legitimate penological grounds”.¹²² While potentially a stretch, this is relevant as further rights considerations are sought to be brought into IF regulations.¹²³ It is thus arguable that awarding a life ban (especially as a first punishment, in the absence of a gradual scale of sanction) without any concrete possibility to reduce it in the future, raises serious issues as to its proportionality and its compatibility with fundamental principles of law.

Additionally, the issuance of life bans with this regularity requires consideration at the purpose of sanction in these contexts—whether retributive, deterrence or rehabilitation. Having noted the option of rehabilitative sanctions such as social work and education as well that a choice is made to issue life bans indicates a retributive and deterrent approach, which might serve the purpose of keeping such elements out of sport for such time to make sport clean (for the society), but not for assisting the individual. In such cases, the purpose of disciplinary sanctions in sport, could be seen to be different from that in the context of criminal law in society, otherwise.

The question of purpose however, remains independent of the consideration of proportionality, also significant as federation decisions are often final (as noted above). This made determination of the quantum an important exercise. To this end, IF bodies may consider aggravating and mitigating factors, or other guidelines, as discussed below, if so codified. Such factors may also sometimes result in the CAS concluding differently.¹²⁴

3.3 Aggravating and mitigating factors

Aggravating and mitigating factors are usually listed in connection with sanctions, independent of factors listed as relevant (or “not relevant”) to establishing manipulation. Usually, these include age/youth/experience/inexperience, disciplinary record/prior violations, number of breaches, significance of benefit, potential to affect course/result, whether breach was part of a broader scheme, admission of violation/cooperation/assistance/remorse¹²⁵ (Fig. 7), and could also include, the nature of the breach(es), the degree of fault, the harm that the breach(es) has/have done to the sport, the need to deter future breaches, and other specific factors.¹²⁶ Certain guidelines on sanctioning require, for example, considerations of “level of responsibility or …equity”.¹²⁷ Certain federations provide for a strict tabulated range per sanctions based on how a specific manipulation offence is committed.¹²⁸

Fig. 7

Aggravating and mitigating factors in sanctioning

Such factors may be seen in the regulations themselves,¹²⁹ or even specifically applied in adjudication based on fact—the ICC’s ACU has taken into account cooperation, admission of breach, remorse, good prior record, lack of substantial damage to commercial value or public interest or matches and interestingly, the lack of effect on the outcome of the match concerned, in mitigating sentences.¹³⁰ Similarly, the CAS takes into account such factors should an IF decision be overturned.¹³¹

It is interesting to note that certain federations make a distinction in their applicable codes between sanctions awarded for the same offences depending on factors involved (independent of the definition of the crime) such as—“fraud” (intentional breach), “fault” (whether or not intentional), “involvement” (indirect) and “attempting” (result agnostic) in their sections addressing sanctions.¹³² Similar structure can also be observed in certain IF’s sentencing guidelines applicable to all disciplinary offences specific to certain forms of cheating found in a sport such as bridge.¹³³

It might be contested that the myriad factors that are present for consideration across federation guidelines result in a large amount of discretion with only vague guidance on how it is to be exercised. Comparing awards within, across sports and with other processes under law providing varied outcomes, compounds this further.¹³⁴ Finally, it may also be observed that factors specified are often repetitive, with certain factors (non-cooperation, for instance) being offences unto themselves.

4 Disciplinary procedure, dispute resolution rules and procedural issues

4.1 Existence of separate dispute resolution procedure

Another question is whether there are procedures specific to an IF and, more particularly, whether there is a procedure designed to deal with cases of sports competition manipulation separately. While federation-specific procedure exists in all IFs, only some of them have an independent procedure for match-fixing cases (Fig. 8). This even if some of them know certain specific details while mainly applying a common procedure to all sports offences.

Fig. 8

General federation disciplinary procedure and specific procedure where applied

4.2 Internal and external levels of regulation

Sanctions for competition manipulation may intervene at different levels. First, as noted above, disciplinary sanctions are applied by sports bodies, according to their internal (private) sanctions system (“sport justice”, the sanctions being based in contract¹³⁵). Second, sanctions, including criminal, may be applied by public authorities (“state justice”). Depending on the applicable national law, the latter may be of a civil, administrative/disciplinary or criminal nature.¹³⁶ These are considered complementary.¹³⁷ Because they are different in their nature, these sanctions may be applied simultaneously without violating the ne bis in idem principle.¹³⁸

Disciplinary sanctions issued in initial proceedings by federations internally (the process looked at later in this section) may be challenged in front of the sports bodies’ internal jurisdictional bodies and in arbitration proceedings. The jurisdictional bodies created by sport associations around the world pursue the same goal: to settle disputes, to mediate and to guarantee the correct interpretation of sporting rules and regulations.¹³⁹

At the international level, IF bodies that have issued numerous decisions on manipulation offences include FIFA’s Disciplinary Body and Appeals Body.¹⁴⁰ Similarly, UEFA’s Control, Ethics and Disciplinary Body, and Appeals Body have issued numerous decisions.¹⁴¹ Both of these sports bodies together contribute to more than 20 of around 30 to 40 cases on manipulation before the CAS (as had arisen as of the date of this study), with awards on UEFA club eligibility forming a further majority among those.¹⁴²

Outside of these, notable federations which regularly issue internal decisions include the ITF through the International Tennis Integrity Agency (“ITIA”) which administers the TACP, 2020. At the time of study,  the ITIA lists 23 instances of persons serving sanctions not amounting to life bans and 26 instances of persons serving life bans (one such decisions being for life bans for three persons).¹⁴³ Tennis governing bodies¹⁴⁴ overall had also had three cases appealed to the CAS where two life bans and one 5-year ineligibility awarded by tennis governing bodies were upheld.¹⁴⁵

Finally, but not in the least, the ICC has pronounced four decisions through its internal disputes mechanism already on corruption and fixing offences in 2021.¹⁴⁶ More recently, 2 cases have involved awarding 8 years of ineligibility each for conduct violating many provisions of the ICC Anti-Corruption Code, including dealing in insider information.¹⁴⁷ Certain ICC awards are also examples of awards that have been appealed to the CAS and issued alongside ongoing state proceedings, with parallel state proceedings, each factoring in the other.¹⁴⁸

Among the international arbitration tribunals, the CAS was the most solicited insofar as disciplinary match-fixing proceedings are concerned, being the forum to which most federations provide for appeals from their internal disciplinary proceedings.¹⁴⁹ As of the time of study, the cases dealt with by the CAS concerned five different sports.¹⁵⁰ The CAS awards may be ultimately challenged in front of the Swiss Federal Tribunal (“SFT”), on the limited grounds enumerated the applicable provisions of the Swiss Federal Statute of Private International Law.¹⁵¹ As of the time of study, the SFT had not adjudicated any case related to competition manipulation in appeal from a CAS award.

4.3 Applicable procedure within a federation

At the federation level, each international federation contains a distinct dispute resolution mechanism through which disciplinary matters are processed—i.e. a manipulation offence sought to be proceeded against by any of these federations in any discipline of any Olympic sport, has a defined channel under through which it can and will be addressed. Among these, some federations have procedures unique to manipulation offences,¹⁵² some have a combination of specific regulations and certain provisions applicable from common procedures or sanctions, or make specific exemptions. The rest have common processes for all disciplinary and/or other disputes within the federation¹⁵³. Across federations, these procedures are found in dedicated regulations addressing manipulation offences, where, for instance their [above described] definitions are located. If not, the other sources of applicable provisions are spread across (and more commonly prior to the IOC’s 2016 Code) the federation’s common code of ethics, or overarching statutes/constitution.

Certain bodies have more specific reporting, investigation, prosecution and adjudication rules which are applicable.¹⁵⁴ Procedural rights are laid down across most federation regulations and include the right to be informed, right to fair timely and impartial trial, right to a written defence and the right to be accompanied and/or represented. Most federation also provide which authority is to investigate and stages of progress from investigation to adjudication, for which burden and standard of proof is then described, as well as certain specific circumstances in which burden may shift.¹⁵⁵

The standard of proof may range from balance of probabilities to comfortable satisfaction (sometimes specifically stated as greater than a balance of probability but less than proof beyond reasonable doubt,¹⁵⁶ the same as seen at the CAS) with a prevalence of the latter. Certain rules specifically address the standard of admissibility of different types of evidence, sometimes with an illustrative list, as well as whether or not ordinary judicial rules on admissibility are applicable.

Keeping in line with this, certain IFs regulations, in line with certain CAS awards,¹⁵⁷ state categorically that applicable procedure is not intended to be subject to or limited by requirements and legal standards applicable to criminal proceedings or employment matters but was independent and autonomous.¹⁵⁸ Finally, limitation periods are also described ranging from as few as 3 years¹⁵⁹ to no statute of limitations on such offences,¹⁶⁰ with certain independent procedure for “smaller” offences.¹⁶¹

5 Conclusions

This research has allowed us to identify the following take-home points in IF regulations as they apply to competition manipulation.

First, quantitatively, it was found that, as of the time of study, the vast majority of the 43 studied IFs have adopted regulations on the manipulation of sports competitions, either by producing their own detailed regulations or by reference to the IOC’s 2016 Code.

Second, on the regulations’ substance, it was found that applicable provisions across the offences, as at the time of being studied, remain, in their majority, robust, relevant and updated. This may also be considered an indicator of the elaborate thought given to tackling this offence relative to others—heightened attention is seen in certain sports, such as tennis or cricket, a high profile, visible sports, with many cases and high susceptibility. Even so, within regulations, the existence, or lack thereof, of a specific set of regulations, or dispute resolution mechanism assumes relevance given, as noted otherwise in awards of the CAS, or decisions of other bodies such as FIFA’s DRC that evidence within manipulation is sought to be hidden, IF investigative powers are not the same as national authorities, the offence being considered serious and the objective of preserving integrity and competition very crucial.¹⁶²

The most important variations across sports concern basic definitions of the offence, and various elements thereof, as well as the quantum of sanctions (fines and importantly ineligibility and bans), which vary vastly. In this respect, it is important to note that the prevalence of life bans is significant, particularly in the context of proportionality (certain sports having a much smaller maximum ban), impact on athlete careers and the presence of alternative sanctions rooted in rehabilitation.

Yet, on a more general level, it was found that there exists disparity in detail or attention within IF regulations, which could indicate the relative significance associated by sport administration in addressing manipulation-related offences, compared to the treatment of other integrity-related offences, and in particular doping.¹⁶³ Prior opinions have called for re-prioritization of manipulation offences, which in recent times might have slipped in public conscience in the absence of “large-scale” scandals, or increased regulation.¹⁶⁴

Third, it was concluded that further consistency in procedural provisions across sports is desirable, aided by having uniform procedural standards applicable within a sport for various offences and across sports, given also, that sanctioning could work at various levels. This is also relevant in the light of increasing calls for protection of rights of parties and more specifically athletes, in internal IF adversarial processes.

Last, as a look to the near future, it is noted that newer threats within sports would need more regulatory attention—digital currency being one such example.¹⁶⁵ Alongside this, growth in certain sports post new challenges. There has been a noted increase in ongoing investigations and sanctions issued across eSport,¹⁶⁶ and corresponding efforts to combat manipulation therein,¹⁶⁷ for example. The eSports Integrity Coalition and International Esports Federation regulations are regularly applied but have limited applicability amidst complex ownership, affiliation and governance structures across publishers, national bodies and players, as well as the different context of manipulation (such as through edoping). This makes encapsulating potential actions in a conventional definition challenging in this context.

This research has been made possible due to the support of the Swiss National Science Foundation (SNSF-100011_192497).

Appendix: 43 Olympic and Non-Olympic International Federations Studied

Sr. no.	Sport and Federation Name		Applicable Regulations (as effective at the time of conclusion of the study in January 2021)
SUMMER OLYMPIC FEDERATIONS
1.	Boxing (amateur): International Boxing Association (“AIBA”)	AIBA	AIBA Code on Prevention of Manipulation of Competitions (2018) (https://d21c25674tgiqk.cloudfront.net/2018/07/AIBA-Code-on-the-Prevention-of-the-Manipulation-of-Competitions_Final.pdf) Article 8.3.1 of the AIBA Disciplinary Code (2013) (https://d21c25674tgiqk.cloudfront.net/2015/02/AIBA-Disciplinary-Code-Adopted-July-18-2013.pdf)
2.	Badminton: Badminton World Federation (“BWF”)	BWF	Section 2.4 of the BWF Statutes, i.e. the Code on Prevention of Manipulation of Competitions (2020 or “PMC”) (https://extranet.bwfbadminton.com/docs/document-system/81/1466/1468/2.4%20PMC.pdf; the BWF Statutes are available at https://corporate.bwfbadminton.com/statutes/#1513733305001-7485aaef-d176) The BWF’s PMC also refers to the BWF’s Judicial Procedures under Section 3.1 (https://extranet.bwfbadminton.com/docs/document-system/81/1466/1469/Section%203.1%20-%20Judicial%20Procedures%20-Effective%20date%2019%20July%202020.pdf) Chapter 2—Section 2.1 of the (Code of Ethics) also defines manipulation and is subject to general procedure under Section 3.2 of the BWF’s Statutes
3.	Equestrianism: Fédération Équestre Internationale (“FEI”)	FEI	Appendix G (FEI Code on Prevention of Manipulation of Competitions) to FEI General Regulations (2020) (https://inside.fei.org/sites/default/files/FEI%20General%20Regulations%20effective%201%20January%202020%20-%20Final%20Version%20for%20Website%20-%20Clean.pdf)
4.	Basketball: Fédération Internationale de Basketball Associations (“FIBA”)	FIBA	FIBA Internal Regulations—Book 1—General Provisions (of 2020—Chapter 5: Code of Conduct) contains provisions in connection with manipulation (https://www.fiba.basketball/internal-regulations/book1/general-provisions.pdf) However, in many places e.g. certain webpages (here, for example—http://playershub.fiba.com/en/integrity/fair-play-and-betting/how-can-i-protect-myself-illegal-betting-and-match-fixing) make mention of Annexure 4 to Book 1 (All FIBA regulations otherwise are available here—https://www.fiba.basketball/documents#tab=b1506ff3-8ed5-4367-9cae-dc3e448a922f)
5.	Fencing: Fédération Internationale d'Escrime (“FIE”)	FIE	Appendix 1 to Chapter 12 (p. 51—Appendix 1) to the FIE Ethical Code: Betting and Anti-Corruption Rules of FIE Statutes (2015) and Chapter 7 (p. 33) being the Disciplinary Code of the FIE (https://static.fie.org/uploads/9/48811-FIE%20Statutes%20ang.pdf)
6.	Football: Fédération Internationale de Football Associations (“FIFA”)	FIFA	FIFA’s Code of Ethics (2020) (https://resources.fifa.com/image/upload/fifa-code-of-ethics-2020.pdf?cloudid=upxpc0qzxqdgipiiejuj) FIFA’s Disciplinary Code (2019, referred to for sanctioning purposes Article 6.1 of the Code of Ethics, reference possible to be made under Article 52.1.d of the Disciplinary Code) (https://resources.fifa.com/image/upload/fifa-disciplinary-code-2019.pdf?cloudid=twc8yxh6fn0kjkgxhe9e)
7.	Gymnastics: Fédération Internationale de Gymnastique (“FIG”)	FIG	Incorporation of the IOC 2016 Code under Part 2: Article 1. c) of the FIG Code of Conduct and Article 1.c) of the FIG Code of Ethics (for Athletes, Judges and Officials, both of 2019) (https://www.gymnastics.sport/publicdir/rules/files/en_Code%20of%20Conduct%202019.pdf and https://www.gymnastics.sport/publicdir/rules/files/en_Code%20of%20Ethics%202019.pdf) Further mention of IOC 2016 Code in “Objectives” in Article 2.1 of the FIG Statutes (2019) (https://www.gymnastics.sport/publicdir/rules/files/en_Statutes%202019.pdf) Article 5 of the Code of Ethics, Infringement of this code attracts enforcement by the Disciplinary Authority under the FIG Code of Discipline (2019) (https://www.gymnastics.sport/publicdir/rules/files/en_Code%20of%20Discipline%202019.pdf)
8.	Field Hockey: Fédération Internationale de Hockey (“FIH”)	FIH	FIH Integrity Code (“Code”, 2018 of which Article 9 of the Code is title “Anti-Corruption Rules”) (http://www.fih.ch/media/12943893/2018-01-15-final-approved-fih-integrity-code.pdf, which superseded (see para. 1.4 on p. 1) prior specific Anti-Corruption Regulations (2017) and Article 2 of the FIH Code of Conduct Offences, in FIH Code of Conduct, 2016) Specific procedural details are present in the FIH Dispute Resolution Regulations (http://www.fih.ch/media/8997824/fih-dispute-resolution-regulations.pdf)
9.	Aquatics: Fédération internationale de natation (“FINA”)	FINA	FINA Rules on the Prevention of the Manipulation of Competitions (2016) (https://www.fina.org/sites/default/files/fina_rules_on_the_prevention_of_the_manipulation_of_competitions_final_30.01.2016.pdf) This is the “Implementing Provision of Article V.C.4 of the FINA Code of Ethics” (as last amended in 2015) (http://fina.org/sites/default/files/fina_codeofethics.pdf) Sanctions under C 24.8 and 24.9 of the FINA Constitution (referred to also as “FINA Rules” across some FINA documents) (https://www.fina.org/sites/default/files/_fina_constitution_19.07.2019_-_approved_by_fina_general_congress.pdf)
10.	Rowing: Fédération Internationale des Sociétés d'Aviron (“FISA”)	FISA	Regulation 6 on Anti-Corruption and Betting in the WR Regulations Handbook (2016) (https://integrity.worldrugby.org/resources/World_Rugby_Reg_6_EN.pdf; Reg. 6.1.3 states they “reflect” the IOC Code) General procedures in Regulation 18 Appendix 1 apply to any matters under Regulation 6 (https://www.world.rugby/handbook/regulations/reg-18/appendix-1)
11.	Volleyball and Beach Volleyball: Fédération Internationale de Volleyball (“FIVB”)	FIVB	The FIVB Disciplinary Regulations with Annexure A on the Prevention of Manipulations of Competitions (2020) and the FIVB Code of Ethics (2020; both available for download here—https://www.fivb.com/en/thefivb/legal)
12.	Athletics: World Athletics (until June 2019, International Amateur Athletics Federation, “IAAF”)	IAAF	IAAF Manipulation of Sport Competition Rules (“IAAF Rules”, version of 2019) (https://www.worldathletics.org/download/download?filename=88be8791-c819-4acc-826f-e37d90ada3da.pdf&urlslug=D4.2%20-%20Manipulation%20of%20Sports%20Competitions%20Rules) Rule 11 of the IAAF Rules also refers to the Reporting, Investigation and Prosecution Rules—Non-Doping (“Prosecution Rules”, version of 2019—https://www.athleticsintegrity.org/downloads/pdfs/know-the-rules/en/IAAF-AIU-Reporting-Investigation-and-Prosecution-Rules-1Jan2019-Final-18.12.2018.pdf) and to the Disciplinary Tribunal Rules (2019—https://www.athleticsintegrity.org/downloads/pdfs/know-the-rules/en/IAAF-DisciplinaryTribunalRules-1Jan2019-Final-18.12.2018.pdf)
13.	Canoeing: International Canoe Federation (“ICF”)	ICF	Incorporation of the IOC’s 2015 Code under Bylaw 4 under Bylaws to Article 2 of ICF Statutes (2019) (https://www.canoeicf.com/sites/default/files/icf_statutes_2019.pdf) ICF Statutes’ Disciplinary Measures (Article 42) and Disciplinary Processes (Article 43) are provided in Chapter IV of the Statutes (pp. 40 and 42, respectively)
14.	Climbing: International Federation of Sport Climbing (“IFSC”)	IFSC	Objectives under Article 5 bis of the IFSC Statutes (2019) include fighting manipulation and irregular and illegal betting and gambling and Bylaw to Article 10 defined (p. 16 of the IFSC Statutes defines violation of illegal and irregular betting but not manipulation) (https://cdn.ifsc-climbing.org/images/About/2020_IFSC_Statute_Approved.pdf) Certain procedure specified in the IFSC Disciplinary and Appeals Rules (“DAR”, 2007, updated 2019) (https://cdn.ifsc-climbing.org/images/ifsc/Footer/Commissions/Disciplinary_AppealsRules2019.pdf) IFSC website provides for athletes to sign an undertaking adhering to the IOC 2016 Code (“Please note that starting in 2017, the Athletes License form includes specific reference to the Olympic Movement Code on the Prevention of the Manipulation of Competition which all athletes are required to read and sign”.) (https://www.ifsc-climbing.org/index.php/2-uncategorised/49-athletes)
15.	Golf: International Golf Federation (“IGF”)	IGF	IGF Betting and Anti-Corruption Policy (2016) (http://www.igfgolf.org/wp-content/uploads/2017/01/IGF-Betting-and-Anti-corruption101116.pdf)
16.	Handball: International Handball Federation (“IHF”)	IHF	Incorporation of the IOC 2016 Code under Articles 4 and 5 of the IHF Ethics Code (2016, p. 8) (https://www.ihf.info/sites/default/files/2019-06/0_0_Ethics%20Code_GB.pdf—Annexed as an Appendix, p. 14 of the pdf) Article 11, Enforcement is in accordance with IHF Statutes (2018) (https://archive.ihf.info/files/Uploads/NewsAttachments/0_01%20-%20Statutes_GB.pdf) Article 1 of the IHF Regulations Concerning Penalties and Fines (2017) states that its provisions are specifically applicable to “corruption” and “betting” offences (https://www.ihf.info/sites/default/files/2019-05/0_XIX%20Regulations%20Concerning%20Penalties%20and%20Fines_GB.pdf) Article 3 of the Ethics Code otherwise specifically states that “In the event of any inconsistency between the Code and any other IHF Regulations except for the IHF Statutes, the relevant provisions of the Code shall prevail”.
17.	Judo: International Judo Federation (“IJF”)	IJF	Article 1.2.2 (Match-fixing and Competition Manipulation) and Annexure F (Disciplinary Code, p. 153) of IJF’s Sport and Organization Rules (“SOR”, 2019) (https://78884ca60822a34fb0e6-082b8fd5551e97bc65e327988b444396.ssl.cf3.rackcdn.com/up/2019/10/IJF_Sport_and_Organisation_Rul-1570787163.pdf) Another reference to corruption is made in the Code of Ethics (2019, p. 153 of the same SOR document
18.	Surfing: International Surfing Association (“ISA”)	ISA	ISA’s Code on the Prevention of Manipulation of Competitions is located under Section 3 (Contest Rules and Procedures Part A, subpart v—General) of Chapter 2 (ISA Event Administration), under the larger ISA Rulebook (2019) (https://www.isasurf.org/wp-content/uploads/downloads/2019/06/ISA-Rulebook_-13-June-2019.pdf) Section 3.A.v (see above), refers to a specific hyperlinked code (2019) (http://www.isasurf.org/wp-content/uploads/downloads/2019/06/ISA-Rules_Prevention-of-the-Manipulation-of-Competitions.pdf)
19.	Sailing: World Sailing (until December 2015, International Sailing Federation; “ISAF”)	ISAF	Appendix 5 (Regulation 37)—Betting and Anti-Corruption Code of the (World Sailing Regulations, “Regulations”, 2020) and Appendix 6 (Regulation 25)—Disciplinary Appeals and Review Code (of the Regulations (combined document available here—https://www.sailing.org/tools/documents/2020RegulationsClean-[26381].pdf) Other sanctions from the WS Code of Ethics (2019) might also be imposed (https://www.sailing.org/tools/documents/2019CodeofEthicsPostMidYear-[25097].pdf)
20.	Shooting: International Shooting Sport Federation (“ISSF”)	ISSF	ISSF Code of Ethics (“Code”, Article 3.12.3.5, Annex CE) of the ISSF General Regulations (2020), governs manipulation, the preamble stating that “ISSF with these regulations also implements the new IOC Olympic Movement Code on the Prevention of the Manipulation of Competitions. The Definitions used in version 2016 of such IOC Code also apply to the following rules” (https://www.issf-sports.org/getfile.aspx?mod=docf&pane=1&inst=465&file=ISSF%20Code%20of%20Ethics.pdf)
21.	Tennis: International Tennis Federation (“ITF”)	ITF	Tennis Anti-Corruption Program (2020) and Rule 43 of the ITF Constitution 2020 which mandates compliance with the IOC 2016 Code (https://www.itftennis.com/media/2703/2020-tennis-anti-corruption-program-english.pdf and www.teniisintegrityunit.com; https://www.itftennis.com/media/2431/the-constitution-of-the-itf-2020-english.pdf, respectively)
22.	Table Tennis: International Table Tennis Federation (“ITTF”)	ITTF	Code on the Prevention of Manipulation of Competitions in the Code of Ethics (“Code”, in Chapter 6) of the ITTF Handbook (2020) (https://www.ittf.com/wp-content/uploads/2020/04/2020ITTFHandbook_v1.pdf)
23.	Triathlon: International Triathlon Union (“ITU”)	ITU	ITU Rules on the Prevention of Manipulation of Competitions (“Rules”, 2016) incorporate by reference the IOC 2016 Code and make mention of the Rules and IOC 2016 Code being in compliance with the Macolin Convention under Rule 1.3. (https://www.triathlon.org/uploads/docs/ituafl_rules-preventing-manipulation.pdf) ITU Disciplinary Rules (2016) under Article 13 contain details on matters such as admissibility of evidence (https://www.triathlon.org/uploads/docs/ITU_Disciplinary_Procedures_Rules_20160708.pdf)
24.	Weightlifting: International Weightlifting Federation (“IWF”)	IWF	IWF Guidelines: Competition Fixing (2015) (https://www.iwf.net/wp-content/uploads/downloads/2015/11/IWF-Guidelines_Competition-Fixing.pdf) Certain sanctions possible to apply under IWF’s Constitution and By-Laws (2017, p. 21) (https://www.iwf.net/wp-content/uploads/downloads/2017/04/IWF_ConstitutionBy-Laws__2017_pdf)
25.	Cycling: Union Cycliste Internationale (“UCI”)	UCI	Article 8.1 (Manipulation of Cycling Events) and corresponding Appendix 2 to Code of Ethics (https://www.uci.org/docs/default-source/rules-and-regulations/uci-code-of-ethics.pdf) governs manipulation (except betting) Article 1.1.088 of the UCI Cycling Regulations which defines betting (version 2020, p. 23) (https://www.uci.org/docs/default-source/rules-and-regulations/part-i-general-organisation/1-gen-20200612-e.pdf)
26.	Modern Pentathlon: Union Internationale de Pentathlon Moderne (“UIPM”)	UIPM	Betting and Anti-Corruption Rules (2018, being Part V of the UIPM Constitutional Book) (https://www.uipmworld.org/sites/default/files/betting_and_anti_corruption_rules_uipm_2018.pdf) UIPM Code of Ethics (2018) lays down procedural guidelines, including “Procedural Rules” (Annex 1 to the Code of Ethics) (https://www.uipmworld.org/sites/default/files/code_of_ethics_uipm_2018.pdf)
27.	Wrestling: United World Wrestling (“UWW”)	UWW	Incorporation of IOC 2016 Code under Article 1 in the Code of Ethics (2018, p. 10) (https://unitedworldwrestling.org/sites/default/files/2018-12/8_code_of_ethics_eng.pdf) Additional reporting guidelines (not obligatory) under “Reporting acts against the integrity of the Sport” (https://unitedworldwrestling.org/sites/default/files/2020-01/3.5_policy_reporting_acts_vs_integrity.pdf) Procedure under Disciplinary Code and Dispute Resolution Regulations (effective 2018) (https://unitedworldwrestling.org/sites/default/files/2019-09/disciplinary_proced_dispute_resolution_regulations_june2019_final_eng.pdf)
28.	Archery: World Archery (“WA”)	WA	Appendix 9 to Book 1 of the Constitution and Procedures (Betting and Anti-Corruption) (version of October 2020) (p. 43—https://rulebook.worldarchery.org/PDF/Official/2020-10-01/EN-Book1.pdf)
29.	Baseball and Softball: World Baseball and Softball Confederation (“WBSC”)	WBSC	Application/adoption of the IOC 2016 Code through Article 5.2 of the WBSC Code of Ethics (“Code”, 2017) Specifically, within the Code, it is stated that the By-laws regarding Sports Betting (2017) must be applied for manipulation (presumably in addition to the Code). These regulations are worded identically to the IOC 2016 Code, with additional obligations in connection with illegal betting (and gambling—see Chapter II). Disciplinary Procedure is under Chapter III of the Code. All these provisions echo the IOC 2016 Code Presumably, the Disciplinary Regulations (2017) would also apply in addition, for procedure and sanctions. Certain sanctions also in Code. (https://www.wbsc.org/organisation/statutes)
30.	Dance Sport (Breaking): World Dance Sport Federation (“WDSF”)	WDSF	WDSF Code of Ethics (https://www.worlddancesport.org/Rule/Athlete/Code_of_Ethics#:~:text=The%20values%20and%20principles%20written,in%20particular%20its%20fundamental%20principles) Disciplinary processes under WDSF Disciplinary Council Code (https://www.worlddancesport.org/Rule/WDSF/Regulations/WDSF_Disciplinary_Council_Code) Further judicial procedure under the WDSF Internal Dispute Resolution Code (https://www.worlddancesport.org/rule/all)
31.	Karate: World Karate Federation (“WKF”)	WK	WKF Code on the Prevention of Manipulation of Competitions (2016) (https://www.wkf.net/pdf/manipulation-of-competitions-pdf-en-236.pdf) Procedural provisions present in the WKF Disciplinary and Ethics Code (Article 3.1.3 and 3.6) (https://www.wkf.net/pdf/wkf-disciplinary-and-ethics-code_15march2016-pdf-eng.pdf)
32.	Rugby Union: World Rugby (“WR”)	WR	Appendix 8—Bylaws to Article 59—FISA Code of Ethics (“Code”, p. 143) and Appendix 9—Bylaws to Article 60—Manipulation of Competition and Betting (“Manipulation Bylaws” p. 149) both in Part V—Integrity of the Sport (p. 34) and Part VI—Judicial Provisions (p. 35; all within the FISA Rule Book, of 2017) (http://www.worldrowing.com/mm//Document/General/General/13/58/39/FISArulebookEN2019web_Neutral.pdf) govern manipulation.)
33.	Taekwondo: World Taekwondo (“WT”)	WT	WT’s Bylaws on Betting and Anti-Corruption (2012, “Bylaws”) (http://www.worldtaekwondo.org/viewer_pdf/external/pdfjs-2.1.266-dist/web/viewer.html?file=http://www.worldtaekwondo.org/wp-content/uploads/2016/10/WTF-Bylaws-on-Betting-and-Anti-Corruption.pdf)
34.	Skateboarding: World Skate (“WS”)	WS	WS Code of Conduct and Code of Ethics (2019—p. 9, Section I, subsection 6.A.4 and 6.A.7 (making reference to application of IOC 2016 Code) and p. 17, Section II, subsection 2.C—definitions) Certain procedure (prosecution and investigation) is contained in the WS Bylaws under para. 8, Section C.6 (2019) (http://www.worldskate.org/about/documents/category/304-world-skate-charters.html)
WINTER OLYMPIC FEDERATIONS
1.	Luge: Fédération Internationale de Luge de Course (“FIL”)	FIL	Part II (Specification of the Guidelines for Action), and Article 2 of the FIL Ethics Code (2019); as well, the FIL website generally (https://www.fil-luge.org/cdn/uploads/fil-ethik-code-englisch.pdf) and on the FIL website in general (https://www.fil-luge.org/en/anti-doping-fairplay/prevention-of-competition-manipulation; see also and on the FIL website in general (https://www.fil-luge.org/en/anti-doping-fairplay/prevention-of-competition-manipulation) Procedure and sanctions are present FIL Statutes (2019) and the Law and Procedure Regulations specifically commencing on p. 15 (https://www.fil-luge.org/cdn/uploads/statuten-2019-komplett-english-inkl-aenderungen.pdf)
2.	Skiing and Snowboarding: Fédération Internationale de Ski (“FIS”)	FIS	FIS Rules on the Prevention of Manipulation of Competitions (2016) (https://assets.fis-ski.com/image/upload/v1536910200/fis-prod/assets/FIS_Rules_on_the_Prevention_of_the_Manipulation_of_Competitions.pdf)
3.	Bobsleigh and skeleton: International Bobsleigh and Skeleton Federation (“IBSF”)	IBSF	General provisions present in the Code of Ethics (effective September 2011, not strictly related to manipulation) (https://www.ibsf.org/images/documents/downloads/code_of_ethics_E_120712_IBSF.pdf) Code of Conduct to be signed by athletes (2018 version) before obtaining IBSF license contains provisions in connection with manipulation (https://www.ibsf.org/images/documents/downloads/Codes_of_Conduct/20180725_CoC_athletes_2018.pdf) Certain provisions under Statutes of the IBSF (2019) also allude to manipulation and adoption of the IOC 2016 Code (Article 3.15) (https://www.ibsf.org/images/documents/downloads/IBSF_Statutes_am-congress2019.pdf)
4.	Biathlon: International Biathlon Union (“IBU”)	IBU	Chapter C (Prevention of Manipulations of Competitions) of IBU Integrity Code (“Code”—of 2019, which is part of IBU’s constitution, applicable to all cases where violations happen after the “Effective Date” as defined 19 October 2019); this document replaced a number of previous documents (Code of Ethics, anti-doping rules etc.) (https://res.cloudinary.com/deltatre-spa-ibu/image/upload/tziqluncgelica29obn7.pdf)
5.	Ice hockey: International Ice Hockey Federation (“IIHF”)	IIHF	IIHF Code of Conduct (“Code”, 2021) (https://blob.iihf.com/iihf-media/iihfmvc/media/downloads/regulations/2021/2021-iihf-code-of-conduct.pdf) See also ancillary provisions which pre-date the above Code such as Bylaw 24.1 on Manipulation of Competitions in the IIHF Statutes and Bylaws, requiring compliance with the Code of Conduct provisions on manipulations 2018–2022 and 2021–2024 (https://blob.iihf.com/iihf-media/iihfmvc/media/downloads/statutes/2021-2024-statutes-and-bylaws-(effective-september-2021).pdf)
6.	Ice skating: International Skating Union (“ISU”)	ISU	Articles 7, 8, 11, 12, 13, 16 and 17 of the ISU Code of Ethics (“Code”, 2018) (https://www.isu.org/inside-isu/isu-communications/communications-archives/19025-isu-communication-2215/file) Disciplinary Procedure and Sanctions are provided under the ISU Constitution and General Regulations (2018, referenced in Article 16 of the Code) (https://www.isu.org/inside-isu/rules-regulations/isu-statutes-constitution-regulations-technical/17913-constitution-general-regulations-2018/file)
7.	Curling: World Curling Federation (“WCF”)	WCF	Adoption of IOC 2016 Code by incorporation through Adoption Resolution (https://s3.eu-west-1.amazonaws.com/media.worldcurling.org/media.worldcurling.org/wcf_worldcurling/2019/08/05125448/Olympic_Movement_Code_on_the_Manipulation_of_Competitions_approved_at_2017_AGA.pdf) See also reference in Article 8 of the Code of Ethics (2016) (https://s3.eu-west-1.amazonaws.com/media.worldcurling.org/media.worldcurling.org/wcf_worldcurling/2019/08/05124858/Code_of_Ethics.pdf) Procedural provisions under Disciplinary Sanctions/Escalation/Appeals Policy (2017) (https://s3.eu-west-1.amazonaws.com/media.worldcurling.org/media.worldcurling.org/wcf_worldcurling/2019/08/05125501/Disciplinary_Sanctions_Escalation_Appeal_Policy_Sept_2017.pdf; this is to be read with other policies such as an independent available Escalation Policy (2016)—https://s3.eu-west-1.amazonaws.com/media.worldcurling.org/media.worldcurling.org/wcf_worldcurling/2019/08/05125204/Escalation_Appeals_Policy.pdf)
NON-OLYMPIC FEDERATIONS
1.	Cricket: International Cricket Council (“ICC”)	ICC	ICC’s Anti-Corruption Code for Participants (2018, amended 2021) and Minimum Standards for Players and Match-Officials’ Areas at International Matches (https://resources.pulse.icc-cricket.com/ICC/document/2021/01/06/a40dd941-47d0-4dec-8798-6e2885ad0fcd/ICC-Anti-Corruption-Code-amended-with-effect-from-1-Jan-2021-Board-approved-Nov-2020-.pdf; and https://icc-static-files.s3.amazonaws.com/ICC/document/2018/12/16/f3b76dad-9668-4a64-aeb8-0e8684d8e28b/-FV-Effective-from-1-December-2018-PMOA-Minimum-Standards-CEC-approved-.pdf)
2.	Bridge: World Bridge (“WB”)	WB	Article 4 of the WB Code of Ethics (2016) incorporates the IOC 2016 Code (http://www.worldbridge.org/wp-content/uploads/2016/12/WBFCodeofEthics.pdf) Sanctions under Disciplinary Code (2016) and specific Sentencing Guidelines making it contingent on nature of offence. (http://www.worldbridge.org/wp-content/uploads/2020/06/WBFDisciplinaryCode.pdf; and http://www.worldbridge.org/wp-content/uploads/2016/11/WBFSentencingGuidelines.pdf) Anti-betting Regulation (2011) defines betting differently (http://www.worldbridge.org/wp-content/uploads/2016/11/WBFAntiBettingRegulations-1.pdf)
MISCELLANEOUS
1.	Football (Europe): Union of European Football Associations (“UEFA”)	UEFA	Administrative (Eligibility Related): Article 4.02 of the UEFA Champions League and Article 4.03 of the UEFA Europa League Regulations (Champions League (football)—https://documents.uefa.com/r/Regulations-of-the-UEFA-Champions-League-2020/21-Online; the sport of futsal has independent regulations and Europa League—https://documents.uefa.com/r/Regulations-of-the-UEFA-Europa-League-2020/21-Online) Disciplinary Regulations (Sanctions Related): Article 12 of UEFA Disciplinary Regulations (Edition of 2020) (https://documents.uefa.com/v/u/ZNsWJsRSmOuSS2Ql_y8~qQ)