## I. INTRODUCTION Corruption in sports presents a substantial challenge worldwide, undermining public trust, fair competition, and the integrity of athletic institutions. Russia has developed a comprehensive legal and institutional framework to prevent and combat corruption in the sports sector. This article provides an overview of the Russian experience in this area, highlighting legal definitions, compliance obligations for sports organisations, prosecutorial oversight practices, and the enforcement of sanctions. The analysis is structured around four key pillars of anti-corruption policy: compliance, inspection, enforcement, and legal review. ## II. LEGAL FRAMEWORK According to Russian legislation[^1], corruption is defined as the abuse of power, bribery, commercial bribery, or other illegal use of one's official position contrary to the lawful interests of society and the State to obtain benefits such as money, valuables, other property, or property-related services for oneself or others. It also includes the unlawful provision of such benefits by other individuals or on behalf of a legal entity. Countering corruption[^2] includes 3 elements: a) Preventing corruption by identifying and eliminating its causes, b) Identifying, preventing, suppressing, exposing, and investigating corruption offences, c) Minimizing or eliminating the consequences of corruption offences. Based on Russian anti-corruption legislation, several key areas for countering corruption in sports can be identified: - Implementing compliance measures by sports organisations, - Conducting inspections of sports organisations and government bodies by prosecutors, - Detecting, suppressing, and investigating corruption offences and holding guilty parties accountable, - Conducting anti-corruption evaluation of legal acts. Let us examine each of the aforementioned key areas. ## III. COMPLIANCE MEASURES IN SPORTS ORGANISATIONS According to Article 13.3 of the Federal Law "On Combating Corruption", organisations must develop and implement measures to prevent corruption. These measures may include: - Designating officials responsible for preventing corruption, - Cooperating with law enforcement agencies, - Developing and implementing standards and procedures for organizational integrity, - Adopting a code of ethics and official conduct for staff, - Preventing and resolving conflicts of interest, - Preventing the preparation of informal accounting records and the use of forged documents. This requirement applies to all organisations, regardless of ownership or sector, including sports organisations. It should be noted that, unlike in Russia, anti-corruption compliance is not mandatory for all organisations in many other countries and is generally required only for state-owned enterprises, transnational corporations, or large companies[^3]. The list of measures provided by law is neither mandatory nor exhaustive and can be supplemented with additional measures aimed at preventing corruption offences, or otherwise modified in accordance with the specific nature of an organisation's activities, including its own assessment of corruption risks. Thus, while Russian legislation establishes an imperative requirement for all organisations to develop and implement anti-corruption measures, it simultaneously grants them the discretion to independently determine the necessary scope and content of such measures. In light of such regulatory provisions, the development of an effective system of anti-corruption measures by corporate executives places particular importance on the availability of relevant methodological guidance and the practical experience in applying Article 13.3 of the Federal Law on Combating Corruption by other organisations — including that reflected in judicial decisions and prosecutorial oversight practice. The Ministry of Labour and Social Protection of the Russian Federation has published guidelines on preventing and combating corruption, which are available on its official website. It is recommended that every organisation, including sports organisations, develop its own anti-corruption policy and ensure that it is known to all employees. Examples of general obligations for employees include: - Refraining from engaging in corruption offences, - Reporting any instances of being solicited to commit corruption to a superior or designated official, - Reporting known cases of corruption involving other employees or third parties, - Disclosing potential conflicts of interest. Organisations are also encouraged to develop a code of ethics, conflict of interest policies, and rules regarding business gifts. Regular corruption risk assessments with external auditors are advisable, as well as implementing a due diligence policy for new business partners, including anti-corruption clauses in contracts and organizing anti-corruption trainings and individual counseling of employees[^4]. In addition to the Federal Law "On Combating Corruption", Russia has specific regulations to prevent corruption in sports. According to the Federal Law "On Physical Education and Sport in the Russian Federation", one of the main principles is the prohibition of unlawful influence on the results of official sports competitions. Such unlawful influence includes bribing athletes, judges, coaches, or team managers, as well as receiving money or other benefits in exchange for manipulating competition results. To prevent such influence, competition organizers must include a ban on gambling and betting in their competition regulations[^5]. This Federal Law outlines the responsibilities of government authorities, sports federations, and competition organizers in preventing and combating unlawful influence on sports results. All-Russian sports federations, regional and local sports federations, and professional sports leagues are obliged to: 1) Ensure that athletes, sports judges, coaches, team managers, and other participants suspected or charged with corruption crimes do not participate in official sports events until a court verdict is reached or the criminal proceedings are terminated, 2) Impose sanctions within their jurisdiction after a guilty verdict is issued. These sanctions may include disqualification of athletes and penalties against the sports organisations they are affiliated with, especially in cases of illegal influence on the outcomes of official sports competitions, 3) Enforce penalties within their competence against athletes, sports judges, coaches, team managers, sports agents, and other participants for violating the prohibition on participating in gambling, betting, or sweepstakes. ## IV. PROSECUTORIAL OVERSIGHT AND INSPECTIONS Organisations' compliance with anti-corruption measures is subject to prosecutor inspections. These inspections may be initiated by appeals, legal cases, or information obtained through media monitoring and cooperation with civil society. The goal of these inspections is to help organisations establish effective anti-corruption policies. By addressing gaps in corruption prevention tools, prosecutors aim to improve the effectiveness of both the inspected organisations and others in the industry, ultimately promoting fair competition and increasing investment attractiveness. Violations identified during inspections must be addressed immediately, and the results reported to the prosecutor within one month. Failure to comply may result in administrative penalties and legal action. Example: An inspection conducted by the prosecutor's office revealed several violations within an organisation responsible for constructing football stadiums across the country. The company failed to fully comply with anti-corruption legislation. Employees submitted incomplete and inaccurate financial disclosures regarding their income, expenses, and assets. Additionally, no measures were taken to prevent conflicts of interest, particularly regarding the allocation of bonuses. The organisation's internal policy allowed management to assess employee performance and award bonuses, yet the procedures for awarding bonuses to management itself were not clearly defined. This led to a situation where a deputy head of the organisation allocated large bonuses to himself without justification. After the prosecutor's office intervened, the violations were corrected. If organisations fail to comply with, or inadequately comply with, the demands set out in prosecutors' submissions aimed at remedying violations of the law, prosecutors seek full rectification of such violations through judicial proceedings. For example, a district prosecutor in the Tambov Region filed a claim with the court seeking to oblige a municipal housing and utilities enterprise to adopt organizational anti-corruption measures that had not been implemented following the review of the prosecutor's submission. The court upheld the prosecutor's demands. In addition, such organisations and their officials may be held administratively liable under Article 17.7 of the Code of Administrative Offences of the Russian Federation (CAO) for willful failure to comply with a lawful demand of a prosecutor issued within the scope of his or her authority as established by federal law. The special section "Anti-Corruption" on the official Website of the General Prosecutor's Office of the Russian Federation contains the most relevant materials, which may be of interest to a wide range of persons: legislation on combating corruption, guidelines, information on international cooperation in this area, information on organized anti-corruption activities and many other. ## V. ENFORCEMENT AND ACCOUNTABILITY In line with international standards, Russian legislation has established mechanisms to hold legal entities accountable for corruption-related offences. This is an essential component of our broader anti-corruption strategy. Under Russian law (Article 14 of the Federal Law "On Combating Corruption"), legal entities (including sports organisations) can be held liable for corruption offences if the offence was committed on behalf of or in the interests of the organisation. This liability does not exempt individuals from being held accountable for their actions. For example, Article 19.28 of CAO stipulates fines for legal entities involved in corrupt activities, such as offering, promising or giving money, securities, property, or property-related services to officials in exchange for favours. The prosecution office is exclusively responsible for initiating such cases, which are then reviewed by federal judges. The penalties for such offences can include substantial fines and the confiscation of property or other benefits obtained through the offence. These penalties serve as a powerful deterrent against corruption. To illustrate the effectiveness of these measures, in 2024 alone, 480 legal entities were brought to administrative responsibility under Article 19.28 CAO. The total amount of fines imposed by the courts reached 932 million rubles. These figures underscore the seriousness with which Russia approaches the issue of corporate responsibility in the fight against corruption. For example, a hockey club in one Russian region was fined after its director used an intermediary to bribe a government official in exchange for favourable decisions regarding budget support for the club. But financial penalties are not the only consequence. Russian law also imposes restrictions on companies found guilty of corruption. For instance, any company that has been sanctioned under Article 19.28 CAO is prohibited from participating in public procurement for two years. This measure is crucial in ensuring that companies with a history of corruption do not continue to benefit from government contracts. To enforce this regulation effectively, a special registry of companies that have been penalized under this article is maintained and published in the Unified Information System for Public Procurement. This transparency ensures that the public and other businesses are aware of which companies have been involved in corrupt practices, further discouraging such behaviour. The Russian Criminal Code includes several articles related to corruption offences, such as bribery, commercial bribery and embezzlement. For example, the director of a state institution overseeing Olympic preparations and his deputy were convicted of accepting a large bribe from a hockey club. In exchange, they provided access to a training facility without the necessary contracts. The court fined them 1 million rubles. In another case, the head of a regional sports department orchestrated fraudulent activities by inflating prices during a public auction. He submitted fictitious commercial proposals and falsified acceptance certificates, resulting in a loss of 1.5 million rubles in public funds allocated under a national sport project. A criminal case was launched against him for embezzlement. Usually, corruption crimes are detected through special investigative techniques such as wiretapping, surveillance, and operational experiments. However, sometimes crimes are also detected during routine checks by the prosecutor's office. As an example, a prosecutor's inspection uncovered that a sports school director unjustifiably awarded a bonus to an individual who did not actually work for the organisation. This led to the initiation of a criminal case for abuse of official powers and forgery. A special article in the Criminal Code, Article 184, addresses unlawful influence on the outcome of official sports competitions or profit-making contests. This includes bribing athletes, referees, and other participants, as well as coercing or conspiring with them to manipulate results. The penalties for such actions are severe, especially when committed by organized groups or officials. In 2018-2019, the executive director of a football club conspired with the head coach of another club to secure a victory in a professional football league championship. The coach agreed to arrange for his team to deliberately lose the match in exchange for a monetary reward. Several players from the team were also involved in the scheme. As a result, the match, which took place on May 13, 2019, ended with a 3-1 victory for the director's team. The investigation into this case was conducted by the department responsible for organized crime within the Ministry of Internal Affairs of Russia. Charges were brought against the individuals involved under Article 184, Part 3 of the Criminal Code of the Russian Federation, for conspiring to manipulate the results of an official sports competition. In 2022 and 2023, guilty verdicts were issued, marking the first convictions in Russia for match-fixing. The coach and six players involved were fined amounts ranging from 290,000 to 400,000 rubles. As for the director, he received a much larger fine of 18 million rubles. ## VI. ANTI-CORRUPTION EVALUATION OF LEGAL ACTS The evaluation of legal acts related to sports for corruption risks is regulated by special Federal Law. This process aims to identify and eliminate provisions that could create conditions for corruption. Anti-corruption expertise is a unique legal tool that plays a crucial role in Russia's strategy to prevent corruption at its roots. This tool allows prosecutors to carefully examine legal documents — both existing laws and draft regulations — with the aim of identifying and eliminating provisions that might create opportunities for corrupt activities. These provisions, which we call "corruption factors," may not violate the law directly, but they create loopholes or conditions that facilitate corruption. For example, corruption factors can include the absence or incompleteness of administrative procedures that govern the rights of citizens and organisations. Another common issue is the unjustified broad discretion granted to officials, which can lead to biased decision-making. Additionally, unclear or overly burdensome requirements placed on citizens and organisations can become breeding grounds for corrupt practices. These are just a few examples of how legal provisions, if not carefully scrutinized, can inadvertently open doors to corruption. Russia has taken a leading role in implementing this tool, becoming a pioneer in many aspects of anticorruption measures. To give you an idea of the scale of this work, consider the following figures: Every year, Russian prosecutors analyse tens of thousands of legal acts and their drafts. Within these documents, corruption factors are typically identified in about $4 - 5\%$ of cases. This may seem like a small percentage, but given the vast number of documents analysed, it represents a significant amount of work. The elimination of these factors strengthens the integrity of our legal system and reduces the risk of corruption across various sectors. For example, the anti-corruption review of a Ministry of Sports order revealed that certain provisions allowed officials to refuse to register sports federations without providing a means to appeal such decisions. This gap was addressed following a prosecutor's intervention. Another Example: Following an appeal by the Prosecutor's Office of the Republic of Mordovia, the procedure for granting subsidies from the Saransk urban district's budget for reimbursement of costs associated with transportation of passengers during the days of the FIFA 2018 World Cup matches was amended to comply with federal law. Previously, these procedures imposed unnecessary restrictions on subsidy recipients, such as prohibiting the acquisition of foreign currency using allocated budget funds. They also granted excessive discretionary powers to local government officials in deciding whether to grant subsidies. These factors were recognised as potential sources of corruption and were subsequently corrected. ## VII. CONCLUSION Russia's approach to preventing corruption in sports is characterised by legal precision, institutional involvement, and regulatory adaptability. Through compliance obligations, prosecutorial oversight, administrative and criminal enforcement, and the review of legislation, a multifaceted system has emerged. While challenges remain, particularly in enforcement consistency and awareness, the Russian model offers valuable insights into the development of a holistic anticorruption framework applicable to the sports sector. [^1]: Article 1, Paragraph 1, Federal Law No. 273-FZ, December 25, 2008, "On Combating Corruption". _(p.1)_ [^2]: Article 1, Paragraph 2, Federal Law No. 273-FZ, December 25, 2008, "On Combating Corruption". _(p.1)_ [^3]: See, e.g., Yu. V. Truntsevsky et al., Combating Corruption in the Business Sphere: A Scientific and Practical Guide (T. Ya. Khabrieva & O. S. Kapinus eds., Inst. of Legislation & Comp. L. under the Gov't of the Russ. Fed'n 2020) (in Russian); _(p.2)_ [^4]: See Methodological Recommendations of the Ministry of Labor of the Russian Federation on the Development and Implementation by Organizations of Measures to Prevent and Combat Corruption (issued Mar. 28, 2014, amended Nov. 10, 2018), Ministry of Labor and Social Protection of the Russian Federation, https://mintrud.gov.ru/ministry/programms/anticorruption/015/0 (last visited July 5, 2025) (in Russian). _(p.2)_ [^5]: Article 26.2, Federal Law No. 329-FZ, December 4, 2007, "On Physical Education and Sport in the Russian Federation". _(p.2)_

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