Since time immemorial, sports have been an important part of the society. It has been given considerable attention and resources for its development. Not only the sports, but individuals involved in such sports, particularly the sportsmen too, have been treated with great importance and repute. The history related to the phenomenon of sports dates back to 3000 years ago. However, in earlier times, sports were more like a preparation for a war. Sports as an idea itself came into prominence after the Greeks organised the first Olympic games in the year 776 BC and it has seen its development ever since.
The sports, in its commercialised form in the recent times, has evolved as an international event which involves various stakeholders other than the people are who are actually playing the sports, such as the sponsors, broadcasters and the viewers from different parts of the world. This commercialisation has led to high influx of money in the sporting events, thus, making sports an economy in itself with various States and world order thriving over it. The enthralling phenomenon of sports and the economy associated with it has helped the sportsmen and their supporting staffs by developing various infrastructures and logistics for them. However, it has also attracted certain criminal-minded individuals to feed upon the opportunities any sport offers. There has been ever increasing risk of the economic offences such as fraud and corruption because of the huge amount of money involved in modern sports. Just like any other business, a sport can be used by criminals to launder the proceeds of crime or to perpetrate illegal activities for financial gain.
Sports that could be vulnerable to illegal activities are either big sports played and watched worldwide like football, or region-specific favourites like cricket, basketball or ice hockey, or sports like boxing, kickboxing and wrestling that traditionally have certain links with the criminal milieu. Football has been one of the major sport that has evolved itself as an industry having an economic impact upon various social structures at different levels. It is pertinent to observe that football maintains various mechanisms through which the development at economic, social, educational and cultural levels has become possible. The rapid capitalism has affected the game of football, particularly since the start of 1990s, whereby money invested in football surged mainly as a result of increase in television rights and corporate sponsorships. Simultaneously, the labour market for professional football players had experienced unprecedented globalisation – with more and more football players contracted by teams outside their country and transfer payments of astounding dimensions. Transfers are carried out all over the world, with the highest recorded transfer fee being Neymar’s transfer from F.C. Barcelona to Paris Saint-Germain in August 2017 for £198 million pounds. The cross-border money flows that are involved may largely fall outside the control of national and supranational football organisations, giving perfect opportunities to move and launder money.
Such massive influx of money in football has made the game prone to various corrupt and unethical practices such as bribery, tax evasion, money laundering, nepotism, etc. Some of the reasons which can be associated to aforementioned unethical endeavours of the individuals are:
- The market of football which comprises of various stakeholders has been very easy to penetrate for the corrupt individuals mainly due to the minimal or vanished entry barriers in the market.
- One of the major issues has also been the opacity of stakeholders to associate culpability or responsibility, as the network of the stakeholders concerned is very complicated. With the growth in the number of international transfers and the skyrocketing sums of television and sponsorship money that is spent on sales and purchase of players, more and more people are involved in the sector now such as managers, intermediaries, sponsors and companies who own players.
- The huge sum of money involved in the football market also induces an individual to promote unethical practices to gain an advantage in the competing world of football.
- In football market, a considerable proportion of the sum invested is with the presumption of future returns, opening a scope of unpredictability and uncertainty. Thus, an irrational character of money invested is involved.
- Financial management of the clubs and sporting parties also play a vital role as many of them are already in dilapidated shape. Such circumstances not only make them accept money without conducting proper verification of the sources but also induces the management to involve in corrupt practices.
2. FIFA’s structure
Fédération Internationale de Football Association (FIFA) is a not-for-profit association organised under the Swiss Civil Code.The purpose and the role of FIFA are to develop and promote the game of football in every part of the world as well as to regulate the sport. FIFA is comprised of national associations of 209 countries which in turn are bifurcated into continental confederations named as:
(i) Union des Associations Européennes de Football (UEFA);
(ii) Confederación Sudamericana de Fútbol (CONMEBOL);
(iii) Confédération Africaine de Football (CAF);
(iv) Confederation of North, Central American and Caribbean Association Football (CONCACAF);
(v) Asian Football Confederation (AFC); and
(vi) Oceania Football Association (OFC).
Each national association is responsible for all levels of football in the country, from amateur to professional clubs and leagues. The FIFA Congress, the legislative body of world of football, is made up of one delegate from each national association and is responsible for, among other duties, electing the President of FIFA, amending the FIFA Statutes, approving financial activities, and removing members of the Executive Committee from office. Each member association is granted one vote, such as in FIFA presidential election. FIFA is primarily led by the Executive Committee which comprises of a group of representatives belonging to a variety of geographic regions and appointed by various football confederations and associations. The role and responsibility of the Executive Committee gains the perspective, when the matter is unrelated to the responsibility of the Congress or is not specifically reserved for the other bodies of the FIFA. FIFA also contains a variety of other committees responsible for different areas of world football governance, including marketing and television, finance, legal, and football clubs.
FIFA as an organisation also holds certain judicial responsibilities where they adjudicate upon the disputes through their in-house authorities without involving any court of law. For performing aforementioned functions effectively, the rules of FIFA need the parties to abide by the jurisdiction of such adjudication and also waive off their right associated to the recourse in the court of law, thus making the decision of FIFA’s in-house arbitral body binding. The three major bodies associated to the quasi-judicial functions of the FIFA are following:
- The Disciplinary Committee: The primary aim of the Committee concerned is to maintain a level of discipline in the football matches as well as off the field. So they are associated to the adjudication of the disciplinary actions pertaining to “inadmissible conduct both on and off the field of play”, “sanctioning serious infringements which have escaped the match officials’ attention”, or “rectifying obvious errors in the referee’s disciplinary decisions”.
- The Ethics Committee: This judicial body of FIFA adjudicates upon the unethical and immoral practices such as corruption and bribery through its two wings, namely, investigative wing and judicial wing. One of the major roles of the Ethics Committee is to look upon the charges of misconduct or bribery committed specifically by FIFA’s another body – Executive Committee. The Ethics Committee is also required to be entirely independent and must avoid any third-party influence. Any party bound by the FIFA Code of Ethics, which includes all FIFA officials and players, may file a complaint regarding the breach of ethics to the investigatory chamber of the Ethics Committee, which will then initiate proceedings to potentially recommend to the adjudicatory chamber for examination.
- The Appeal Committee: The primary work of the Appeal Committee is to finally adjudicate upon the matters decided by the Disciplinary Committee and Ethics Committee which are not specifically being barred from appeal.
The primary aim which FIFA seeks to achieve through aforementioned in-house committees is the quick redressal of the grievances without involving external adjudicatory bodies. These bodies are governed and regulated by the FIFA Disciplinary Code and the FIFA Code of Ethics, whereby the officials of these adjudicatory bodies are appointed by the Executive Committee of the FIFA. The chairman of each committee is required to have “legal qualifications”, though those qualifications are unspecified.
3. Corporate crimes and FIFA’s indictment
3.1. The criminal indictment
FIFA has been marred with various controversies, one of which is the charges against various high-ranking officials of FIFA being investigated by the United States Department of Justice. “At the present time, the United States Department of Justice has obtained: (i) an initial indictment in May of 2015; and (ii) a subsequent, more inclusive indictment in December of 2015”.
3.1.1. The initial indictment of May 2015
On 27-5-2015, the United States Department of Justice unsealed a 161-page indictment in the United States District Court for the Eastern District of New York. The said indictment was against the current and former officials of FIFA, fourteen in number, and the five private business individuals who were involved in business transaction with FIFA. The Brooklyn Grand Jury returned the said indictment. In the aforementioned indictment, as a part of investigation, various raids and search operations were done by the Swiss and US officials at the Zurich headquarters of FIFA and FIFA’s various facilities in Miami. Florida Swiss authorities also conducted an early morning raid on Zurich’s luxury Baur au Lac Hotel arresting seven FIFA officials. The crimes charged include $150,000,000 in bribes paid over a period of twenty years, often in connection with the selection of a host nation for the quadrennial FIFA World Cup or the sale of marketing and broadcast rights for FIFA events. The schemes allegedly relates to the solicitation and receipt of bribes and kickbacks by soccer officials from sports marketing executives in connection with the commercialisation of the media and marketing rights. It is associated with various soccer matches and tournaments, as well as schemes related to the payment and receipt of bribes and kickbacks in connection with the sponsorship of the Brazilian Football Confederation (Confederação Brasileira de Desportos) by a major US sportswear company, the selection of the host country for the 2010 World Cup and the 2011 FIFA presidential election.
3.1.2. The subsequent indictment of December 2015
A 236-page superseding indictment was unsealed by US Attorney General Loretta Lynch on 3-12-2015. The superseding indictment described payment of more than $200,000,000 in bribes and charges sixteen additional individuals associated with football in the western hemisphere. Various other officials had also been charged, making the total number of indictees in the superseding indictment to 27. Thus, the total number of individuals and corporate defendants charged were forty-one.In the said indictment by the US authorities, the high-ranking officials of FIFA were charged for grave offences like money laundering, fraud and bribery in the period ranging from 1991 to the present. All told, the soccer officials were charged with conspiring to solicit and receive more than $200 million in bribes and kickbacks in exchange for their official support of the sports marketing executives who had agreed to make the unlawful payments.
3.2. Jurisdiction and international law
In the aforementioned indictments, the individuals who were accused and prosecuted under the United States law and the whole transaction which was in the purview of the investigation were transnational in nature and thus, a question of extraterritorial application of laws arose. However, the United States attorneys in the indictment were actually enforcing legislation that is based on the territoriality principle–the well-accepted and heavily relied upon form of prescriptive or legislative jurisdiction under public international law. It can be seen from the accusations made upon the individuals that the said indictments were of international nature. However, a closer look on facts and circumstances of the case gave a view that most of the transactions and the individuals were related to United States. The jurisdictional issues can be understood by following facts and circumstances:
- Out of the fourteen indictees, Aaron Davidson, a US national and Eugenio Figueroa, is a dual US-Uruguayan national. The other indictees are nationals of Argentina, Brazil, the Cayman Islands, Costa Rica, Paraguay, Nicaragua, Trinidad and Tobago, the United Kingdom, and Venezuela.
- FIFA, CONCACAF and CONMEBOL are all entities based outside of the United States. FIFA is an entity under Swiss Law with headquarters in Zurich, Switzerland, though it has had a development office in the United States since 2011 and FIFA’s Executive Committees held meetings in the United States. CONCACAF has been incorporated since 1994 as a non-profit organisation in the Bahamas, though its principal administrative office was located in New York and is currently located in Miami, Florida. CONMEBOL, meanwhile, is domiciled and headquartered in Paraguay.
- Third, Traffic Group, the multinational sports marketing company accused of bribing these soccer officials, is based in Brazil, though in the early 2000s it acquired a Florida-based subsidiary, which it renamed Traffic Sports USA.
However, it is pertinent to note that even though all aforementioned transactions seem transnational in nature, the important chain between the alleged bribery relates to the banks of United States and their foreign branches putting the role of United States financial mechanism in question. Thus, the indictments specifically dealt with the transactions which occurred in the United States.
3.2.1. Selection of charges
In the United States, the federal laws do not criminalise commercial bribery or private to private bribery. Thus, the indictment did not charge the individuals specifically for bribing even though the factual matrix suggested the same. The reason behind it was that the various high-ranking officials who were accused by the Department of Justice were not public officials as FIFA, CONMEBOL and CONCACAF are all registered as private bodies at the respective States. US federal laws cover the bribery of foreign public officials under the Foreign Corrupt Practices Act of 1977, as well as the bribery of domestic public officials, but bribery solely within the private sector remains a matter for State law in the United States.United States is a party to a non-mandatory criminalisation provision related to the bribery in private entities enshrined under Article 21 of the United Nations Convention against Corruption (UNCAC). Also, the United States conducted a self-assessment of their laws pertaining to bribery in the private sector institutions and found out that the said illegal conduct is already dealt with in their civil and criminal statutes through which the grievances can be addressed.
This is one of the main reasons that enabled the federal agencies to prosecute the accused people without any hindrance, despite the absence of any specific provisions related to bribery solely in private sector individuals in the United States law. Each count of the indictment is mindful to specify that the alleged wire fraud or money laundering took place in the Eastern District of New York, the Southern District of Florida, etc. In doing so, the prosecutors are enforcing laws based on the territoriality principle under international law.
3.2.2. Omitted charges
The biggest point of contention which later turned out to be a controversy was an omitted count of charge against the FIFA officials relating to the selection of the venue for the FIFA World Cup that was supposed to be organised in 2018/2022. The main explanation provided by the indicting federal agencies was that such alleged transactions in the selection of venue do not involve the United States banking institutions. Between 1984 and 2004, venues for FIFA World Cup Championships were selected separately, each chosen six years in advance. Following the same procedure in the year 2004, the venue of FIFA World Cup was awarded to South Africa. However, at the same time, in the same transaction, the procedures regarding the selection of venues were changed to grant the authority to FIFA Executive Committee to decide the venue of subsequent two editions of FIFA World Cup i.e. 2018 and 2020 in the year 2010 itself. All venues were ultimately rated low risk except for Qatar (rated as high risk) and Russia (rated as medium risk). While Russia is the largest country in the world by land area, Qatar is ranked 166 in terms of land area. This sheikhdom, part of the United Arab Emirates, does not have a strong tradition of playing football, has no indigenous football fan base and its teams have never qualified for World Cup play. One notable fact about the Qatar is that during the playing time of World Cup, the temperature is supposed to shuffle around more than 45 degree celsius. This is in addition to the fact that Qatar does not have adequate number of football stadiums and could possibly present an attractive target for terrorists from the region. An in-house inquiry was done by the Ethics Committee to address the allegations of bribery. However, the head of the Committee Hans Eckert concluded: “To assume … that envelopes full of cash ($40,000) are given in exchange for votes on a World Cup host is naïve.”
3.2.3. The presidential election
The presidential election of the FIFA was marred with various controversies in which a candidate running for the election was allegedly accused of bribing the potential voters of a particular union. Mohammed bin Hammam, a national of Qatar and the member of Executive Committee of FIFA, challenged the candidature of incumbent President of FIFA, Sepp Blatter, in March 2011. In order to promote his run, Mohammed bin Hammam set up a meeting with the Caribbean Football Union (CFU) on 10-5-2011 to 11-5-2011.Jack Warner, FIFA’s Vice-President and the President of CONCACAF (the confederation including North America and the Caribbean), then announced that there were gifts for the representatives from the CFU for each national association. Each representative was given a brown envelope with $40,000 cash. Subsequently when the scheme was discovered, Jack Warner had to resign from his positions at various levels and Mohammed bin Hammam had to withdraw his candidature. He also was subjected to an inquiry of Ethics Committee which sanctioned his permanent ban. This whole turn of events led to the reappointment of Sepp Blatter as the President of FIFA, unopposed.
3.2.4. Copa América scheme
The Copa América is one of the most watched sporting events in the world. It can be known from the fact that in 2011, it was estimated that the cumulative audience for the tournament was over five billion people. The worldwide commercial rights for the 1987 Copa América were sold for $1.7 million. Since 1986, all of those commercial rights of one of the biggest football events in the world have been largely controlled by one company – Traffic Sports. One of the special events of Copa América was organised in the year 2016 in USA where the organisers were celebrating hundred years of the event, naming it Copa América Centenario, which resulted in the huge sum of 112.5 million dollars as revenue.
The indictment accused the Traffic Sports of securing the exclusive rights of the Copa America by bribery. Allegedly, executives of Traffic Sports and associated companies were involved in bribing two CONMEBOL Presidents, and up to nine other Presidents of national football associations, including the then Presidents of the Brazilian and Argentine associations.The charges which were framed against the accused under the United States Code Title 18 i.e. Crimes and Criminal Procedure under US Code, were related to the Racketeering (Title 18, USC, Section 1952), Wire Fraud & Wire Fraud Conspiracy (Title 18, USC, Sections 1343 and1349), and Money Laundering and Money Laundering Conspiracy (Title 18, USC, Sections 1956 and1957).
“Wire Fraud in particular has the following ingredients that –
1) the defendant voluntarily and intentionally devised or participated in a scheme to defraud another out of money;
2) the defendant did so with the intent to defraud;
3) it was reasonably foreseeable that interstate wire communications would be used; and
4) the inter-State wire communications were in fact used.”
4. Accountability and corporate governance
The FIFA is working in negligible corporate governance and subsequently, such principles including corporate accountability in the modern context are totally absent in its working. The lack of corporate governance and accountability has become a pressing concern considering the fact that FIFA is a multimillion-dollar organisation having control of the football world. Scholars have suggested that FIFA officials have been able to evade repercussions because football has historically been perceived as separate from politics. Unfortunately, in light of the recent US indictments, these expectations seem to reflect idealistic sentiment rather than reality.
Since FIFA congress follows “one member one vote” policy, there is an observation of structural flaws in its framework. Some small and economically weak States which are members of the Congress are prone to corruption and bribing from the economically affluent States. It reflects that FIFA is struggling in forming a balance between the democratic structures and prevention of abuse of such democratic process as envisaged under the FIFA rules. The issues which can be observed in the aforementioned democratic structure of FIFA are as follows:
- Football power within smaller countries naturally rests in the hands of a select few. The smaller the group in which power is vested, the more susceptible a country’s votes are to corruption and bribery as evidenced by the US indictments.
- Even legitimate funding from FIFA has the potential to influence votes of smaller member States, because not only does a relatively small amount of funding go a long way in smaller nations, but money that is earmarked for development projects can easily be allocated elsewhere, including the pockets of football officials.
Even though FIFA has tried to curb the powers of the president, the lacklustre attitude towards the corporate accountability resulted in no fruits for the better functioning of FIFA. Although FIFA is affiliated with corporate giants like Coca-Cola, McDonald’s, Visa, and Adidas, none seem willing to do more than issue public-friendly statements of concern. Additionally, the immense global popularity of football makes public reputational accountability unlikely, as fans care about what happens on the pitch rather than the functioning of the governing body.
5. Conclusion and suggestions
It has been observed that the FIFA has intentionally promoted the “culture of corruption” by ignoring the loopholes in its structural framework and a lackadaisical approach towards the necessary changes it needs. Bribery, fraud and corruption have become a common event in the discharging of functions of FIFA. The law cannot always punish the individuals concerned because any penalty imposed on the erring people will not affect them much owing to their economic strength. Michael Garcia, the former head of the Investigative Committee of the FIFA Ethics Committee resigned in disgust, concluding that FIFA cannot be reformed from inside. David Beckham, English football’s leading personality, also condemned corruption at FIFA, labelling it disgusting.
Some of the suggested reforms which can help FIFA come out of this dark alley are as follows:
- Making Swiss laws strong: If the Swiss laws under which the FIFA is governed are made more stringent, there is possibility of increased corporate accountability in the functioning of FIFA. The investigation which is being done by United States and Switzerland is a right step for the recognition of the same. Approved by Swiss Parliament in September 2015, a new law, aptly named “Lex FIFA” or “the FIFA law” enhances stringency of the existing corruption laws by making the offer or acceptance of a bribe an automatic criminal offence. A law passed by Swiss Parliament in December 2014 increases the level of scrutiny that can be applied to the bank accounts of sports officials and subsequently made the leaders of sports organisations, including FIFA’s President, classified as “politically exposed persons” subject to corruption investigations.
- The United States prosecution: The prosecution done by the United States can be bolstered by the implementation of anti-bribery laws pertaining to solely private individuals. Scholars suggest that the passage of a federal law criminalising commercial or private-to-private bribery could further enhance the ability of prosecutors to target this type of conduct, particularly if Congress gave the law an extraterritorial scope.
- Internal reforms: The FIFA also needs to work along with other agencies to bring a structural reform which will strengthen its administrative framework against such offences. One important change which can be brought is making the officials disclose their annual income along with revamping the “one nation one vote system”.
There is need of revamping the FIFA to protect the interest of the game of football as well as to minimise the unethical and illegal practices prevalent in the system of FIFA. It is high time that the administrative framework behind the game of football is strengthened to keep football on and off the pitch, a “beautiful game”.
*LLB, final year student, ILS Law College, Pune. Author can be reached at email@example.com
Money Laundering through the Football Sector – July 2009, Financial Action Task Force Report, OECD, <https://www.fatf-gafi.org/media/fatf/documents/reports/ML%20through%20the%20Football%20Sector.pdf> (hereinafter referred as “2009 FATF Report”).
 Vivek Sharma, Football and Cricket Most Susceptible to Money Laundering, Moneylife, <https://www.moneylife.in/article/football-and-cricket-most-susceptible-to-money-laundering/36919.html>
 Tim Krabbenbos, Commercialisation Strategies in Football, Univ. of Twente Bus. Rev., <https://essay.utwente.nl/62826/1/Masterthesis_TPKrabbenbos.pdf> (2016).
FC Barcelona communiqué on Neymar Jr. (Press Release), FC Barcelona, <https://www.fcbarcelona.com/en/news/748497/fc-barcelona-communique-on-neymar-jr>(3-8-2017).
2009 FATF Report, supra note 1.
 Raffaele Poli, Loic Ravenel & Roger Besson, Financial Analysis of the transfer Market in the Big 5 leagues (2010-2018), CIES Football Observatory Monthly Report, https://football-observatory.com/IMG/pdf/mr37en.pdf (2018). (hereinafter referred as “CIES Report 2018”)
Schweizerisches Zivilgesetzbuch (ZGB)(Civil Code)10-12-1977, SR 210, Art. 60 (Switz.).
FIFA Fact Sheet – FIFA’s 209 Member Association, FIFA, http://www.fifa.com/mm/document/fifafacts/organisation/52/00/10/fs-120_0Ia_mas.pdf (hereinafter “FIFA Fact Sheet”).
Chance Esposito, A Red Card for FIFA: Corruption and Scandal in the World’s Foremost Sports Association, 16 Rich. J. Global L. & Bus. 45, <https://scholarship.richmond.edu/cgi/viewcontent.cgi?article=1147&context=law-student-publications> (2016) (hereinafter referred as “Esposito”).
Sean Rassel, The Necessity for National Federations to Stand Up for Themselves, 20 Mich. St. J. Int’l L. 798, <https://digitalcommons.law.msu.edu/cgi/viewcontent.cgi?article=1098&context=ilr> (2012).
 Kate Youd, The Winter’s Tale of Corruption: The 2022 FIFA World Cup in Qatar, the Impending Shift to Winter, and Potential Legal Actions against FIFA, 35 Nw. J. Int’l L. & Bus. 167, <https://scholarlycommons.law.northwestern.edu/cgi/viewcontent.cgi?article=1778&context=njilb>(2014) (hereinafter “Youd”).
Aaron N. Wise & Bruce S. Meyer, International Sports Law and Business (1997), 1461.
Corina Luck, Arbitration in Football: Issues and Problems Highlighted by FIFA’s Experiences with The Court of Arbitration for Sports (2004), 26.
FIFA, FIFA Disciplinary Code, Ch. 1, S. 3, Art. 77 (2011).
 FIFA, FIFA Code of Ethics, Pt. III, Ch. 1, S.1, Art. 26.
 FIFA, FIFA Code of Ethics, Pt. III, Ch. 1, S.1, Art. 61.
 FIFA, FIFA Disciplinary Code, Ch. 1, S. 3, Art 81.
Rory Jones,FIFA Scandal Prompts New Scrutiny of Qatar World Cup Bid, Wall Street Journal, <https://www.wsj.com/articles/fifa-scandal-prompts-new-scrutiny-of-qatar-world-cup-bid-1432920652> (May 2015).
United States of America v. Jeffrey Webb et al. (2015), (No. 15-CR-0252-RJD) (hereinafter “Webb”).
 Des Bieler, Another Raid Sweeps up more FIFA Officials in Switzerland, The Washington Post, <https://www.washingtonpost.com/news/early-lead/wp/2015/12/03/another-raid-sweeps-up-more-fifa-officials-in-switzerland/> (3-12-2015).
Webb, supra Note 22.
Sixteen Additional FIFA Officials Indicted for Racketeering Conspiracy and Corruption, US Department of Justice, <https://www.justice.gov/opa/pr/sixteen-additional-fifa-officials-indicted-racketeering-conspiracy-and-corruption> (3-12-2015) (hereinafter “Superseding Indictment Press Note”).
Webb, supra Note 22.
Superseding Indictment Press Note, supra Note 25.
Cristopher Staker, Jurisdiction, in Malcolm D. Evans, International Law316 (4thEdn., 2014).
Indictment, United States v. Webb et. al. (E.D.N.Y. May 20, 2015) (No. 1:15-cr-00252-RJD) (hereinafter referred as “Indictment”).
 Cecily Rose, The FIFA Corruption Scandal from the Perspective of Public International Law, 19 ASIL Insights 23, <https://www.asil.org/insights/volume/19/issue/23/fifa-corruption-scandal-perspective-public-international-law> (23-10-2015) (hereinafter “Rose”) ¶6.
 18 USC S. 1962(c) (racketeering conspiracy); 18 USC S. 1343 (wire fraud); 18 USC Ss. 1956–1957 (money laundering and money laundering conspiracy); 18 USC Ss. 1961(1), 1961(c) (2012).
 World Cup, New World Encyclopaedia, <https://www.newworldencyclopedia.org/entry/FIFACup> (last accessed 3-10-2020).
Statement of the Chairman of the Adjudicatory Chamber of the FIFA Ethics Committee on the Report of the Inquiry into the 2018/2022 FIFA World Cup Bidding Process prepared by the Investigatory Chamber of the FIFA Ethics Committee, FIFA, <https://www.fifa.com/who-we-are/news/statement-by-the-chairman-of-the-adjudicatory-chamber-of-the-fifa-ethi-2474165> (13-11-2014) (hereinafter “Eckert Statement”), ¶4.3.6.
 Bruce Bean, An Interim Essay on FIFA’s World Cup of Corruption: The Desperate Need for International Corporate Governance Standardsat FIFA, 22 ILSA J. Intl & Comp. L. 367, <https://www.semanticscholar.org/paper/An-Interim-Essay-on-FIFA’s-World-Cup-of-Corruption%3A-Bean/be267eb02c3fa7af7089ab6e72c129afb709565e> (2016) (hereinafter “Bean”), 376.
FIFA, Eckert: Full Publication of the Garcia Report not Legally Possible, FIFA, <https://www.fifa.com/who-we-are/news/eckert-full-publication-of-the-garcia-report-not-legally-possible-2457878> (17-10-2014), ¶7-8.
Mohamed Bin Hammam v. Fifa, Court of Arbitration for Sport Case No. CAS 2011/A/2625, Arbitral Award, ¶ 4.plz chk
Youd, supra Note 12, 168.
 Paul Sargeant, Football Corruption: Who bought the Copa America?, BBC News, <https://www.bbc.com/news/world-latin-america-33087370> (11-6-2015).
Indictment, supra Note 30, ¶109.
Will Kenton, Wire Fraud, Investopedia, <https://www.investopedia.com/terms/w/wirefraud.asp> (24-9-2019).
 Roger Pielke Jr., How can FIFA be Held Accountable?, 16 Sport Mgmt. Rev. 255, <https://sciencepolicy.colorado.edu/admin/publication_files/2013.01.pdf> (2013).
 Samuel Chi, Democracy is at Root of FIFA’s Corruption, The Postgame, <http://www.thepostgame.com/blog/daily-take/201505/fifa-corruption-probe-sepp-blatter-justice-department-fbi> (285-2015).
 Matthew B. DiCenso, A Long-Awaited Reboot: The FIFA Scandal and its Repercussions for Football’s Governing Body, 40 B.C. Int’l & Comp. L. Rev. 115, <https://paperity.org/p/82274698/a-long-awaited-reboot-the-fifa-scandal-and-its-repercussions-for-footballs-governing-body> (2017).
 Helena Bachmann, Lax Swiss Laws Led to Less Scrutiny of FIFA, USA Today, <https://www.usatoday.com/story/sports/soccer/2015/05/27/switzerland-fifa-corruption-investigation/28021111/> (28-5-2015).
 Charles Sale, Michael Garcia Slams FIFA for a “Lack of Leadership” and Resigns from Ethics Committee in World Cup Report Protest, Mail Online, <https://www.dailymail.co.uk/sport/football/article-2877754/Michael-Garcia-slams-FIFA-lack-leadership-resigns-FIFA-s-ethics-committee.html>(18-12-2014).
 Joshua Franklin & Hugh Lawson, Swiss Lawmakers Pave Way for ‘Lex FIFA’ Anti-corruption Law, Reuters, https://in.reuters.com/article/soccer-fifa-swiss-lawmaking/swiss-lawmakers-pave-way-for-lex-fifa-anti-corruption-law-idUKL5N11H16U20150911 (11-9-2015).
Matthew B. DiCenso, A Long-Awaited Reboot: The FIFA Scandal and its Repercussions for Football’s Governing Body, 40 BCInt’l & Comp. L. Rev. 115, <https://paperity.org/p/82274698/a-long-awaited-reboot-the-fifa-scandal-and-its-repercussions-for-footballs-governing-body> (2017).
Rose, supra Note 35, ¶9.