ResearchPDF Available

Combating Match Fixing in Club Football Non-Competitive (Friendly) Matches

December 2021

Authors:

Steve Menary

Nicos Kartakoullis

University of Nicosia

Christina Loizou

University of Nicosia

Content uploaded by Steve Menary

Content may be subject to copyright.

This project has been funded with support from the European Commission. This publication reﬂects the views only of the authors,

and the Commission cannot be held responsible for any use which may be made of the information contained therein.

Final Project Report

Project: 603138-EPP-1-2018-1-CY-SPO-SCP

Malta Football Players Associa

tion

‘Kelong Kings: Confessions of the World’s Most Proliﬁc Match-Fixer’ (2014), Perumal, Wilson Raj

Malta Football Players Associa

tion

“There are greater penalties for ﬁxing in the league from the FA,

so now they have to ﬁx the friendly games.”

“The clubs are not obliged to let the federation know that they

are going away and they announce the games in the press

purely for betting.”

“We were losing a friendly 2-0 at half-time so the owner said you

may as well let in another two goals.”

“Friendly matches were a different story altogether because I

would be watching the game from the bookies corner so, when

there were changes in my plans, I would page my players at half-

time from a payphone in a nearby cafeteria and they would call

me back. Then I would instruct them on the number of goals that I

needed. Done. The money was usually handed out after the match

at the same cafeteria.

Testimony from players on playing in club friendly matches (Names withheld by agreement).

Convicted match-ﬁxer Wilson Raj Perumal.¹

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

COMBATING MATCH FIXING IN CLUB

FOOTBALL NON-COMPETITIVE MATCHES

Contents

Introduction & Overview

Current National, International, and Global Regulation

Player Surveys

Role of Player Unions

Suspicious Friendly Matches

Training Camps and Friendly Tournaments

Case Study

Categorisation and Methodology of Fixing a Friendly

Possible Non-betting Related Reasons for Manipulating a Friendly

The Global Betting Market

Role of Betting Operators and European Betting Regulation

Role of Data Providers

Role of National Platforms, Interpol and Europol Data Standards

Conclusions

Recommendations

Appendices, methodology and needs analysis

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2 h!ps://www.reuters.com/article/uk-soccer-ﬁfa-friendlies-idUKTRE7225KL20110304

3 h!p://www.sportsintegrityinitiative.com/tackling-match-ﬁxing-threat-posed-lower-tiers/

4 UEFA Club Licensing Benchmarking Report (2020), p115.

Malta Football Players Associa

tion

The aim of this project was or has been to fully

understand the issue of manipulation in non-

competitive matches – hereafter described as

friendlies – which are an increasingly important

part of the football industry in terms of player

development, globalising the fanbase for larger

transnational clubs and in providing product for

betting companies. A lack of oversight by the

sport’s regulators leads to the impression that

governance is not important for the majority

of club friendlies and this project explores

what governance exists, the role of existing

stakeholders and how friendlies are exploited

by match-ﬁxers.

For transnational clubs from competitions

such as the English Premier League and

Spanish La Liga, friendly matches are as

focused on growing an international fanbase

as preparations for the new season. For the

latter reason, clubs throughout Europe play

thousands of friendly games every year, notably

within the framework of pre-season and training

camps in both summer and winter when

leagues take a break.

These games are not only an important part of

the sporting calendar, but also have ﬁnancial

stakes, in particular from the perspective of

betting. As underlined in this report, there is a

growing body of evidence showing an increase

of match-ﬁxing in friendlies.

Bogus international matches have been

organised by ﬁxers since at least 2010. The

ﬁrst public case occurred when a fake Togo

international team played international matches

to defraud betting companies. This prompted a

response from FIFA, which in 2011 pledged to

tighten the rules around these games.2

Since then, however, there has been no

concerted action to tackle match-ﬁxing club

friendlies and alerts from betting monitoring

bodies for suspicious betting movements

have increased and outperformed the average

for competitive matches in 2017 and 2018

according to data from STATS Perform and

Star Lizard. This was even before the COVID-19

outbreak, when friendly matches were the only

games available to try and corrupt during the

spring and summer of 2020.

The reasons for this increase are varied and

complicated, but the status of friendlies at most

levels of the sport has created an impression

that these matches do not matter either at a

sporting level or in terms of governance. There

is little regulation of friendlies at club level

and the few guidelines that do exist are only

sporadically enforced.

In common with a growing trend of recent

sporting manipulations, the problem is at

the lower level of the professional and semi-

professional club game, where more matches

are already coming under suspicion but cases

are not making it to the Court of Arbitration for

Sport (CAS), due to the high threshold of proof

required to uphold a match-ﬁxing charge. 3

Clubs in many smaller European leagues are

easier to inﬁltrate due to endemic ﬁnancial

weakness. In 2020, for example, UEFA noted:

“Given the number of clubs spending at

least €6 for every €5 they make (i.e.,

with loss margins in excess of 20%), there

appears to be a continued reliance on

benefactors and occasional income from

transfers and training compensation. Indeed,

there are a number of countries where

profitability remains the exception, rather

than the rule.” 4

Match type 2017 (%) 2018 (%)

Friendlies 1.20 2.00

All Games 0.73 0.61

INTRODUCTION & OVERVIEW

Figure 1. Suspicious matches by type

5 The Involvement of Organised Crime Groups in Sports Corruption: Situation Report. Europol (2020), p4

6 Federbet Annual Fixed Matches Report (2014)

7 Federbet Annual Fixed Matches Report (2015)

8 h!ps://www.bloomberg.com/news/articles/2014-08-12/soccer-bookmakers-pulled-bets-twice-in-2014-on-false-data

9 h!p://www.dutchnews.nl/news/archives/2015/01/match-ﬁxing-claims-about-dutch-club-friendlies-in-spain/ The Standard Liege vs

Heerenvereen game can be viewed here: h!ps://www.youtube.com/watch?v=xrLn6r_w-V0

10 This ICSS report into this investigation was not made public but this project has a copy.

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

This financial instability and the lack of

governance makes friendly games easier

to corrupt, particularly in Europe, where

the involvement of organised crime groups

in sporting manipulation is also increasing.

In 2020, Europol noted that: “OCGs

predominantly target sporting competitions

matching the profile of lower level

competitions across different sports.” 5

Additionally, there are unsuitable owners or

outside investors, such as organised crime

groups (OCGs), seeking to taking advantage of

the ﬁnancial weakness at the lower level of the

European game. As stated by many interviewees,

they see friendlies as easier to corrupt,

particularly given the lack of sporting or criminal

sanctions for any incidences of manipulation.

Due to the reduced proﬁle of friendly matches

generally and the involvement of lower level

clubs, these problems are only rarely covered

in the media and usually result in little or no

action being taken by the respective governing

authorities. Nonetheless, evidence of the

problem exists.

Some suspicious games attract headlines in

the media but there are rarely follow-up stories

about if and how players, clubs, ofﬁcials or

outside actors are prosecuted and sanctioned

for these incidences.

Incidences of manipulation of friendlies began

to increase at the turn of the last decade.

According to betting monitoring group

Federbet, there were 11 club friendly matches

played in Europe where they monitored

suspicious betting activity between January

and May 2014.6 These games involved clubs

from Bulgaria, China, the Czech Republic,

Finland, Lithuania, the Netherlands, Norway,

and Sweden.

Between September 2014 and January 2015,

Federbet reported another eight friendlies

involving clubs from Albania, Armenia, the

Czech Republic, England, Germany, Italy,

Latvia, Russia, Portugal, and Slovakia where

suspicious betting activity indicated potential

match manipulation. 7 One of these games

was a ‘ghost’ friendly, which did not actually

take place and was created by corrupted data

scouts to defraud betting companies.8

In January 2015, the International Centre for

Sports Security (ICSS) warned of a criminal

gang operating in southern Spain after

investigating matches between ADO Den Haag

of the Netherlands and Albanian champion

Skënderbeu Korçë in Estepona, as well as

another game between Dutch club Heerenveen

and Belgian side Standard Liège in Murcia,

which had been manipulated. 9 10 Between

November 2010 and April 2016, UEFA’s Betting

11 h!ps://www.theguardian.com/sport/2018/mar/19/match-ﬁxing-skenderbeu-albania-uefa-report-ban

12 ‘Norwich City forced to apologise for reporting on the wrong opponents in bizarre pre-season dispute with local Italian side’

Mailonline, 25 July 2014.

13 h!p://www.sportsintegrityinitiative.com/portuguese-football-league-reports-federbet-over-ﬁxing-claims/

14 h!p://www.sportsintegrityinitiative.com/the-ghost-game-phenomenon/

15 Federbet Annual Fixed Matches Report (2016)

16 h!p://www.baltic-course.com/eng/legislation/?doc=127614

17 ‘The Romanian Network – the Story of Dubious Friendly Matches’ Futbolgrad 27 January 2017.

18 h!p://futbolgrad.com/romanian-network-dubious-friendly-matches/

Malta Football Players Associa

tion

Fraud Detection System identiﬁed 53 matches

involving Skënderbeu Korçë that were allegedly

manipulated for betting purposes.11 These

matches included club friendlies, which the club’s

president is alleged to have been ‘targeting’ for

‘illegal gain’.

The lack of regulation and governance around

friendlies is best illustrated by an incident in

2014, when English club Norwich City beat

Italian Serie D club Saint-Christophe Vallée

d’Aoste 13-0 in a friendly match only to

subsequently discover that their opponents

were not the Serie D club, but a regional select

from the Aosta hastily assembled after the real

club was unavailable.12

This lack of transparency around friendlies

allows for the creation of ﬁxtures simply to

defraud betting companies. In August 2014,

Betfair suspended betting on a friendly in

Portugal involving SC Freamunde after which

their supposed opponents, SD Ponferradina,

denied involvement in the game.13 In 2015,

SBOBET and Bet365 took bets on a friendly

between two Belarusian clubs, FC Slutsk and

Shakhtor Soligorsk, that never took place.14

Between July 2016 and February 2016,

Federbet identiﬁed another nine club friendlies

played in Europe where suspicious movements

on betting markets suggested that manipulation

was likely. These games involved clubs from

Azerbaijan, Croatia, Cyprus, Greece, Germany,

Hungary, Romania, and Turkey.15

Friendlies are sometimes organised into

privately-run tournaments and these are also

vulnerable to manipulation due to lack of

organised integrity. In January 2017, a match

in the Baltic Winter Cup tournament between

Latvian club Babite and Lithuanian team

Marijampole Suduva was allegedly ﬁxed.16

The Latvian Football Federation launched an

investigation and Babite were subsequently

expelled from the Latvian Virsliga.

Appointment of ofﬁcials for ﬁxtures organised

by private tour operators and match agents is

another area of weakness. In 2017, ﬁve matches

involving Romanian clubs playing in Cyprus and

Spain were cited in an investigation by Romanian

media outlet Gazeta Sporturilor, which uncovered

that the Bulgarian referees assigned to the game

were in fact Romanians.17 A gang of match-ﬁxers

had disguised their identity to try and cover up

ﬁxes.18 Concerns over friendly games in Cyprus

are so great that data monitoring company

RunningBall – now part of the STATS Perform

Group, then just part of Perform - stopped

coverage of these games in 2017.

These are only a few examples illustrating a

genuine need for the issue of ﬁxing in friendly

club football matches to be the subject of

serious analysis and solutions in terms of

governance reform and educational tools to be

developed to combat the problem.

19 Manchester United: The Forgo!en Fixtures (Breedon Publishing: 2009), p245.

20 ‘Bans keep Leeds at home”, The Times 22/7/1987.

21 ‘Norther Exposure’, World Soccer December 2008.

22 Match-ﬁxing in sport: A mapping of criminal law provisions in EU 27, KEA European Aﬀairs, March 2012 h!p://ec.europa.eu/sport/

library/studies/study-sports-fraud-ﬁnal-version_en.pdf

23 Model Criminal Law Provisions for the Prosecution of Competition Manipulation (2013, UNODC/IOC)

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Sport’s governing bodies have been slow

to recognise the importance of regulation of

friendlies. Currently, the level of regulation

varies drastically from country to country within

Europe. This ranges from total lack of regulation

within certain countries/regions to the Deutscher

Fußball-Bund (DfB) using two specialised

companies to monitor friendlies involving

Bundesliga clubs and a tacit agreement by many

Scandinavian clubs to avoid perceived problem

areas, such as Turkey, according to sources in

the region interviewed for this report.

Intervention over the staging of club friendlies

by national, continental and international bodies

has been limited to safety or political reasons.

In 1983, Liverpool and Manchester United were

deterred by FIFA from playing in a tournament

in South Africa, which was then in sporting

isolation due to the country’s apartheid policy.19

In 1987, the Football Association of England

prevented Leeds United from playing in a friendly

tournament in West Germany due to concerns

over hooliganism.20 In 2008, English club

Luton Town visited the unrecognised Turkish

Republic of Northern Cyprus and planned a

friendly against local club Cetinkaya, which was

subsequently cancelled after complaints to FIFA

by the Cyprus Football Association. 21

Action against match manipulation in club

friendlies is sporadic despite the fact that

investigating allegations of match-ﬁxing in

football is vital to maintaining participant and

stakeholder conﬁdence in the game. Indeed,

the manipulation of football matches to make

money from betting markets affects the very

essence of the principle of loyalty, integrity, and

sportsmanship.

In general terms, the responsibility for tackling

these issues rests with the relevant governing

body. In the case of club-level football, it is the

national association. For national team-level

matches, it is either UEFA for Europe or FIFA

worldwide. This responsibility includes friendly

matches as the reputational damage is the

same, although the reality is that they do not

receive the same level of response, certainly at

club level.

Most incidences of match-ﬁxing in football are

likely to involve the commission of a crime,

especially when fraudulently making money

from betting is the reason for the ﬁx. As a

consequence, investigating such matters are

responsibility of the police or other public

bodies entitled to enforce the law of the land.

Additionally, football governing bodies generally

do not have the in-house resources (or skill

levels) to investigate such allegations.

However, it is rarely straightforward persuading

European police forces/law-enforcement

agencies to become involved in such

investigations. An important question in this

regard is whether investigating and combating

match-ﬁxing in football is in the public interest

in that particular country compared to other

crimes? Therefore, it does not receive the policy

response and resource attention it needs. This

is especially true when the suspicious games

are club friendlies. This combination of lack of

regulation and investigation suggests that these

games are not considered by the football and

judicial authorities to be real football matches.

Additionally, match-ﬁxing is an idiosyncratic

offence, meaning that the legislation in place

across Europe can either help or hinder an

investigation depending on the country. By way

of example, the British Gambling Act includes

a provision of cheating at gambling which can

be used for betting related match-ﬁxing. Only a

handful countries have more speciﬁc provisions

for match-ﬁxing in their criminal codes. 22 A

2013 study by the United Nations and the

International Olympic Committee found that only

ﬁve of the 19 states studied had established

speciﬁc or ad hoc criminal offences for match-

ﬁxing, a number of these have, in the meantime,

amended or reviewed relevant legislation. 23

Paradoxically, some of the countries (such as

Portugal and Germany) that do have legislation

to deal speciﬁcally with match-ﬁxing, do not

extend it to friendly matches.

CURRENT NATIONAL, INTERNATIONAL AND

GLOBAL REGULATION

24 United Nations Convention against Transnational Organized Crime parties, treaties.un.org

h!ps://treaties.un.org/Pages/ViewDetails.aspx?src=TREATY&mtdsg_no=XVIII-12&chapter=18&lang=en

Malta Football Players Associa

tion

There is some international United Nation’s

legislation that can be of help to law-

enforcement across Europe when investigating

match-ﬁxing, notably the United Nations

Convention against Transnational Organized

Crime (UNTOC) which carries 147 signatories

and 185 state parties.24 The purpose of UNTOC

is to, “promote cooperation to prevent and

combat transnational organized crime more

effectively.” UNTOC can only be used by

public bodies and is targeted especially at law

enforcement.

One element of the UNTOC which investigators

need to be aware of at the outset is the

deﬁnition of what constitutes an ‘organized

criminal group’. Article 5 of UNTOC reads:

“Shall mean a structured group of three

or more persons, existing for a period of

time and acting in concert with the aim of

committing one or more serious crimes or

offences established in accordance with

this Convention, in order to obtain, directly

or indirectly, a financial or other material

benefit”.

This deﬁnition encompasses a wider range of

match-ﬁxing activities due to the fact that only

“three or more persons” have to be involved,

whereas in a number of countries organised

crime groups are viewed more as a network

typically much larger than three persons

involved in serious criminality. However, three

or more people are likely to have been involved

in most match-ﬁxing enterprises.

A further inhibitor is the jurisdiction issue. When

an incident of match-ﬁxing in football crosses

borders inevitably the two countries with a link

to the allegations will have different approaches

to investigating this type of crime. In the ﬁrst

instance, it is likely the investigation will be

carried out by the police force of the country

where the match takes place.

In essence, this is a question of which state or

country can exercise jurisdiction, based upon

the preliminary presumption that, if possible, a

prosecution should take place in the jurisdiction

where the main element of the corruption

occurred. However, this presumption could be

rebutted by the location of the accused at the

time the ﬁxing is discovered and whether or not

they can be detained or even extradited.

Another consideration is the judicial/court

process of the country including the amount of

time taken to hear the case and the sentencing

powers of the court should the accused be

found guilty of the match-ﬁxing offence.

Securing the attendance of witnesses would

also be a key consideration for the case moving

forward. Where organized crime is involved,

there are unlikely to be many, if any, witnesses

who come forward without the promise of

robust protection of their identity and safety.

Without witnesses, giving testimony under oath

a criminal conviction for match-ﬁxing offences

are more difﬁcult to secure.

With all these complexities, detection, disruption

and deterrence of match-ﬁxing in football

by state bodies is generally low and has the

consequence that criminal prosecutions for

match-ﬁxing in football is still relatively rare – and

even more so when it comes to successfully

prosecuting match-ﬁxing in friendlies. For

example, the investigation by Bochum police

into a major match-ﬁxing ring in Germany took

four years to reach court after arrests in 2009.

National association survey

As part of the project, a survey was carried out

in April 2021 of national associations asking

about their rules governing regulation of friendly

matches. A brief questionnaire featuring ﬁve

questions (see appendix 2) was sent to all 55

members of UEFA and 21 responses were

received. Given the nature of some replies

and the wider lack of governance surrounding

friendly matches, the level of responses was

perhaps reﬂective of some associations being

unable rather than unwilling to co-operate.

Details on which associations did and did not

respond is at the end of this section.

The results showed that 76% of associations

required notiﬁcation from clubs before these

clubs went abroad to play friendly matches.

However, given the level of responses, it would

be unwise to assume from this response that

three quarters of all UEFA members require

notiﬁcation from their clubs of overseas trips for

training camps.

In comments with responses, some federations

also acknowledged that friendlies are more

prone to manipulation. For example, the

Norwegian Football Federation commented:

“There is no formal requirement that clubs

going abroad to play friendlies notify NFF

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

about this. In practice, at least for clubs

belonging to the top tiers of Norwegian

football, NFF still keep track on the clubs’

activity abroad, both regarding opponents

and officials. This is due to fact (sic) that

NFF for many years have subsidised clubs’

preseason camps in places like La Manga

and Marbella.

“NFF has usually been part of the organising

committee for friendly tournaments played

during these camps. NFF has also used

these tournaments as training camps for

Norwegian referees. We acknowledge

however that also these tournaments have

integrity concerns.”

The notice required before playing these

overseas games ranged from 60 days (England)

to no notice (Cyprus). The bulk of respondents

requiring notice asked for between seven and

14 days, but there was a signiﬁcant difference

between countries where clubs were required

to give notice of overseas friendlies and the

amount of information on these games that had

to be provided to the national governing body

(NGB). Only 38% of respondents required clubs

that played friendly matches abroad to provide

the names of match ofﬁcials and the FIFA

licensed match agent organising these games.

For visits from overseas clubs for friendly

matches, 66% of NGBs required notice of

these trips. The notice required ranged from

60 days (England) to the day before the game

(Belgium). In 95% of cases, match ofﬁcials

for these games are provided by the home

association.

Note:

Survey respondents: Austria, Belarus,

Belgium, Croatia, Cyprus, Czech Republic,

England, Georgia, Hungary, Italy, Latvia,

Luxembourg, Malta, North Macedonia,

Norway, Poland, Slovakia, Spain, Sweden,

Switzerland, and Ukraine.

Contacted but no response received: Albania,

Andorra, Armenia, Azerbaijan, Bosnia &

Herzegovina, Bulgaria, Denmark, Estonia, Faroe

Islands, Finland, France, Germany, Gibraltar,

Greece, Iceland, Republic of Ireland, Israel,

Kazakhstan, Kosovo, Liechtenstein, Lithuania,

Moldova, Montenegro, Netherlands, Northern

Ireland, Portugal, Romania, Russia, San Marino,

Scotland, Serbia, Slovenia, Turkey, and Wales.

25 Don’t Fix It – An education and prevention programme to ﬁght match-ﬁxing in football. Report May 2014.

Malta Football Players Associa

tion

PLAYER SURVEYS

The project surveyed players to understand

their experiences of match-ﬁxing in friendlies

and make comparisons with ofﬁcial league and

cup matches.

The survey of 694 players from the top three

divisions in Cyprus, Greece and Malta covered

mainly players aged 18-30 years of age, with

the largest proportion of the sample aged

between 18-22 years. The largest proportion of

players came from Cyprus (66%) followed by

Greece and Malta.

Most of the respondents to the survey were

playing in the second division, where clubs are

ﬁnancially more vulnerable and match-ﬁxing

more likely. Around 70% of respondents came

from the country of their club of employment.

The research built on an earlier questionnaire

carried out by FIFPRO in 2014, which was part

of its “Don’t Fix It” campaign. This research

deﬁned games where respondents knew a

match that they played in had been ﬁxed or

suspected was ﬁxed and on approaches to

manipulate matches.25

Playing in a Game Players Knew or

Suspected was Fixed

The survey drew on the difference between

whether players knew a game to be ﬁxed

or suspected that the match had been

manipulated. This showed that 26.5% of the

respondents already suspected that a friendly

game they participated in was manipulated,

compared to 13.5% who said that they had

played in a game they knew was ﬁxed. Also,

16.5% of players had been approached to

manipulate a friendly.

Players who played in a friendly they

suspected was ﬁxed

Greece 35.5%

Cyprus 25.3%

Malta 21.9%

Total 26.5%

Players who played in a friendly they knew

was ﬁxed

Greece 20.0%

Cyprus 14.0%

Malta 5.6%

Total 13.5%

Players who had been approached to ﬁx a

friendly

Greece 23.3%

Cyprus 16.4%

Malta 9.6%

Total 16.5%

The Approach and the Instigators

The research sought to identify where

approaches were made to persuade players

to manipulate friendlies and who the main

instigators were. Out of the players having been

approached, 40% were done so in the dressing

room. In total, nearly half of all approaches

(49.2%) were made on club premises of the

dressing room, elsewhere in the stadium or the

training ground. A further 6.1% of approaches

were in hotels.

Who made the approach to ﬁx a friendly?

Club ocials 19.0%

Players 14.8%

Match Ocial 9.4%

Organiser/agent 8.3%

Someone else 12.0%

Don’t know 17.7%

Never confronted with

the issue

18.9%

26 h!ps://theblacksea.eu/stories/football-leaks/cypriot-deception/

27 h!ps://www.dailyrecord.co.uk/sport/football/football-news/players-deliberately-miss-penalties-purpose-9736187

28 ‘Oefendual tussen de verhuisdozen’ Dagblad De Limburger 13/7/2017.

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

A third of all approaches were made either

by club ofﬁcials (19%) or players (14.8%),

while 9.4% of approaches were by match

ofﬁcials. The percentage of match ofﬁcials

trying to manipulate friendly matches was

higher in Cyprus, where 11.4% of respondents

responded that the referees or match ofﬁcials

were responsible compared to 8.7% in Greece

and 2.1% in Malta.

Match agents seek to bypass national

associations and approach regional

associations directly, which creates an

integrity vacuum that is exploited by match-

ﬁxers.26 Match ofﬁcials going on their own

training camps overseas can be unwittingly

lured into taking charge of games targeted

for manipulation by ﬁxers, but ﬁxers also

introduced ofﬁcials into friendly matches solely

for the purpose of ﬁxing. An investigation by the

European Investigative Collaborations network

uncovered a group of eight former and current

players posing as referees who took charge of

32 matches in training camps between 2016

and 2018 as part of a series of manipulations

tied to a match-ﬁxers. This same group was

also linked to real match ofﬁcials who travelled

to Cyprus and Turkey and were involved in

suspicious friendly ﬁxtures.

Dubious ofﬁciating has been at the heart of

numerous suspicious friendlies staged in a

training camp environment in Europe. Players

sometimes responded to this by walking off the

ﬁeld, or even missing unmerited penalties on

purpose on a number of occasions in locations

including Cyprus, Spain and Turkey. 27 28

The 2014 FIFPRO survey found that in Greece,

club ofﬁcials were the main instigators

according to 48.8% of respondents and the

survey results bear this out at a wider level.

Here too, club ofﬁcials are considered as the

primary instigators of match ﬁxing according

to 25.5% of respondents. Given players’

suspicions about the involvement of club

ofﬁcials in manipulation, respondents were not

comfortable reporting approaches or concerns

over ﬁxed matches to national associations.

While younger players are often perceived as

being more vulnerable to manipulating a game

or being approached, this was not reﬂected

in responses by players from Cyprus, Greece,

and Malta. The survey showed that 86.3% of

respondents did not believe younger players

were more vulnerable. As older players typically

hold more inﬂuence and power in a dressing

room and are likely to be approached, this may

explain why younger players are not perceived

as more vulnerable.

Almost 40% of players who had been

approached, were approached in the dressing

room. This further supports the involvement

from club ofﬁcials in approaches to manipulate

a game, as only club ofﬁcials are likely to have

access to the dressing room. In total, half of the

approaches to players were in club facilities,

namely the dressing room, training ground or

stadium.

Where were players approached to ﬁx a

game?

Dressing room 39.5%

Other 19.3%

Combination of places 9.6%

Hotel 6.1%

Training ground 5.3%

Own home 5.3%

Elsewhere in the stadium 4.4%

N/a 10.5%

The second largest place where players were

approached is other. Anecdotally, players

routinely report approaches via social media

such as Facebook and encrypted messaging

services such as What’s App or Messenger,

so this is assumed to be the case for this

response.

In some cases, this may be connected to

‘organised criminality’, but more often is

individuals connected to football clubs, such as

owners or even sponsors, who have access to

the dressing room, training ground and other

non-public areas of the stadium.

29 h!ps://www.gsp.ro/gsp-special/investigatie/investigatie-gsp-gazeta-a-discutat-cu-cel-mai-cunoscut-aranjor-de-meciuri-din-lume-

singaporezul-wilson-raj-perumal-cu-romanii-e-usor-nu-au-integritate-cum-functioneaza-sistemul-din-antalya-si-cipru-500636.html

30 As multiple answers were possible, the totals do not add up to 100%.

Malta Football Players Associa

tion

Ofﬁcials also play a key role in manipulating

friendly games, particularly when the players

are not involved. Referees working for match

ﬁxers have reportedly earned between €3,000

and €5,000 for two weeks ofﬁciating in Turkey.29

Outside of club ofﬁcials and players, match

ofﬁcials represent the next largest area of

concern according to the survey, followed by

match agents, who are often involved with

recruiting and appointing these game ofﬁcials

in the ﬁrst place.

Who were the main instigators of an

approach?

Friendly Ocial

game

Club ocials 19.0% 25.5%

Players 14.8% 19.2%

Match Ocial 9.4% 8.8%

Organiser/agent 8.3% 3.6%

Someone else 12.0% 11. 9%

Don’t know 17.7% 15.1%

Never confronted

with the issue

18.9% 15.9% 30

The survey also asked players who the main

beneﬁciaries of ﬁxing friendlies were and this

was again club ofﬁcials according to 26.3%

of respondents, ahead of players on 15% and

match agents or organisers on 11%.

The survey found that 22% of players did not

know who the beneﬁciaries were. Given that

organisers such as promoters and match

agents are typically distanced from players

during friendly matches, the percentage of

match agents or organisers may be higher.

Who were the main beneﬁciaries of an

approach?

Friendly Ocial

game

Club ocials 26.3% 27.2%

Players 15% 18.2%

Match Ocial 9.2% 9.3%

Organiser/agent 11% 7.8%

Someone else 16.6% 16.8%

Don’t know 22% 20.7%

Perceptions over whether friendlies or ofﬁcial

games are more vulnerable were less clear. Out

of those having expressed an opinion, a third of

respondents believed that friendlies were ﬁxed

more frequently.

Friendlies vs Ocial Games

The survey also researched players’

experiences of ofﬁcial league and cup matches

that they knew or suspected to have been

manipulated to make a comparison with the

results for friendly games. Across the three

countries, 13.5% of respondents had played

in a friendly game they knew to be ﬁxed

compared to 21.3%, who had played in ofﬁcial

games.

The proportion of players in Greece who played

a match that they knew was ﬁxed was larger

than an earlier survey conducted as part of

FIFPRO’s “Don’t Fix It campaign” in 2014. In

this survey, 13.7% of respondents said they

had played in a game that has since been

identiﬁed as ﬁxed. This can be partly explained

by a greater proportion of players in this survey

coming from smaller clubs, where ﬁxing is more

likely to be a problem.

In the 2014 survey, the percentage of Greek

players who had played in a league match

that they believe was ﬁxed was higher at 64%,

compared to about 50% here.

31 h!ps://www.ugent.be/en/news-events/matchﬁxing

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Players playing in a game they knew was

ﬁxed

Friendly Ocial

game

Greece 19.8% 18.2%

Cyprus 13.9% 20.6%

Malta 5.3% 27.2%

Total 13.5% 21.3%

In addition, 42.2% of respondents had played in

an ofﬁcial game that they suspected was ﬁxed

compared to 26.5% that played in a friendly

that they suspected was ﬁxed. However, it

should be noted that players typically play in

three or even four times more ofﬁcial league

and cup matches than friendly matches even

when including games played in pre-season

and mid-winter breaks.

Players are also approached signiﬁcantly

more often to manipulate ofﬁcial matches for

sporting reasons such as league position or

European qualiﬁcation rather than solely for

betting reasons.31 As there are no real sporting

reasons to manipulate friendly matches, the

amount of suspicious friendly games is higher

as a proportion of total matches played.

Players playing in a game they suspected

was ﬁxed

Friendly Ocial

game

Greece 35.5% 49.6%

Cyprus 25.3% 30.4%

Malta 21.9% 81.6%

Total 26.5% 42.2%

Players who had been approached to ﬁx an

ocial match

Friendly Ocial

game

Greece 23.3% 45.5%

Cyprus 16.4% 11.2%

Malta 9.6% 23.9%

Total 16.5% 19.6%

Conclusion

This survey found that the ﬁxing of friendlies

is a domestic and international problem.

Respondents typically play three or four times

more ofﬁcial matches over the course of a

season than friendly games. So, the proportion

of friendly matches where players reported

both approaches and suspicions that games

were corrupted is in reality higher than ofﬁcial

games on a pro rata basis.

The main conclusion of the survey is that the

respondents believe there is indeed match-

ﬁxing in friendly matches and that approaches

to players are primarily made in the dressing

rooms, or a combination of elsewhere in the

stadium, the training ground or the hotel.

The results support the ﬁndings that the main

instigators and beneﬁciaries for match-ﬁxing

for both friendlies and ofﬁcial matches are

club ofﬁcials according to 19% and 25.5% of

respondents confronted with the issue. These

personnel typically have access to the main

venue for making approaches to players. This

was the key ﬁnding across all three countries.

32 As multiple answers were possible, the totals do not add up to 100%.

33 h!ps://www.uefa.com/insideuefa/stakeholders/news/0219-0f8a6924b415-ad5fc8fc44f6-1000--european-football-adopts-code-

of-conduct-on-integrity/

Malta Football Players Associa

tion

ROLE OF FOOTBALL

PLAYERS’ UNIONS

Players unions play an essential role in

combating all types of match manipulation and

most importantly protecting their members.

The survey of players from Cyprus, Greece,

and Malta showed that players unions are the

primary institution for players to report these

concerns (84.5% of all respondents) ahead of

the police (54.8%) and national associations

(37.1%). 32

To try to deter match-ﬁxing, international

football players union FIFPRO launched the

Don’t Fix It project in 2012 in cooperation

with Birkbeck University, the European

Union and UEFA. FIFPRO did not believe in a

zero-tolerance policy and a one-size-ﬁts-all

approach and wanted to enter the dressing

room to ﬁnd out why players become involved

with match-ﬁxing and to produce a programme

to inform and protect players from the dangers

of match manipulation. The goals of this

educational and prevention programme are to:

• raise awareness

• reduce the conditions that lead to match-

ﬁxing

• establish strong and relevant networks at

national and European levels.

FIFPRO and UEFA also developed a Code of

Conduct in 2014 against match-ﬁxing, which

has been adopted by all stakeholders in

European professional football. 33

Project partner P5 EU Athletes is also a

recognized stakeholder in the European sport

sector and adopted combating match ﬁxing

a key priority in 2016. Since the ﬁrst EU

Workplan for Sport, EU Athletes has been an

observer to different EU Expert Groups on

Good Governance, Match-Fixing and Integrity,

to represent the voice of the European athletes

at European institutions.

EU Athletes has worked with the three FIFPRO

members on this project - P2 PASP in Cyprus,

P6 PSAP in Greece and P7 MFPA in Malta - to

develop educational awareness programmes

that encourage players to understand and

report match manipulation in friendly games.

The three FIFPRO members involved with this

project have also all adopted the UEFA Code of

Conduct and independently rolled out their own

match ﬁxing awareness programmes.

In Cyprus, this comprises:

• Training and education of player members

• Awareness of match-ﬁxing

• Training Seminars about the manipulated

games

• Research and Scientiﬁc studies

• Mental health programs and support of

professional football players

PASP also offers legal assistance, advice

and protection. In addition, it established a

wide network of people in key positions that

can provide help to players. PASP has also

launched several campaigns against the

manipulation of football matches using a variety

of mediums from bracelets, shirts, and leaﬂets.

Furthermore, it developed a Code of Conduct

that sets out the guiding principles for all

players on the issues surrounding the integrity

of football.

In Greece, the aims of PSAP are to develop

athletic spirit, fair competition, solidarity

among colleagues and mutual aid between

its members. PSAP aims to protect football

from any danger obstructing its progress

and improvement. PSAP’s work includes

studying the social, technical, economic, and

professional problems of its members and to

look for methods, ways and means for their

resolution.

In Malta, the MFPA emphasises the following to

its members about match-ﬁxing:

• It is a criminal offence

• Refusing is the right thing to do

• The player risks huge sporting sanctions

that will probably end their career

• Criminal charges may be brought against

the player, with legal consequences if found

guilty

• Participating will aid criminal organisations

• Participating will directly harm the sport that

billions of people love

34 h!ps://www.independent.com.mt/articles/2018-08-22/football/Court-of-Arbitration-for-Sport-upholds-two-year-ban-for-Maltese-

football-player-Samir-Arab-6736195223

35 h!ps://www.uefa.com/insideuefa/about-uefa/news/0248-0f8e62b299fc-bebe1ae66c15-1000--uefa-welcomes-cas-decision-to-

dismiss-appeal-by-maltese-player-/?referrer=%2Finsideuefa%2Fnews%2Fnewsid%3D2567612

36 ‘Which whistle-blowing system for the French national platform to ﬁght against the manipulation of sports competitions?’ Kalb,

Christian. (October 2018).

37 h!ps://www.ﬁfa.com/who-we-are/news/ﬁfpro-ﬁfa-sign-collaboration-agreement-to-reinforce-ﬁght-against-match-ﬁxing

38 h!ps://www.youtube.com/watch?v=p7V7-Z3yykA

39 h!ps://cyprus-mail.com/2020/02/13/red-bu!on-app-eﬀective-while-protecting-players-anonymity-says-pasp-president/

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Apart from refusing to participate, players in

Malta are also requested to report any match-

ﬁxing approach immediately. A failure to do so

may result in heavy sporting sanctions. Whilst

MFPA is wholeheartedly against match-ﬁxing,

it also understands that reporting an approach

may not be as straightforward as some people

may think. Fear of reprisals for refusing to

comply with match ﬁxers is a reality amongst

players. Some players would rather face sporting

sanctions than create other consequences for

themselves and their families.

The case of Samir Arab is an example of this.

UEFA investigated two European Championship

Under-21 qualifying matches that took

place in March 2016. These games were not

manipulated because several Maltese players

who were approached - including Arab -

refused to take part in match-ﬁxing. Arab only

reported the approach three weeks after the

incidents occurred, but cooperated fully with

a police investigation, gave evidence in court

against the match-ﬁxer and was described by a

Maltese court as a “very important witness.” 34

The police investigation and Arab’s testimony

preceded UEFA’s disciplinary charges by

approximately one year, but in 2018 UEFA

subsequently decided to ban Arab for two

years for not immediately reporting the incident.

This ban was subsequently upheld by the Court

of Arbitration for Sport.35

As a consequence of this incident, MFPA set

about trying to help players do the right thing

for themselves and their sport. Research

as well as consultation with players and

stakeholders led MFPA to the conclusion that

an anonymous reporting mechanism would go

a long way to alleviating these fears.

There are many reporting options developed

for players. FIFA has conﬁdential methods for

players to report match-ﬁxing approaches

through its FIFA Integrity App and another

integrity app, BKMS. FIFPRO’s smartphone

Red Button app, was also developed in 2016 to

encourage players to report concerns and rated

the most effective in use in 2018 according to

an independent report.36

In September 2020, FIFPRO and FIFA signed a

collaboration agreement to encourage players

to use the Red Button app.37 In 2020, the

MFPA introduced the Red Button app to Malta

and this was personally endorsed by Samir

Arab.38 Licensing expenses are completely

covered by FIFPRO and MFPA members can

request a unique code, which allows them

to access the web-app. Codes are randomly

assigned, and there is no way to link a code

to the player. Via this web-app the player

can submit an anonymous report which is

completely untraceable.

The MFPA believes that with the co-operation

of players, the Red Button can be a crucial

tool in the ﬁght against match ﬁxing. The Red

Button app was introduced into Cyprus on

February 5 2020 and within weeks the local

union had received 20 reports that led to two

arrests for match-ﬁxing.39 Over the course of

the 2019/20 season, the Cypriot players union

PASP reported 35 reports via the Red Button.

Reporting anonymously is the preferred route for

67.7% of players surveyed in Cyprus, Greece and

Malta for this project and 69.1% of respondents

would do so using FIFPRO’s Red Button.

Malta Football Players Associa

tion

SUSPICIOUS FRIENDLY

MATCHES

Instances of suspected manipulation in club

friendlies began to emerge publicly in the ﬁrst

decade of the new Millennium as the training

camp industry, which had initially developed in

more traditional destinations such as Portugal

and Spain to cater for pre-season preparations

for visiting clubs, began to expand. Euro

2008, which was jointly staged by Austria and

Switzerland, provided the catalyst for a growth

in training camps in the former, while other

destinations offering lower budget camps began

to grow in popularity in places including Cyprus,

Slovenia, and Turkey.

As more matches were played in these camps,

betting operators began to offer more of these

games to customers and there was an increase

in the number of matches attracting suspicion

amongst betting operators and monitoring

companies for suspicious betting.

Between 2012 and the end of 2015, more than

60 friendly matches in Europe were identiﬁed as

“suspicious” just in open-source media alone.

The majority of these games were staged in

Turkey, Spain and Cyprus and played during the

summer or midwinter breaks.

The dataset for these games covers the period

2016 to 2020 inclusive and was compiled by the

main author of the report from a wide range of

sources, including open source media, players

and national player associations, bookmakers,

betting monitoring companies and national

associations. Further details on how this dataset

was gathered is available on P42-43.

Games were rated as suspicious by the

organisers of this project based on criteria set

by betting monitoring companies or betting

operators, open-source details in publicly

available media investigations that indicated

some form of manipulation was possible or

on the testimony of players. It is important to

note that these friendly matches should be

categorised as “suspicious ﬁxtures” and NOT as

conﬁrmed ﬁxed games.

Overall, in the ﬁve years between 2016 and 2020,

there was a total of 257 friendly games staged in

Europe that can be categorised as “suspicious

ﬁxtures” in terms of match manipulation. These

are games where a rating for suspicion is at a

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COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Figure 2. Suspicious friendlies by country

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40 h!ps://www.sportsintegrityinitiative.com/match-ﬁxing-in-the-ukraine-the-grim-reality

41 h!ps://www.bbc.co.uk/sport/football/44216041

42 h!ps://www.praguemorning.cz/czech-police-charge-20-in-soccer-corruption-probe

Malta Football Players Associa

tion

medium level or above, or where media stories

suggest clear reasons for suspicion or, in the

case of games based on player testimony, where

the players reported to their unions playing in

a match including irregular activity from fellow

players, match ofﬁcials or club ofﬁcials. (For

more information, see note at the end of the

chapter. The full ﬁve-year breakdown of this data

is available in appendix 3).

The country staging the largest number of

suspicious friendlies between 2016 and 2020

was Cyprus with 44 games – or 17% of the

dataset. The next largest was Ukraine with 38

matches, although this was primarily due to a

large number of ﬁxtures in 2018 (22 games), the

single largest number of suspicious friendlies in

one year in any one country.

Ukraine had a long-standing problem that

included manipulation of friendlies with

one training camp friendly match between

Chornomorets Odessa and Olimpik Donetsk

in 2015 attracting bets of $200,000.40 However,

after 2018, action by the Ukrainian Association

of Football (UAF) to tackle match manipulation

including raids on 35 clubs, led to a drastic

reduction in the number of competitive and friendly

matches where manipulation was suspected. 41

In the Czech Republic, an existing problem with

manipulation of matches between domestic

clubs escalated as ﬁxers took advantage of

the void in competitive games created by the

COVID-19 pandemic. In December 2020, action

by local judicial authorities led to the arrests

of 19 people including the deputy head of the

Football Association of the Czech Football

Republic.42 This explains some of the suspicious

matches recorded in 2020, but not all.

Prior to 2016, Turkey staged a signiﬁcant

number of suspicious games between clubs

from other countries. The country ranks fourth

in terms of hosting suspicious friendlies for

the 2016-2020 period. No suspicious games

were identiﬁed in 2019 before irregular matches

returned again in 2020, although this time not

involving clubs from outside Turkey.

In 2019, there was a crackdown by law

enforcement on match ﬁxing in a number

of sports across Europe. The number of

suspicious friendlies in Europe subsided overall

and no suspicious friendlies were identiﬁed in

Sweden, for example. However, by the following

year there was a number of suspicious matches

including professional Swedish clubs, and

attempts to inﬂuence amateur teams after the

onset of COVID-19.

The number of suspicious friendlies staged in

Russia increased between 2019 and 2020 as

ﬁxers again appeared to take advantage of the

lack of competition games that was caused by

the onset of COVID-19 (see case study).

Neutral Venue Games

The dataset shows that 24% of the suspicious

matches over the ﬁve years of the study were

played in a different country of either of the

competing clubs. This percentage could have

been higher without the impact of COVID-19, in

2020, which reduced travelling by many clubs

with just four games in neutral venues rated as

suspicious.

The largest number of matches played in neutral

venues during one calendar year was 2016 (21

games), when 58% of all suspicious friendlies

were staged in a different country to either of the

competing clubs. (The full ﬁve-year breakdown

of this data is available in appendix 4).

Fig 3. Suspicious friendlies played in neutral

venues

Country TOTAL

Cyprus 23

Turkey 13

Spain 5

Netherlands 5

Bulgaria 4

Croatia 4

Austria 4

Slovenia 2

Slovenia 1

Poland 1

TOTAL 62

43 h!ps://uaf.ua/article/39208

44 Situation report: The involvement of organised crime groups in sports corruption. Europol (2020), p16.

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Cyprus staged the most suspicious neutral

venue friendlies, primarily due to games

between 2016 and 2018. Turkey hosted the next

largest amount. Combined with Cyprus, these

two countries hosted 61% of all suspicious

friendlies staged in a neutral venue over the ﬁve

years of the dataset. Turkey was also the host

for suspicious matches involving clubs from

other countries at the start of 2021, including

one between the Ukrainian Premier Liga side

FC Mariupol and Polish side Ekstraklasa side

Raków Częstochowa, which is the subject of

a formal complaint to UEFA by the Ukrainian

Association Football (UAF).

Clubs

A total of 338 clubs from 42 different countries,

mainly in Europe but also including a small

number of clubs from Asia and the Middle East,

were involved in suspicious friendly matches

played in Europe between 2016 and 2020.

When the same clubs are repeatedly playing

in friendly matches that attract suspicion this

would suggest that at some level, whether it

be players or staff, there is some link with the

club and possible manipulation. A total of 92

clubs were involved in two or more suspicious

matches, 35 clubs were involved in three

or more and 11 clubs played in ﬁve or more

suspicious friendlies.

The country with the largest number of clubs

involved in suspicious friendlies is Ukraine,

where one club, PFK Sumy, was involved in

10 games. Competitive ﬁxtures played by this

club also came under scrutiny. In 2020, Sumy

had its professional status removed by the

UAF.43 Five of the 12 clubs involved with the

most suspicious friendlies were from Cyprus,

where two clubs were involved in nine and eight

suspicious matches respectively over the ﬁve

years of the survey. Two Czech clubs were also

involved in seven and six matches respectively.

The majority of the clubs involved in suspicious

matches do not play in their national top

division. This reﬂects a wider shift by

manipulators to take advantage of clubs

playing at a lower level that are more prone

to being ﬁnancially weak and less likely to be

monitored.44 This also reﬂects an increase in

data being collated on these friendly games by

data providers and, in turn, being sold to and

offered by betting operators around the world

operating under varying degrees of regulation,

where inside information about team line-ups or

tactics can also be a cause of irregular betting

rather than match ﬁxing itself.

It is important to note that match ofﬁcials

play an important role in the manipulation of

matches and clubs or players have frequently

been unwittingly caught up in suspicious

friendly ﬁxtures. Even where clubs are behind

ﬁxing, this does not mean that their opponents

are also involved in this manipulation or even

aware. A large number of clubs in one country

can also be indicative of a small number of

local teams attempting to manipulate games

against a range of entirely innocent opponents.

The same applies to a club, where a small

number of players may be attempting to

manipulate games and their actions would not

be indicative of the whole team.

Match day and time

On 34 occasions between 2016 and 2020,

two or more suspicious friendlies were staged

on the same day. These games were mostly

staged outside of traditional matchdays. On

ﬁve separate Tuesdays and nine different

Wednesdays, two or more suspicious friendlies

were staged. On Tuesday in July 2018, four

friendlies involving clubs from just three

different countries all attracted suspicion.

Given the transnational nature of sporting

manipulation and friendlies in particular and the

role of criminal syndicates, this may indicate

attempts to deﬂect attention from individual

ﬁxtures by manipulating more than one game

on the same day.

Friendly matches are more likely to attract

greater liquidity - the amount of money that

is bet on a game - on betting markets if they

are staged on a different day and time to

regular league matches as there are fewer

ofﬁcial matches being offered to bettors as

competition. Betting on friendly matches

typically involves smaller amounts and can be

spread across multiple bets using the agent

system in Asia, which involves bets being

placed then moved anonymously up a pyramid

structure that allows for anonymity amongst

bettors and is often funnelled through poorly

or unregulated operators based in Asia. This

suits match-ﬁxers looking to disguise their

identity (see diagram). As a result, relatively

small value bets on obscure ﬁxtures are less

45 Europol, p14.

Malta Football Players Associa

tion

likely to be detected and even if they are,

the lack of regulatory betting oversight and

integrity provisions means that there is little,

if any, mechanism for many Asian operators

to formally report and address such activity

through sports’ governing, regulatory and law

enforcement channels.

Matches staged on different days of the week

to league ﬁxtures - particularly high proﬁle

European leagues – or matches in UEFA

club competitions can be more indicative

of manipulation. By staging a game when

there is less competition from more high

proﬁle matches, bettors have less choice and

are more likely to bet on these games. This

increases the liquidity and means that any

attempted manipulation is less likely to attract

attention, particularly as organised crime

groups (OCGs) tend to bet with operators in

the Asian market due to the pyramid agent

system with bets placed at one level then

passed up the pyramid. This makes identifying

bettors more difﬁcult than in Europe, where

regulated operators are required to know the

identity of their customers and to monitor and

report suspicious betting activity to the relevant

authorities.

The greatest proportion of suspicious friendly

matches are staged during January and

February, which is the mid-winter break for

many European leagues and when many clubs

go abroad for training camps.

January and February is also the start of

the pre-season period for those leagues

that run from March to Autumn, so clubs in

those leagues are involved in preparatory

matches. The research also showed that

10% of suspicious friendlies were played in

March, which typically features a FIFA agreed

international break. Some clubs choose to play

friendly matches in this period without their

international players.

The third largest percentage of suspicious

friendlies were played in July, when clubs that

play in leagues staged from August to May are

engaged in preseason training and many clubs

also go abroad on training camps.

Over the course of the study, the greatest

proportion of suspicious matches were staged

on Wednesdays followed by Fridays. Matches

played at a different time to league matches,

particularly in the European morning, which

is the late afternoon in South East Asia and a

prime time for betting in the region, will also

attract greater attention on betting markets in

Asia. Central European time is between seven

and eight hours behind Asian betting hubs,

such as Hong Kong.

Source: Asian Racing Federation

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

The study shows that 58% of all suspicious

friendlies over the period kicked off during the

early afternoon, which would be expected.

However, 17% of suspect matches kicked off

before noon in the country of origin.

While staging matches at irregular times of

day is not uncommon within training camps

to avoid hotter temperatures in countries with

warmer climate, staging games at 9:00am is

less common. This probably reﬂects the will to

attract more interest in Asian markets as there

are few if any competitive European games

underway at that time.

The largest proportion of suspicious ﬁxtures

were played in the European midwinter, when

many European leagues take a break and

clubs attend training camps. Games played in

January and February comprised 45% of all

suspicious matches, while 15% of games were

staged during July.

Overall, the number of suspicious friendlies

identiﬁed in this dataset illustrates the potential

scale of a problem that touches – although not

necessarily directly involves – clubs from 32

members of UEFA and also clubs from further

aﬁeld, including a small number from Asia and

the Middle East playing European opposition in

Europe during training camps.

Case Study - The COVID-19 Effect

As the COVID-19 outbreak spread across

Europe, league and cup matches were

suspended and at one point the only leagues

still playing regularly were in Belarus, Burundi,

Nicaragua and Tajikistan. With little competitive

football on offer, betting companies sought out

other events to offer bets on. Well-regulated

operators sought more reputable events to

offer to customers, but some poorly-regulated

or unregulated Asian-facing operators offered

whatever was available, which ranged from

soap ball to Ukrainian table tennis to – at one

Asian operator - betting on the number of

deaths from the actual virus.

Month % Total Weekday % Total

January 20 Monday 10

February 25 Tu e sday 16

March 10 Wednesday 21

April 2Thursday 12

May 4Friday 18

June 6Saturday 14

July 15 Sunday 11

August 8

September 6European Time %

October 3Morning 17

November 2Afternoon 57

December 0Late afternoon 20

Evening 6

Figure 4. Month, day

and time of suspicious

friendlies

46 h!p://www.insideworldfootball.com/2020/03/31/ukraine-ghost-games-fool-bookies-punters-data-ﬁrm-criminals-pull-oﬀ-perfect-crime

47 Sports be!ing and corruption: how to preserve the integrity of the sport (2012). IRIS, University of Salford, Cabinet PRAXES-

Avocats, CCLS, p30.

48 Games that could not be substantiated as actually having been played are not included in the dataset.

49 Translated from h!ps://www.championat.com/bets/news-4005547-bukmekery-prinimali-stavki-na-nesuschestvujuschij-futbolnyj-

match-v-rossii.html

Malta Football Players Associa

tion

During this period, the lack of regulation

over club football friendlies was exploited by

criminals across the world with suspicious

friendlies played in countries from Russia and

the Ukraine to Brazil and Vietnam. This ranged

from individual clubs arranging games, with

one Eastern European team involved in six

suspicious friendlies from the spring of 2020

to a tournament in the Ukraine, the Azov Cup,

being created and players playing in the strips

of real clubs in ﬁxtures that were covered by

data companies and subsequently sold to and

offered by Asian bookmakers. Four of these

‘fake’ games were played before the scam

was uncovered by the Ukrainian Association of

Football and the games stopped.46 This scam

was arranged to try and defraud bookmakers

who would utilise the match data being sold

to offer betting unaware that the games and

scores had already been decided by the

organisers. Lack of regulation around the

staging of friendlies helped this happen.

In Russia, a swathe of friendlies were played in

March 2020 by amateur clubs from such a low

level that their games would not normally be

offered by many licensed or even unlicensed

betting companies. Small provincial clubs

in Russia have previously been linked to the

Russian maﬁa.47 And like the fake games in

the Ukraine, these low-level Russian matches

were on betting markets due to the dearth of

alternative ﬁxtures and because live data was

available from these matches.

These games were pushed on social media via

various fan sites, including some tied to Russian

ultras, and picked up ﬁrst by domestic online

bookmakers, such as Bet600, and then by larger

companies outside Russia and even Europe,

even though there was very little information

available on some of the actual ﬁxtures, which

may well have been ghost games.48

Some bettors claimed online that games

being traded as live had actually already been

completed, culminating in leading licenced

bookmakers and Asian operators having to void

bets on a game between Zenit Moscow and

Kraskovo Moskovskaya Oblast on March 27 as

this ﬁxture did not involve the real clubs.

In a statement, Kraskovo said: “The website

of one of the bookmakers is currently

broadcasting the ‘match’ that our team is

allegedly playing now. In fact, this is a fake.

Not a single player of the FC Kraskovo team

is currently participating in any game. Why

bookmakers decided to use the name of

our team for their own purposes remains a

mystery.” 49 This is not strictly true and the

real reasons are a combination of commercial

pressures and failures in veriﬁcation procedures

at data providers and the betting operators they

sold this ‘fake’ match data to. After this game

was voided, the spate of suspicious Russian

friendlies subsided.

Notes on dataset

Matches included in this dataset were based

on risk indicators provided by the sources of

the information. More than 60 matches initially

ﬂagged up by data providers and bookmakers

as suspicious were subsequently excluded from

the dataset as irregular betting patterns could be

explained by mispriced starting odds, often due

to team news only becoming known after kick-off.

When odds were changed to reﬂect the players on

the ﬁeld, this subsequently prompted a movement

in odds on betting markets which, while atypical,

was not due to suspicious activity. Friendly

matches offered for betting frequently exclude

key information, such as the venue of the ﬁxture,

and some matches have also been excluded from

the dataset because sufﬁcient information on the

actual staging of the match was not available.

Again, this does not mean that these matches

should not be considered suspicious, but that

there is not the same level of indicators as those

games included in the dataset.

Major well-regulated betting companies all

have in-house protocols and trained personnel,

which will advise on markets to avoid. As

such, a lack of alerts from a particular country

may not be due to lack of suspicious activity,

but instead a dearth of betting markets being

offered on what are considered high risk

markets or limits on potentially suspect games,

which would restrict liquidity and deter potential

manipulation.

50 h!ps://www.theparliamentmagazine.eu/news/article/federbet-match-ﬁxing-in-europe-has-reached-epidemic-proportions

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Information in this dataset comes from a variety

of sources, including open source media, player

associations, bookmakers, betting monitoring

companies and national associations and

some sources cannot be identiﬁed, particularly

individual players involved in games. The main

sources for this dataset were:

• International Betting Integrity Association

(IBIA) is a project partner and not-for-

proﬁt association whose members include

many of the world’s largest regulated

betting operators and which operates the

largest customer account-based integrity

monitoring system in the world and covering

$137bn in bets per annum.

• STATS Perform is a leading sports data

company, whose approach to managing

match-ﬁxing risk that includes betting

market monitoring, global intelligence

gathering, and performance analysis

as a combined service. With Starlizard,

STATS Perform is the co-author of the

annual Suspicious Betting Trends in Global

Football Report.

• Starlizard Integrity Services is part of

the Starlizard sports betting consultancy

and offers Betting market analysis and

opinions on Asian Handicap and Total

Goals markets, full-time and half-time

markets, pre-match and in-play, with a

view to identifying or discounting integrity

concerns.

• Bet Genius a leading sports data company,

which provides market monitoring and

performance analysis to clients around the

world from the English Premier League to

Mexico’s Liga MX.

• Federbet was an international non-proﬁt

federation that works on behalf of betting

companies to combat match-ﬁxing and

which has presented to the European

Parliament on the dangers of sporting

manipulation.50 Federbet has been

superseded by the Sports Integrity Team.

• Pinnacle is an online sports betting

company licensed in Curacao.

• The Ukrainian Association of Football (UAF)

is responsible for the organisation and

governance of football in The Ukraine.

• The Slovak Football Association is

responsible for the organisation and

governance of football in Slovakia.

• The Pancyprian Footballers Association

represents footballers playing in Cyprus and

is both a project partner and member of

FIFPRO.

• Asianmonitor is a professional odds

monitoring and risk management tool for

bookmakers and sports organizations.

• Francesco Baranca is the head of the ethics

and fair play committee at the UAF. He was

previously head of a legal department for

some of the biggest betting companies in

Europe and general secretary of Federbet

and has been an expert witness in a

number of match-ﬁxing cases.

• Chris Kronow Rasmussen is an expert

in monitoring match ﬁxing on betting

markets. Formerly an employee at the

World Lottery Association and Danske

Spil, he lectures at New Haven University

in the USA on match ﬁxing.

51 FIFA Match Agents Regulations. Article 5.

52 FIFA Match Agents Regulations. Article 7.

53 A Friendly Business: A Critical Evaluation of the Globalisation of the Preseason Friendly. Menary Steve (CIES 2019).

Malta Football Players Associa

tion

TRAINING CAMPS

AND FRIENDLY

TOURNAMENTS

Clubs going overseas for training camps in pre-

season and during mid-winter breaks is a long-

established and perfectly legitimate practice

within the football industry. However, evidence

suggests that training camps are unregulated

at international level and only sporadically so

at domestic level. There is also no regulation

of the tour operators that organise these

training camps other than for the compulsory

involvement of a match agent, whose has been

licensed by FIFA and should oversee the match.

Only individuals can apply for licences – not

companies – even though most training camps

are run by private companies. The agent must

also enclose conﬁrmation from their national

association that they are of a “good reputation”

and that the association has no objection to

their organising matches. It is the responsibility

of the national association in question to

examine the application.51

Once this has been provided, the application

is submitted to the FIFA Player’s Status

Committee for consideration. FIFA will only

issue licences to match agents, which have

professional liability insurance with a minimum

cover of 200,000 Swiss francs to cover any

claims from parties involved with that agent.

Any agents who are unable to secure this

insurance must lodge a 100,000 Swiss Francs

as a bank guarantee with FIFA.52

Ensuring the requirement to involve a licensed

match agent is met is generally left to clubs in

many countries and is, in reality, rarely policed.

One very experienced UK match agent testiﬁed

to this project that they only had their FIFA

afﬁliation checked once in 20 years.

Understanding exactly how many friendly

matches are played within the environment of

training camps is difﬁcult due to lack of regulation

in so many territories across Europe. However, in

the busy period of January and February and the

summer months, thousands of games are played.

The main centres in the summer are Austria,

Spain and Portugal, and Turkey in the midwinter

break of January and February.

Austria

Good facilities and weather in the European

summer make Austria popular with many

clubs from across Europe. Before the outbreak

of coronavirus, in excess of 250 category

A games involving the adult senior side of

professional or semi-professional clubs were

being staged every summer in Austria. The

latter country has one of the largest football

training camp markets in Europe and the

best regulated. Austria was the most popular

preseason destination for clubs in the German

Bundesliga and Italy’s Serie A between

2013/14 and 2017/18.53 Between 2008/09

and 2019/20, Austria was also the third most

popular destination for English Premier League

(EPL) clubs in preseason behind the USA and

Germany.

Figure 5. Friendlies played in Austria

Category A club

friendlies

Year Friendlies

2016 274

2017 294

2018 287

2019 245

2020 91

Source: ÖfB

All clubs proposing to play in Austria must

which will assess ﬁxtures and deny permission

for any friendlies where crowd disturbance

between rival supporters may manifest itself. A

fee of around €150 is levied per game. This can

be higher if the application is made through a

regional association.

The ÖfB also works with police where any

suspicion of potential match manipulation

is suspected. For example, in July 2016, the

Salzburg police raided the hotel of Teuta

Durrës on suspicion that the Albanian club had

ﬁxed two friendly matches recently played in

54 h!ps://www.sn.at/sport/fussball/verdacht-auf-spielmanipulation-bei-testspielen-in-oesterreich-1278586

55 h!ps://theblacksea.eu/stories/football-leaks-2018/eric-mao-asset-stripper-european-football/

56 Interview 18/2/2019

57 h!p://www.footballimpact.com

58 Alfredo Lorenzo Mena - Director de Integridad y Seguridad, Integrity and Security Oﬀicer - FPF - August 2019

59 Rute Soares – Coordenadora, Integridade e Compliance | Integrity and Compliance - RFEF - August 2019

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Austria.54 The same year, Austrian police raided

a hotel occupied by Romanian club Academica

Clinceni, who were on a training camp in the

country and suspected of involvement in match

manipulation.55

“It’s about compliance. We are interested in

stopping match fixing so we need to know

the details but a lot of teams in camps do not

know what other teams in camps are doing.

From a compliance point of view 60 days is

fine but from a practical level it’s impossible.

The minimum is 21 days. We need that to set

up security and to contact the Ministry of the

Interior and they will decide if each friendly

can go ahead. We might object to 20 games.

It’s not about stopping the game but about

finding a different time slot or location.”

ÖfB secretary Thomas Hollerer.56

Operation of this system in Austria is partly-

funded through the ÖfB levying registration

fees on match agents and clubs, in return

for suppling ofﬁcials. Clubs are categorised

based on the league level in their home country

and the size of the fees reﬂect this, starting

at roughly €200 for smaller clubs and rising

to €5,000 for the few games each summer

that involve transnational clubs from major

European leagues. For these games, the ÖfB

also supplies a fourth ofﬁcial but there are no

rules on data rights. Some clubs will eject the

data scouts that supply information to make live

betting possible if they are identiﬁed. ÖfB rules

on friendlies are available in appendix 5.

Spain and Portugal

Spain and Portugal are also long-standing

destinations for many clubs in Europe. Large

numbers of games have been played each

summer in both countries for decades. One

leading Spanish training camp operator,

Football Impact, organises more than 260

matches every year for more than 230 clubs

from 40 different countries.57

The project team established that the permission

of the Royal Spanish Football Federation (RFEF)

is needed before any friendly can be played

in Spain, and once that permission is granted,

the RFEF (through the Referee’s Technical

Committee) appoints the ofﬁcials for the game

from the Ofﬁcials Register. 58

According to the RFEF, the organisers of the

match have to pay between €150 and €300 for

the services of the ofﬁcial to their committee,

which appoints the ofﬁcials and makes the

necessary payments. Previously, the organisers

used to give money direct to ofﬁcials. However,

this is now deemed inappropriate. The RFEF

says it never gives permission for foreign match

ofﬁcials to ofﬁciate a friendly in Spain.

When a Spanish team wants to play a friendly

abroad, they again need permission, but the

RFEF requires the ofﬁcials to be appointed

by the governing body in the country the

match is being played. The RFEF also requires

registration from visiting foreign teams.

However, the RFEF accept that in some cases

when two teams from overseas play a friendly

in Spain this can be played without notiﬁcation.

This is especially likely to be the case if an

independent agent or promoter from another

country is involved.

If a friendly match played in Spain is suspected

of any sort of manipulation, then the RFEF will

either investigate it themselves or more likely

refer the matter to the Police.

The regulation of friendlies in Portugal is very

similar to Spain in that teams are required

to get the permission of the Federação

Portuguesa de Futebol (FPF)59 in advance.

However, the processes for the appointment

(and payment) of ofﬁcials for friendly matches

is less strict. There is also an anomaly in the

match-ﬁxing legislation in Portugal in that the

current legislation only relates to matches

played within competitions and not friendlies.

When there is an allegation of match-ﬁxing

in a friendly, this omission inhibits/prevents

any form of meaningful investigation by law-

enforcement and is de facto a reduction in

the deterrent to potential ﬁxers. This situation

is compounded by the fact that the FPF has

very limited in-house capacity to investigate

allegations of match-ﬁxing in friendly matches.

A 2015 report by the International Centre for

Sports Security (ICSS) cited 15 suspicious

matches arranged by one leading Spanish

training camp operator, which put on matches

60 ICSS Investigation Report – Malaga Suspected Fixed Club Friendlies 2014

61 h!ps://www.youtube.com/watch?v=xrLn6r_w-V0

62 h!p://www.theatlanticcup.com

63 Interview, Brian Horne, 23/9/2020

Malta Football Players Associa

tion

from clubs in Europe and Africa and had

organised 575 matches in the previous four

years at just one venue in southern Spain.60

On January 1 2015, Belgian club Standard

Liège played SC Heerenveen in Marbella and

the Dutch club’s goalkeeper walked off the

ﬁeld after a series of dubious penalty decisions

leading to the game being abandoned.61 While

Dutch authorities did investigate this incident,

no action was taken by UEFA and FIFA and

the referee in this game was still ofﬁciating in

Spanish regional games prior to the outbreak

of the pandemic in 2020. The organisers remain

one of the largest training camp operators

in Spain but matches staged in their training

camps have again fallen under suspicion,

including a series of matches played by Latvian

club Ventspils in February 2019 (see intelligence

report, appendix 6).

A key weakness in the organisation of these

games in Portugal and Spain is the recruitment

of match ofﬁcials, which does not always

follow the protocols of the two governing

bodies. Match agents are ofﬁcially required by

FIFA to register friendly matches with national

associations and in Spain agents who register

with the RFEF claim that some assigned

ofﬁcials that usually take control of higher

league games can cost in the region of €3,000

per game.

Interviews for this project found that match

agents tend to operate either for a ﬂat fee or on

a percentage of the cost, both payable by the

club. Training camp ﬁxtures between low-proﬁle

clubs from smaller leagues or lower league

teams from bigger leagues in neutral countries

do not create sufﬁcient revenue stream for

match agents to justify spending this amount

on ofﬁcials. As a result, match operators,

particularly in Spain, approach regional

refereeing associations to recruit ofﬁcials, who

can cost as little as €150.

The games identiﬁed as suspicious in the 2015

ICSS report were ofﬁciated by match ofﬁcials

from the Andalucía Refereeing Committee. The

RFEF admits that clubs can easily visit Spain

without their knowledge if match operators

choose to recruit match ofﬁcials locally and

that, while some clubs may not realise they

need to register, others choose not to do so

to avoid fees or to so they can play a friendly

without detection from the authorities.

Case Study – The Atlantic Cup,

Portugal

The Atlantic Cup is an annual friendlies

tournament held mid-season in Algarve,

Portugal that has taken place every year since

2011. The 2021 event was cancelled because

of the COVID-19 pandemic but the tournament

aims to resume in 2022.62

The event is organised by Sporting Events,

which is owned by two former professional

footballers, Stefan Schwartz and Brian Horne.

European football clubs from national leagues

that have a break in the winter months are

invited to play in the Atlantic Cup, which

provides high quality preparation prior to their

domestic season resuming.

The competition is televised, which allows

fans across Europe to watch the games and

provides media exposure for the clubs and

individual players. As the Atlantic Cup takes

place at a time when there is a dearth of other

club-level league football, betting operators

across Europe are likely to offer a variety of

betting markets on all of the televised matches.

However, the tournament organisers say they

are very much mindful of the challenges this

brings and take steps to protect the integrity of

the tournament from any form of betting-related

corruption. Permission is sought from the FPF

and insurance obtained, while only high proﬁle

European clubs that are ﬁnancially stable and

have the permission of their respective FAs

to attend are invited. The FPF also appoint

all ofﬁcials for the matches and payment is

secured through levy from the tournament

organisers.

As an example of their commitment to integrity,

in the past, the tournament organisers say they

have been proactive in refusing entry to speciﬁc

clubs who they suspected had nefarious

reasons for wanting to play at the tournament.

63 One club asked to play but would only

take part if they could play on the main pitch,

which would have guaranteed their matches

would have been televised. The organisers

suspected this was because this club planned

to manipulate matches and the invite was

withdrawn. Years later, this club was censured

by UEFA for match-ﬁxing.

64 h!p://925.nl Get Rich with Dutch Amateurs Feel Like a Pro 6/1/2016

65 h!p://www.endatour.com

66 Interview with Jake Marsh, STATS Perform global head of integrity, 3/5/2019

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

These integrity steps for the Atlantic Cup are a

model on how to run a friendlies tournament/

training camp that can provide an attractive (and

fairly reliable) betting product for betting operators.

Turkey

Lower cost of accommodation, meals and

facilities make Turkey an affordable destination

for clubs with lower budgets. This country

is popular in the midwinter break and even

amateur clubs are taking midwinter breaks

to this region.64 Due to Turkey’s geographical

location, clubs from Asia and the Middle East

are also regular visitors and play teams from

UEFA in a market that is potentially the largest in

Europe. One major Turkish tour operator claims

to have organised more than 6,500 matches for

1,540 teams since the turn of the Millennium.65

However, Turkey also lacks effective regulation

to govern their sizeable friendlies market.

The matches between Latvia and Bolivia and

between Estonia and Bulgaria in February

2011 organised to defraud betting operators

were staged in Antalya. The furore over these

matches meant that no further suspicious

international matches were staged in Turkey,

but 14 friendlies incidences of suspicious club

friendlies were identiﬁed in open source media

between the start of 2012 and March 2013.

Data company Perform (now STATS Perform)

cancelled live coverage of friendly games in

Turkey in 2017 due to integrity concerns.66

A snapshot of summer and winter training

camps in the 2019/20 season for top division

clubs in the Czech Republic, Romania, Slovenia

and the Ukraine illustrates the scope of training

camp activity and the focus on Turkey. While

Austria is the most popular summer destination,

mainly for better-ﬁnanced clubs in these four

leagues, Turkey dominates in winter training

camps. All top division clubs from these four

countries go abroad in winter and the entire

Ukrainian Premier League visited Turkey in

2019/20.

This does not suggest that any of these camps

have been manipulated, but to illustrate the

extent of training camp activity by European

clubs and the amount of interaction with clubs

Summer

Country Clubs Clubs

abroad

Top destination Countries Non-

UEFA

Czech Rep 16 14 Austria (10 clubs) 15 0

Romania 14 13 Austria (5 clubs) 15 0

Slovenia 10 8 Croatia (4 clubs) 13 1

The Ukraine 12 8 Austria, Turkey (2 clubs) 21 0

Summer

Country Clubs Clubs

abroad

Top destination Countries Non-

UEFA

Czech Rep 16 16 Turkey (6 clubs) 21 1

Romania 14 14 Turkey (9 clubs) 21 3

Slovenia 10 10 Croatia/Turkey (4 clubs) 14 0

The Ukraine 12 12 Turkey (12 clubs) 25 3

Figure 6. Clubs going abroad

67 Numerous a!empts were made to engage with the TFF for this report but no responses were received.

68 MFA Integrity Oﬀicer Newsle!er No50 15/6/2016.

69 h!ps://theblacksea.eu/stories/football-leaks/cypriot-deception/

Malta Football Players Associa

tion

from Europe and further aﬁeld, particularly

in the winter break. In the 2019/20 midwinter

break, clubs from the Czech Republic,

Romania, Slovenia and Ukraine played teams

from Algeria, China, Japan, South Korea,

China and Uzbekistan. While the Turkish

Football Federation is understood to have

a process for registering friendly matches,

details remain unclear.67

Training camp manipulation

Interviews conducted for this project recorded

numerous anecdotal examples of clubs across

all levels in Europe being offered reduced or

even free training camps in other countries.

Clubs are routinely warned off taking up these

offers by national associations. However, the

latter have no power to intervene. In 2016,

the integrity ofﬁcer at the Maltese Football

Association warned:

“It has become a pre-season routine for a

couple of clubs to seek our advice before

embarking on a new joint venture with

foreign sponsors or investors. These groups

or individuals make an appearance before

the start of every new season offering quick

fix solutions to unwitting club officials.

The perplexing proposals enticing clubs to

sustainability are at times, tabled in front of

us in minimised form. We do our utmost to

understand what really drives the interest in

the project at hand. Our regulations do not

empower us to condone or condemn any

club from entering into a collaboration or

business agreement.” 68

Similar conversations with clubs are reported

by many other national associations,

particularly in Eastern Europe, such as the

Czech Republic and Slovakia. In 2016, a

match agent offered Czech club Nitra free

accommodation for 26 players and club

ofﬁcials for a 10 night stay in Cyprus.69 The

Slovak Football Federation warned Nitra not to

accept this offer, but the club went regardless

and were then involved in two suspicious

friendly matches against Polish clubs.

As many clubs are unlikely to generate a

commercial return for organisers and match

agents through sponsorship or the sale of

broadcast rights, the motivation for these deals

and discounts by camp operators or external

companies remains hard to comprehend. The

existence of many instances of alleged and

known manipulation within training camps

reinforce the concerns.

One of the ﬁrst examples of an external

company offering to cover the costs of a

training camp in return for manipulating

matches was identiﬁed in 2009, when Bosnian

club NK Travnik travelled to Switzerland for

a training camp with the €80,000 cost borne

by match ﬁxers according to a 2009 German

police investigation into the manipulation. NK

Travnik played six matches in Switzerland and

succeeded in manipulating three solely to earn

money on betting markets.

Although the perpetrators of the NK Travnik

scam were subsequently arrested and jailed,

incidences of outside sponsors funding training

camps continue. Training camps, particularly

in Turkey, but also in Cyprus and in parts of

Eastern Europe such as Slovenia, are offered

Date Opponents Stake Winnings

26/6/2009 Sion €219,000 €196,000

27/6/2009 Winterthur €104,000 €93,000

1/7/2009 Neuchatel Xamax €50,000 €28,000

Figure 7. Money made on ﬁxing friendlies involving NK Travnik in Switzerland

70 The European Club Footballing Landscape – Club Licensing Benchmarking Report Financial Year 2018 (UEFA, 2020) P115

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

to clubs at reduced cost or even no cost

according to sources interviewed for this

report. New investors also arrive at clubs and

suggest the team go to a training camp in a

new location.

Match agents typically work for clubs on a ﬂat

fee or percentage basis. With larger clubs, the

potential of selling TV rights or tickets to matches

played in training camps is more likely, as it is

sponsorship. For smaller clubs from leagues

where trading at a deﬁcit is endemic, playing

matches abroad against clubs from a third

country is unlikely to generate any signiﬁcant

amount of TV rights. Setting up to sell tickets

could also cost more than any gate receipts

would generate, but match agents still face costs

in terms of hiring match ofﬁcials and venues.

Clubs that are involved in training camp

manipulation tend to come from leagues, often

in Eastern Europe, where ﬁnancial instability is

endemic and, as noted by UEFA: “proﬁtability

remains the exception, rather than the rule.”70

In 2018, the number of leagues where clubs

reported an aggregate net loss of more than

20% rose from 11 to 13 and clubs in seven

leagues - Israel, the Czech Republic, Georgia,

North Macedonia, Latvia, Kosovo and Gibraltar

- reported net losses of more than 30%. Yet,

clubs from most of these places regularly

attend training camps abroad that can cost

€20,000 and often frequently more.

The lack of regulation of the training camp

market creates clear integrity problems that are

being exploited by match-ﬁxers. This problem

is likely to continue as ﬁnancial instability

worsens in the aftermath of coronavirus and,

in the current situation, ﬁxing within training

camps offers a ﬁnancial incentive with a low

risk of any punishment.

71 h!ps://www.iforbet.pl/zaklady-bukmacherskie

Malta Football Players Associa

tion

CASE STUDY

Raków Częstochowa vs Mariupol

(Club Friendly)

Introduction

This match was a club-level friendly played

between the Ukrainian Premier Liga side FC

Mariupol and Polish side Ekstraklasa side

Raków Częstochowa. It took place on the 16

January 2021 at the Asteria Kremlin Palace in

Belek, Turkey.

This region is regularly used as a location for

a “winter break” training camp for European

club football teams. Organisers mainly target

countries where there is a break in domestic

leagues across Europe, which was the situation

for both Raków and Mariupol.

Organisers of these winter training camps

look to offset costs and possibly make money

through sponsorship arrangements and it

can be seen from the footage still available

on YouTube that one of the sponsors of this

particular training camp was forBET, a Polish

betting company.71

Source: https://www.youtube.com/

watch?v=NQ27q4EXcio

Sports data and betting monitoring company

Genius Sports supplied data to betting

operators for this match and a number of

international betting operators offered markets

on the game. This may seem surprising given it

was low-level friendly involving two club teams

that few football fans outside of Poland and

the Ukraine would recognise, but they need

matches to offer customers, particularly in Asia,

during the European winter due to a number

of leagues in Europe that have a mid-season

break.

However, there is a more sinister side to the

predicament betting operator’s face in the

winter months. In recent years, as already

stated, there have been repeated question

marks about the integrity of matches at training

camps across Europe as they present the

ideal opportunity for ‘unscrupulous elements’

to make money from the betting markets by

ﬁxing matches, including manipulating speciﬁc

outcomes. In some cases, organised criminality

can be behind the ﬁxing, or on occasions the

‘unregulated match agents’ that specialise in

organising these training camps.

In recent years across Europe, it is more likely

to be connections of the clubs, including the

owners, directors or managers looking to keep

their clubs ﬁnancially viable. As these games

are friendlies, nothing rests on the outcome,

so it is easier for club owners or management

to persuade players or match ofﬁcials to

manipulate the ﬁxtures.

Friendly matches played by these clubs in

neutral locations are also an easy target as

they often take place ‘under the radar’ of the

national association of the host country and

their respective own associations. As regards

the level of permission the teams gained from

their respective national associations for this

particular match, the Ukrainian Association of

Football (UAF) state they were notiﬁed about

Mariupol’s attendance at this training, while

Raków did not need permission from the Polish

Football Association (PZPN).

72 h!p://www.endatour.com

73 1.62 (the decimal price) or 8/13 (the fraction price) means Raków were ‘odds-on’ clear favourites to win the match.

74 4.05 (the decimal price) or just over 3/1 (the fraction price means Mariupol were ‘odds-against’ to win the match.

75 2.02 (the decimal price) means that there was ‘even’ or 50% chance on there being 4 goals (or more) in the match which at this

stage of the game is an unusually short price.

76 1.77 (or 4/6) means that the price for there being 4 goals or more in the match is shortening (more likely to happen) – which if

diﬀicult to justify as the score was still 0-0 and less time to go in the match. The most likely explanation for this price chance is

considerable amounts of money being placed on this outcome - possibly because those placing the bets were very conﬁdent that

there would be at least 4 goals in the match.

77 The match can be viewed here: (h!ps://www.youtube.com/watch?v=NQ27q4EXcio)

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

The UAF reports that the camp was organised

by a company called ‘Enda Tours’, who

specialise in these events.72 Both teams

denied any involvement in the appointment

of match ofﬁcials. To date, it has not been

possible to conﬁrm how ofﬁcials were

allocated and whether this was done through

any of the national associations, or even

establish the identity of the referee (other

than he was possibly Turkish) for the above

match, or whether he had the correct licence/

qualiﬁcations to ofﬁciate.

It is not known whether the training camp

had the necessary permission of the Turkish

Football Federation (probably not) and multiple

attempts to contact the TFF did not produce a

response.

The early betting markets

Genius Sports and the sports data and

analytics company Stats Perform both

provided their opinion on the betting markets

for the match and, in essence, came to similar

conclusions on how the markets correlate to

the outcome of the match.

Betting markets for this match were ﬁrst

established approximately one-hour before

kick-off. A relatively small selection of known

international operators including Marathonbet

and Unibet, as well as Asian-facing operators

such as Singbet and SBObet offered the

match. Given the markets were open so close

to kick-off, all these operators intended to

offer live betting throughout the duration of the

match.

Raków were initially established as the clear

favourite, with their average opening odds set

to 1.62 (8/13).73 Meanwhile, Mariupol’s opening

odds were on 4.05 (3/1)74 on average, whilst the

draw was available at around 3.80. There was

minimal betting interest seen on these markets

and as such no reported integrity concerns

before the match started.

However, as the match progressed, some highly

suspicious betting was seen in the “Overs”,

which involves betting on the number of goals

being scored in the match. Soon after the match

started, there were a signiﬁcant volume of bets

placed on there being at least four goals scored

in the game, which drastically skewed the odds

for the remainder of the game.

By way of example, early on in the match (the

9th minute), the Asian betting operator Singbet

was offering odds of 2.02 (which is just above

‘evens’)75 on there being four or more goals

in the match, but by the time the match had

progressed to the 33rd minute, these odds had

steadily fallen to 1.77 (approximately 4/6). This

reduction in price76 (on there being four or more

goals) is completely illogical because the score

in the match had remained 0-0 throughout

this period. Consequently, you would expect

to odds to be somewhat more attractive (at

around 2.25) due to less time being available to

score four goals.

A similar anomaly occurred in the “Unders”

market (betting on there to be less than four

goals scored). Early on the match (the 9th

minute), the price on offer was 1.84. By the

33rd minute, the price had drifted out to 2.12.

Again, this is suspicious as there was still

no score in the match so you would have

expected the price to have shortened due to

the chances of there being under four goals

having considerably increased. As the match

progressed, the betting continued to be of

concern due to the support (in terms of volume

of bets placed) for there to be at least four

goals in the match.

Assessment of the match footage

When viewing footage of the match,77 it can be

seen that in the ﬁrst 30 minutes only ﬁve shots

had been registered by both teams and no

corners awarded. It was thus not a particularly

open game and, as such, no indication existed

that there would be many goals.

However, there are clear questions marks

against the performance of the referee.

Concern ﬁrst arose in the 7th minute when he

disallowed what looked to be a ‘good goal’.

78 Interview by Maciej Wasowski. 16-1-2021.

79 Email 10-4-2021

Malta Football Players Associa

tion

Then, as the game progressed, he awarded

what can only be described as ‘three dubious

penalties.’ The ﬁrst of which was even re-taken

after the player initially missed his spot kick,

scoring on the second attempt. However, it is the

last two penalties that are of real concern as they

were both awarded in the dying minutes of the

game (after the 89th minute). In addition, it is clear

from the footage that there is no obvious rules

infringement that justiﬁes either being awarded.

Comparison of the betting alongside the

match footage

The ﬁnal score of 2-2 very much correlates

with suspicious nature of the betting which

successfully predicts there would be four

goals or more in the match. However,

suspicion about the integrity of the match is

further heightened when the match footage

is considered alongside the betting. The ﬁrst

incident of concern is that the referee disallows

a goal early on. He indicates it is for a push on

an opponent by the player scoring the goal,

but this does not appear to be the case in the

footage. The likely reason for disallowing the

early goal is that the ﬁxers were yet to place all

their expected bets and not allowing the goal

helped keeping the odds attractive.

The next incident of concern is the referee

ordering a penalty to be retaken for no obvious

reason, then ﬁnally awarding two highly

dubious penalties when the match appeared

to be petering out to a 1-1 draw. In summary,

the only rational conclusion that can be

drawn from the suspicious betting alongside

the performance of the referee is that he

deliberately manipulated the game to ensure

that at least four goals were scored, meaning

the bets would be successful.

Post-match reaction

Soon after its conclusion, doubts about the

integrity of the match began to surface on

social media. After the game, the coach of

Raków, Marek Papszun, said:

“It is difficult to relate in any rational way to

what the Turkish referee was doing. I don’t

know what drove him. Perhaps it was about

some unfair practices. I hear something

similar has happened in the past in training

camps. However, for the first time in my life,

I have seen something like this with my own

eyes. At one point, we realised with the

entire training staff that we had no influence

on anything. We looked at it helplessly.” 78

Mariupol reported their concerns to the UAF

who in turn complained to FIFA, although they

then referred the matter to UEFA to deal with as

the match did not come under their remit.

Subsequently, a number of other stakeholders

raised concerns about the integrity of the

match, including the betting data (and

monitoring) companies Genius Sports, Stats

Perform and Star Lizard, which all expressed

serious reservations about the integrity of the

match grading at the very top end of their scale

which is ‘highly suspicious’. Genius Sports

and Stats Perform openly said they will be

very wary of offering games from this region to

betting operators in the future.

The PZPN also decided to change their rules

for clubs playing matches in training camps

abroad. PZPN integrity ofﬁcer Adam Gilarski

commented:

“From next season, it is necessary to

introduce information procedures for the

organisation of friendly matches during

preparatory camps especially in Turkey or

Cyprus.” 79

Options for follow-up investigation

To date, it has been difﬁcult to establish

whether any meaningful investigation has taken

place. This should have happened as together

with the highly suspicious nature of the betting

markets, the dubious decisions made by the

referee and the fact that all the suspicious

bets were successful, it appears likely that the

match was manipulated to defraud betting

operators.

This apparent lack of action means there are

a number of investigative avenues that remain

outstanding. The most obvious involve the

referee, as there is strong evidence from the

match footage to suggest that the referee

perpetrated the manipulation. However, he

cannot have been acting alone as many of the

suspicious bets were placed after the match

started. However, his identity remains unknown

to both teams and the authorities, as does the

80 Any suspicious be!ing identiﬁed by IBIA would have been passed on to UEFA at the time.

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

identity of his accomplices.

It is possible that the referee orchestrated the

ﬁx and then relied on the accomplice(s) he

recruited to place the in-running bets. However,

the more likely scenario is that the referee was

recruited by others unknown and was paid by

then to carry out the ﬁx. Who that was would

of course be the focus of any investigation with

the most obvious candidates being any one of

or combination of:

• Individuals connected to the clubs

• Connections of the training camp

organisers Enda Tours

• An organised crime group.

Source: https://www.youtube.com/

watch?v=NQ27q4EXcio

Other unresolved investigative avenues include

establishing the identity (and geographic

location) of those behind the suspicious

bets. This would involve approaching the

relevant betting operators for assistance.80

Once this is known, the investigative direction

would be searching for connections between

those placing the bets and the individuals

directly involved in the ﬁx. However, more

than 12 months after the match, it appears

that no meaningful progress has ensued.

Consequently, those responsible for the ﬁx,

including the referee, probably continue to be

involved in football. In addition, there continues

to be no deterrent to others thinking of planning

a similar enterprise. Furthermore, just as

importantly, no meaningful regulation of training

camps and the friendlies that take place within

them was implemented, nor a structured

oversite of the ofﬁcials appointed for these

matches.

The delay?

The delay in this particular investigation is

undoubtedly caused by a number of complex

issues that are also relevant to numerous

other past suspicious friendly matches at

these types of training camps. The ﬁrst major

hurdle is the ‘jurisdiction of the investigation’.

Once the match ﬁnished, the responsibility

of any investigation into any suspected

malpractice needs to be established. The

referee through his suspect action could have

committed a criminal offence in Turkey, so is

it the responsibility of the police to deal with

the matter? This option can be very quickly

dismissed through the limited perceived

importance of the match (not part of a

competition) that was between teams from

outside of Turkey and therefore not a ‘priority

crime’ for the police, which is likely to be the

case in many European countries.

Potentially, there is a case for the match to be

investigated by the police where the crime was

initially planned, which was most likely Poland

or Ukraine. However, again, neither would see

this as a priority crime, and the investigation

would also be put off by the geographical

complexities related to the fact that the main

element of the offence was committed in

Turkey, while the planning and execution most

probably elsewhere. Geographical international

barriers would also inhibit national associations

of the three countries to launch an investigation,

so this responsibility would be left to UEFA.

Enquiries by this ERASMUS project as to what

progress is being made by UEFA are on-going,

but they have conﬁrmed that they are looking

into this match.

Conclusions

Investigating the suspected manipulation of

a friendly football match, especially those

taking place at a European training camp in

neutral country is de facto going to remain the

responsibility of UEFA. The local police and

national football associations are highly unlikely

to be interested due to the already stated

reasons but questions around this match,

like many other suspicious matches of this

nature, remain unresolved mainly because of

the logistical and geographical complexities of

such an investigation.

81 Convention on the manipulation of sports competitions – The Macolin Convention (CETS n°215). Updated concept of manipulations

of the sports competitions 8/11/2018.

82 h!ps://www.coe.int/en/web/sport/typology

83 Typology of Sports Manipulations – Interactive Typology Tool (Council of Europe, June 2020), p6

Malta Football Players Associa

tion

CATEGORISATION

AND METHODOLOGY

OF FIXING A FRIENDLY

Categorisation

The Convention on the Manipulation of Sports

Competitions (the Macolin Convention).

coordinates the efforts of individual countries in

the detection, prevention and punishment of those

involved in match-ﬁxing in football, especially

where corrupt betting is involved. Article 3 of the

Macolin Convention set out the deﬁnition of the

manipulation of sports competitions and in 2018

this was updated to restrict:

“the use of the term “match-fixing”

(whether this includes fixing the entire

event, a tournament or one part of it)

purely to the on-venue action, through

which the manipulation is implemented;

the “match-fixing” is therefore a part of

the manipulation, rather than a synonym.

In this context, it links and distinguishes

the two aspects, “on” and “off” the sport

venue, and guarantees that with regard to

the Macolin Convention, they are equally

important when defining the nature of the

manipulation.” 81

In 2020, the Council of Europe and the Group of

Copenhagen, which is the network of National

Platforms designed to bring together all those

with an interest in preventing match-ﬁxing,

developed a Typology of Sports Manipulations.

The aim of this framework was to classify:

“the different types of competition

manipulation that could fall within the

definition provided by the article 3 of

the Macolin Convention. The Framework

promotes clearer communication across

the Group of Copenhagen about the types

of manipulations that National Platforms

will likely encounter. The Framework also

provides a basis upon which uniformed

statistical information can be collected to

help the Group of Copenhagen members

identify areas of risk or emerging threats.” 82

By using this tool, the ﬁxing of friendly

matches can be categorised into as a Type

1A manipulation, which is ‘direct interference

in the natural course of a sporting event or

competition instigated by exploitation of

governance’.83

As the research for this project shows, friendly

matches played by many European clubs in

many (although not all) European countries

are contested in a governance and integrity

vacuum.

The instigator of a Type 1A manipulation is

categorised as an ofﬁcial of a sports club, team

or sports organisation who holds a dominant

position. The players’ survey for this project

shows that 19% of respondents believe that the

instigators of ﬁxes were by club ofﬁcials.

The executors of Type 1A interference are

categorised as athletes, and competition

ofﬁcials. The survey research for this project

shows that 14.8% of respondents believe that

the instigators were fellow players and 9.4%

were match ofﬁcials.

According to the COE typology, pressure

applied, request made or bribe paid by the

instigator is how the attempted aim is achieved

to unfairly inﬂuence the natural course of a

sporting event or competition, or to competition

ofﬁcials to apply bad or unfair decisions during

an event or competition.

The main reason for the instigator to organise

the manipulation is to abuse betting (e.g.,

sports participants are coerced to lose an event

or competition and the instigator places bets on

the pre-determined outcome).

However, it should be noted that there is also

an element of opportunism within all ﬁxing,

and friendlies in particular, which means these

games could be categorised as Type 1C

within the COE typology. These manipulations

involve direct interference in the natural course

of a sporting event or competition, but the

instigators include person(s) outside of the

jurisdiction sports organisations (e.g., these

may be personal associates of the executor or

individuals involved in criminality). This would

also include match agents, who are having

indirect inﬂuence on the players as the executor

with the complicity of club ofﬁcials.

84 h!ps://www.gsp.ro/gsp-special/investigatie/exclusiv-singaporezul-judecat-pentru-ca-a-trucat-doua-amicale-ale-stelei-nu-poate-

justiﬁca-2-7-milioane-ﬁnul-lui-reghecampf-audiat-de-procurorii-dna-in-acest-caz-513384.html

85 Conﬁrmed by UAF Head of Ethics Francesco Baranca by What’s App, 24/3/2021.

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

The ﬁnancial reasons for an instigator for a

Type 1C manipulation are also the key drivers

for ﬁxing friendlies:

• to abuse betting (e.g., sports participants

deliberately lose an event or competition

and the instigator places bets on the pre-

determined outcome)

• to facilitate money laundering (e.g.,

organised criminal groups using

competition manipulation as a vehicle to

clean their criminal funds via the abuse of

betting)

• other illicit practices

Further research ﬁndings

Information collected during the research from

actors within or connected to match-ﬁxing

groups show they have a clear understanding

of the components necessary to successfully

secure a ﬁnancial return from the manipulation

of a friendly match, while minimising detection.

Unless matches are offered on betting markets,

particularly in Asia, where games are less

likely to attract suspicion due to a highly liquid

market, there is no prospect of ﬁxers making

any ﬁnancial return from any manipulation of

a friendly. While manipulation of competitive

league or cup matches can produce other

rewards, these are not available for friendlies.

As such, these games are mainly manipulated

for ﬁnancial gain, primarily on betting markets.

Where clubs are frequently the instigators

of any manipulated friendlies, these ﬁxtures

are routinely advertised or promoted on

social media to attract the attention of

data companies. Once clubs know that

representatives of data companies - typically

known as data scouts, who collect and transmit

match data - are inside the stadium and

transmitting data that is used to offer in-play

betting, then manipulations can be carried out.

Clubs and outside actors trying to manipulate

games also seek to ensure that matches are

streamed live on the Web. This combination

of live streamed games and live data are even

more likely to ensure that games are offered by

betting companies on Asian betting markets.

Livestreams of friendly matches, particularly

low-key games played in a neutral location

during training camps, or at a time better

suited to attracting large numbers of Asian

bettors that will increase liquidity and mask

bets from manipulators, are indicative of the

methods used by ﬁxers. This also applies to the

manipulation of games by ofﬁcials.

If no data scouts are present, the manipulations

can be cancelled. Similarly, if betting

companies are restricting stakes for bets on

games or not offering bets that ﬁxers favour,

for example the scoring of a total of 4-6 goals

in one game on Asian handicap, which is

particularly common in suspicious friendlies,

the proposed manipulations can also be

cancelled.

In the case of NK Travnik, according to police

sources, the organisers of the club planned to

ﬁx all six matches arranged during the trip to

Switzerland. However, there was insufﬁcient

evidence for the match against Servette

Geneva. In addition, ﬁxtures against Young

Boys and Schaffhausen, were not offered on

betting markets and the manipulations were

cancelled. NK Travnik matches that were

effectively ﬁxed showed declining returns

between the ﬁrst and the third ﬁxtures.

Similarly, bribes reportedly paid to referees

during a training camp in Turkey in early 2013,

also allegedly organised for match ﬁxing,

showed a decline, which suggests lower

expected returns from organisers.84

PFK Sumy, the Ukrainian club who were involved

with more suspicious friendlies between 2016

and 2020 than any other club according to the

database built up from this project, earned

$10m from ﬁxing over 30 matches. However,

these included a large number of second tier

Persha Liga matches that attracted higher levels

of liquidity (and earnings for manipulation) than

friendly games.85

Anecdotal information from the research and

investigation project suggests that bets on

friendly matches, particularly where the clubs

are the primary instigators of manipulation, are

typically producing returns of below €50,000 in

many different countries. This is partly because

these are low proﬁle matches and smaller bets

86 For example: h!ps://asianconnect88.com

Malta Football Players Associa

tion

placed through the agent system common on

Asian markets or through distributor websites

that allow bettors to spread bets across

different sportsbooks are less likely to attract

attention.86 Manipulators also understand

that betting companies do not want to cancel

games and smaller bets made across a variety

of websites will also deﬂect suspicion. This is

why friendly matches appeal to ﬁxers willing

to accept smaller returns from a succession of

games, where detection is less likely and any

censure extremely unlikely, particularly given

the multitude of jurisdictions involved in any

prosecution.

87 h!ps://www.eposm.net/kopie-van-persbericht

88 Interview with Evgheni Zubic, integrity manager at the Moldovan Football Federation, 8/4/2021.

89 h!ps://www.theguardian.com/football/blog/2013/mar/14/match-ﬁxing-player-sold

90 See: h!ps://www.reddit.com/r/SoccerBe!ing/comments/4sz01x/should_i_abstain_from_be!ing_on_the_club/

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

POSSIBLE NON-

BETTING RELATED

REASONS FOR

MANIPULATING A

FRIENDLY

In competitive matches, games can be

manipulated for a variety of non-betting related

reasons and these games make up a far

greater proportion of ﬁxed matches. A large-

scale international study coordinated by Ghent

University suggested that as few as 10% of

approaches to ﬁx a match were betting related.87

Competitive matches can be manipulated

for league placing or qualiﬁcation for UEFA

competitions, both of which will produce a

ﬁnancial reward for the clubs involved and can

result in some betting-related activity if news of

any manipulation spreads.

Friendly matches – by their very nature – offer

no such beneﬁts in terms of aiding league

position or European qualiﬁcation. The dearth

of regulation around friendly matches creates

a lack of transparency. As shown, this is being

exploited for betting reasons, which is the

primary driver for any manipulation in non-

competitive matches.

However, here too, other types of manipulation

must also be considered. These include

manipulation of matches to boost the proﬁle

of a team and a manager in preseason, or to

increase the value of players that clubs are

looking to transfer. Anecdotal reports suggest

clubs are approached to lose games by clubs

from other countries to bolster the conﬁdence

of their players before a season starts.

Typically, these games involve opponents

outside of UEFA. However, in Moldova, a club

was approached to lose a preseason friendly

by the opposition manager solely to make the

opposing team appear well prepared ahead of

the forthcoming league season.88

Using matches that have no competitive

value to boost the value of players available

for transfer cannot be discounted, as this has

already occurred in competitive matches. One

football scout operating in Eastern Europe

reported:

“I began to notice a few ‘knowing looks’

exchanged between them at every assist

and goal from the wunderkind and

eventually realised the whole game was a

set-up, a showcase for his undoubted skills to

shine unreservedly.” 89

Tor-Kristian Karlsen, football scout

This was in a league match, but the author also

notes “manipulation of various kinds seems

all too easy to achieve.” Given the unregulated

environment of friendly matches and the

number of Eastern European clubs playing in

training camps abroad, particularly during the

midwinter break, similar types of deception

cannot be ruled out in non-competitive

matches.90

Clubs can play friendly matches that do not

immediately appear to make any commercial

or footballing sense, venturing to obscure

destinations or changing long-standing

preseason arrangements. This is often related

to changes in ownership with overseas

investors wanting to take their new club to their

own country. Clubs can also play seemingly

meaningless matches to satisfy sponsors,

particularly during the worst of the COVID-19

pandemic, when clubs were playing friendlies

to comply with sponsorship agreements that

stipulate a certain number of ﬁxtures be played.

While the majority of these matches and

training camps are perfectly legitimate and are

often connected to commercial arrangements

at clubs, the rationale for some overseas

trips remains hard to understand, given the

cost of training camps and the poor ﬁnancial

condition of the clubs involved. For example,

a 2019 three-match tour in Belgium by Greek

second division club Panachaiki was led by

a former bookmaker convicted for fraud with

links to offshore entities. Many of the concerns

raised about this tour, which took place

without the knowledge of the Royal Belgian

Football Association, remain unanswered (see

91 h!ps://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52019DC0370

Malta Football Players Associa

tion

intelligence report, appendix 7).

The multi-jurisdictional commercial transactions

involved with training camps and clubs’

involvement with previously unknown outside

bodies that subsidise these trips, combined

with the lack of regulatory oversight, also

provide a clear potential for money laundering.

In 2019, the European Union cautioned about

the potential for this: “Professional football’s

complex organisation and lack of transparency

have created fertile ground for the use of illegal

resources. Questionable sums of money with

no apparent or explicable ﬁnancial return or

gain are being invested in the sport.” 91

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Sports Betting Market Overview –

Growth & Trends

The global betting markets comprise regulated

markets that are overseen by a statutory

regulatory authority and conform with licensing

parameters, and unregulated markets, which

are not overseen/no licensing parameters.

Both have grown signiﬁcantly in recent years,

driven in particular by betting on football.

The following forecasts from consultants H2

Gambling Capital categorise sector activity into

three markets:

• ‘White market’ - betting where the operator

is licensed ‘onshore’ in the same jurisdiction

as the bettor is located

• ‘Grey market’ - betting where the operator

is licensed ‘offshore’ in a different

jurisdiction

• ‘Black market’ - betting where the operator

is completely unregulated or illegal.

The forecasts provided here are based solely

on the ‘white’ onshore and ‘grey’ offshore

regulated betting markets and do not include

the unregulated ‘black’ market.

Betting is a high turnover, low margin business.

The global regulated market generated $74.1bn

of gross win in 2019 from circa $490bn in

turnover. This gross win is forecast to increase

to an estimated $105.7bn by 2025 from

circa $770bn in turnover. In 2019, this ﬁgure

represented 16% of all gambling gross win.

Gambling included betting, casino/poker,

bingo, lotteries and gaming machines. Betting

is the fastest growing gambling segment and

is forecast to grow at over double the rate of

the overall gambling industry over the next ﬁve

years.

Online betting is the fastest growing segment of

betting. It has been growing substantially faster

than land-based betting for a number of years.

In 2019, online betting accounted for 45% of all

betting gross win. In 2020, H2 calculates that

online betting will account for more gross win

than land-based for the ﬁrst time. Although this

was primarily due to the enforced closure of

retail betting shops during the pandemic, online

is forecast to remain the dominant channel

going forwards.

THE GLOBAL BETTING MARKET

Figure 8. Global Betting Turnover and Gross Win 2012-25e (US$bn)

Source: H2 Gambling Capital, May 2021

Malta Football Players Associa

tion

Football is by far the largest sport for sports betting, followed by motorsport, basketball, tennis,

and cycling. However, motorsport and cycling are signiﬁcantly skewed by the huge onshore betting

market in Japan, where betting on Kyotei (motorboat) and Keirin (cycling) account for 93% and

98% of the global market for these sports. In terms of truly global betting, football, basketball, and

tennis are the largest products.

Figure 10. Split of Global Sports Betting Gross Win % by Sport 2019 & 2025e

Source: H2 Gambling Capital, May 2021

Betting on football is expected to grow from $23.5bn in 2019 to an estimated $37.7bn in 2025,

which will represent 60% growth over this period. Tennis betting will see growth of over 50% from

2019 to 2025, reaching an estimated $3.2bn (from $2.1bn). Basketball betting through regulated

operators is, however, expected to more than double from $2.6bn in 2019 to $5.7bn in 2025e.

Figure 9. Global Betting Gross Win – Land-based vs Online 2012-25e (US$bn)

Source: H2 Gambling Capital, May 2021

92 h!ps://www.legalsportsreport.com/us-be!ing-sites/

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

Figure 11. Global Gross Win for Football, Basketball and Tennis 2016-25e (US$bn)

Source: H2 Gambling Capital, May 2021

In terms of all betting activity by region, Asia had the largest share in 2019 with almost 50% of all

betting gross win. This is predominantly driven by the large onshore betting monopolies in China,

Japan and Hong Kong. The global market share for Asia and Europe (36% in 2019) is expected

to fall, with North America nearly doubling from 6.7% in 2019 to an estimated 12% by 2025 as

the US market has opened to allow betting following the repeal in 2018 of the Professional and

Amateur Sports Protection Act of 1992 (PASPA). Around 20 US states are now offering betting

either through land-based facilities, online or both.92 Africa and South America are also expected to

increase their share of the market by 2025.

Figure 12. Total Betting Gross Win % by Continent 2019-25e

Source: H2 Gambling Capital, May 2021

For online sports betting, Europe had the largest share in 2019 with over 50%, followed by Asia

with around 30%. Both are forecast to lose market share, falling to an estimated 45% and 27%

respectively by 2025. North America is expected to more than double from around 8% in 2019 to

an estimated 19% in 2025. South America is also expected to double to 1.8%, with Africa rising to

3.4%.

In-play betting and mobile are both key drivers of online sports betting gross win and are expected

to continue to be the main growth drivers over the next few years, with mobile doubling over the

2012-25 term reaching an estimated 61.7% of all online betting by 2025e (up from 30.5% in 2012).

For sports betting (excluding racing), in-play will account for an increasing share of the regulated

market globally. It is estimated to reach 46.3% of the market by 2025 (up from 26.5% in 2012),

driven by increasing consumer demand for that product.

Malta Football Players Associa

tion

Figure 13. Global Pre-Match vs In-Play Online Sports Betting Gross Win % 2012-25e

Source: H2 Gambling Capital, May 2021

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

A study was conducted in January 2020

to collate data and examine the number of

European friendly football matches offered for

betting by IBIA’s regulated betting operator

members. The questions asked are available in

appendix 8. The following data relates to 2019

ﬁgures and covers responses from around

half of IBIA’s membership at the time that the

survey was conducted. Given the size of those

operators, this is likely to be signiﬁcantly higher

in terms of IBIA members’ total turnover on

European friendly football matches.

IBIA members represent many of the largest

regulated betting operators in the world and the

results can therefore justiﬁably be regarded as

a reliable picture of the availability of betting on

European friendly matches across the regulated

global betting market.

Up to 125,000 football matches globally were

offered each year at the time of the survey,

albeit falling to as low as 55,000 for a minority

of operators. Many operators did not split

friendly matches by continent and there were

some variations in how many friendly matches

each operator offered. This ranged from 1,650

to 7,500 matches, representing 3% to 6.5%

of all football matches offered worldwide by

those operators.

Weighting these by size of operator (and

therefore customer base/size), this suggests

an average of around 4,000-5,000 friendly

matches were offered on global football,

representing 4-5% of the total number offered

for betting. Using ﬁgures from those operators

that could provide a European/non-European

split, it is calculated that an average of 3,000-

4,000 European friendly matches per year were

offered for betting through regulated betting

operators alone.

The data to facilitate the generation of betting

markets on football friendly matches was

primarily provided by specialist companies

Sportradar, Genius Sports and STATS Perform.

In many cases, these data companies provided

100% of the data used by betting operators. A

couple of operators report using some event

organiser or website data, but, in general,

betting markets appear to have been 99%+

generated by information from a data provider.

How that data was collected (e.g., scout at

the venue and/or scraped from a website),

whether that was obtained through an ofﬁcial

agreement (or not) with the event organiser and

other reliability issues are considered in other

sections of this report, in particular in the next

one on the role of data providers.

On that latter issue and the robustness of

the data supplied, betting operators stated

that they expect the data provider to take all

reasonable measures to ensure the reliability of

the event information provided. This included

that the data be generated through scouts at

the venue providing information such as the

location, kick-off time and verifying the teams

playing.

Some betting operators also stated that they

prefer to offer friendly matches which are

available for live streaming/broadcasting. Whilst

operators generally do not offer these matches

live streamed on their website for customers,

the betting operators do watch live streamed

matches where available to ensure that the

data is correct and to verify the most relevant

information such as the scores or scoring times.

Gambling Regulator Survey

The project also explored a number of

betting and data related issues with gambling

regulatory and licensing authorities in Europe.

A survey containing three main questions was

sent to 34 regulators in European jurisdictions

in April 2021. Answers were received from

14 of those authorities. A ﬁnal ‘any additional

information’ question was also added. The

project is grateful to those authorities that

responded.

The ﬁrst question sought to ascertain if

regulatory authorities and/or the regulatory

framework in each jurisdiction placed any

restrictions on their licensed betting operators

offering betting markets on friendly football

matches. This could be in the form of

restrictions on the types of matches consumers

are allowed to bet on and/or the types of bets

allowed to be offered on those events.

ROLE OF BETTING OPERATORS &

EUROPEAN BETTING REGULATION

Malta Football Players Associa

tion

Of those 14 regulators that responded, only

the French regulatory system places any

restrictions, which prohibits betting on club

friendly matches and only permits betting on

international friendly matches involving FIFA’s

top 50 ranked national teams.

The Netherlands also introduced restrictions

under its new Remote Gaming Act from

October 2021, which prohibit licensed

operators from offering bets on friendly

matches that are not organised under

the supervision of FIFA, or by one of its

confederations or a national association. For

those friendly matches that are permitted,

licence holders must conduct a pre-event risk

analysis and refrain from offering bets where

concerns of manipulation are apparent.

While it did not respond to the survey, Sweden

has also introduced restrictions from the start

of 2021 that ban the offering of betting on

training on all friendly matches, except where

U21 national teams up to national A-teams

participate.

Apart from France, Sweden and the

Netherlands, the approach in the majority of

countries is to allow betting on friendly matches

within the prevailing regulatory and licensing

structure. It is important to highlight that, as set

out in this report, betting on friendly matches

is a common product offering and sought by

consumers, with an average of 3,000-4,000

European friendly matches offered for betting

each year through the regulated operators that

responded to this study.

The countries that permit betting on friendly

matches do not impose any integrity protocols

speciﬁc to friendly matches, albeit those

matches do fall within the scope of a range of

integrity monitoring and reporting requirements.

Such integrity provisions are increasingly

prevalent across European regulatory

framework for gambling, often reﬂecting the

measures set out in the Council of Europe

Convention on the Manipulation of Sports

Competitions.

As already stated, the availability of real-

time sporting event data is fundamental to

the generation of betting on in-play markets,

including friendly matches. The second

question was therefore focused on assessing

whether companies that sell data (e.g., on the

teams playing, location, score/scorers and

so) on European football friendly matches to

licensed betting operators are also required

to be licensed and regulated in European

jurisdictions (as in some cases gambling

software suppliers are).

None of the European regulatory authorities

having responded to this study currently require

parties supplying data to be licensed, nor have

any immediate plans to bring these companies

within the existing licensing structure. The

provision of data that facilities betting, notably

in-play markets, and the accuracy and integrity

of such data, is not therefore currently under

any statutorily established regulatory oversight.

The third question put to regulatory authorities

asked if there are any betting regulatory

or integrity restrictions on national football

leagues and clubs from selling the data on

their friendly football matches (either directly or

through a third-party data supplier) to betting

operators licensed inside and/or outside of that

jurisdiction (be they regulated or unregulated).

No regulatory authorities imposed any

restrictions here. This is understandably

seen as a matter for sporting authorities to

determine how and to whom their event data

is sold. Albeit, as this study has demonstrated,

the sale and availability of such data is of

increasing importance in the delivery of betting

markets and therefore could be argued to

be of equal importance in maintaining the

integrity of those events. That is especially

the case where such data may be being sold

to poorly or unregulated betting operators

(notably outside of Europe e.g., Curaçao and

parts of Asia) that do not adhere to integrity

monitoring and reporting or operate under an

effective regulatory framework for betting. In

that instance, the sale of sporting event data

to those operators may be seen to be adding

to the integrity risk. Full survey responses are

available in appendix 9.

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95 h!ps://www.deccanherald.com/sports/cricket/fake-sri-lankan-cricket-tournament-in-india-busted-857161.html

COMBATING MATCH FIXING IN CLUB FOOTBALL NON-COMPETITIVE MATCHES

ROLE OF DATA

PROVIDERS

The role of data providers in sports betting

is increasingly central. In particular, the

importance of the global data supply chain,

which involves sport selling event data to data

providers, data companies collating and selling

data to betting operators, and the betting

operator using this data to generate markets

for consumers. As a result, the importance of

having a reliable, accurate and transparent data

supply is critical.

Without live data coverage, betting companies

cannot offer in-play betting, which forms an

increasing amount of global betting turnover.

In 2015, one online betting company, Bet365,

revealed that 80% of all sports betting

revenue came from in-play bets alone.93

These types of bets are also particularly

popular among bookmakers focused on the

Asian betting market, where many bets on

manipulated matches are placed due to the

system of agents that allows bettors to remain

anonymous.

The IBIA survey for this project shows that

operators are heavily reliant on in-play (or live)

data from data companies in order to offer

matches and all betting companies offering

in-play betting, whether they are onshore

licensed, offshore licensed or unlicensed

(illegal), need live data to generate betting

markets. The most popular bets are on leading

European leagues. In 2019, the association

of European professional football leagues

(European Leagues) agreed an expanded data

rights deal with Genius Sports, Sportradar and

STATS Perform for data rights concerning 16

top-tier football leagues across Europe.94

Sportradar has a contract with the Deutsche

Fußball Liga (DFL) to monitor European club

football friendlies involving sides from the

top two national leagues. Genius Sports also

monitors the same Bundesliga clubs in a

separate deal with the Deutscher Fußball-Bund

(DfB) as part of a contract for league matches,

but this is rare. One data company interviewed

for this project said: “Not many sports would

ask for friendlies to be monitored.” Contracts

for national leagues rarely include non-

competitive matches as these can be from

different countries and monitoring is often

only practical when clubs play in friendly

tournaments. Even then, this is not common,

certainly at lower level clubs.

The incidents of ghost games in 2014 and

2015 (see p6) would not have occurred without

the complicity of data scouts, who are often

students and the level of wage may, like poorly

paid sportspeople, leave them vulnerable to

advances from corrupters. Subsequently, data

providers tightened their risk management

procedures to avoid a repeat.

The outbreak of the COVID-19 pandemic in

2020 again highlighted weaknesses in the data

management supply chain, with friendly games

arranged simply to defraud betting companies

(see case study p21-22). This was not restricted

solely to football and incidents of fake games

created for the same purpose emerged in

cricket.95

Survey of national football associations

on data company regulation

Commercial agreements for data rights in

club football friendlies are rare. So, as part of

this project in the survey of national football

associations (see p8-9), a supplementary

question was asked about the registration

and regulation of data companies and their

representatives (aka data scouts) at friendly

matches to all 55 members of UEFA. Of those

21 national associations that responded, 75%

said that data scouts were not required to

In Austria, the ÖfB reports that some clubs

will eject data scouts if they are discovered

at training matches in order to stop games

before they can be offered on betting markets.

Many associations had not even considered

this aspect of the organisation of friendly

matches and their typical response was that

responsibility for checking the credentials of

data scouts lay mainly with the clubs.

96 One respondent said they did not oﬀer youth or reserve friendly matches.

Malta Football Players Associa

tion

Comments from federations who did not

require registration included:

• “Data scouts are coming to more games

including friendlies, even U16 and

U15 games. We ask them to identify

themselves and if they don’t, they have to

leave” (Belgium)

• “By the time that the friendly game is

open and not behind close gates, we are

not required to register any data scouts.

It’s not controllable.” (Cyprus)

Comments from the 25% of respondents that

did require some form of registration by data

scouts included:

• “The policy of NFF is that for every

match organized by NFF or our member

clubs, only persons representing media

houses or who hold official press-IDs are

given entrance with the right to report

from a match. Unless the data scouts fulfil

these requirements, they will not be given

the right to report and will have to buy a

ticket and attend the match as ‘normal’

spectators.” (Norway)

• “The club that organises the match is

recommended to require accreditation

from the data scouts who wants to report

from non-official ‘friendly’ matches.”

(Sweden).

Data provider survey

To better understand the links between data

companies and their clients in the betting

market over non-competitive matches in

Europe, a range of data providers were

sent a questionnaire in 2020 comprised of

10 questions (see appendix 10). By prior

agreement and to protect commercial

conﬁdentiality, responses were treated

conﬁdentially.

The number of friendly matches in Europe that

are covered by data companies rang