ResearchPDF Available

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

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
‘Kelong Kings: Confessions of the World’s Most Prolific Match-Fixer’ (2014), Perumal, Wilson Raj
Malta Football Players Associa
“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
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
Appendices, methodology and needs analysis
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2 h!ps://
3 h!p://
4 UEFA Club Licensing Benchmarking Report (2020), p115.
Malta Football Players Associa
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
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://
9 h!p:// The Standard Liege vs
Heerenvereen game can be viewed here: h!ps://
10 This ICSS report into this investigation was not made public but this project has a copy.
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://
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://
14 h!p://
15 Federbet Annual Fixed Matches Report (2016)
16 h!p://
17 ‘The Romanian Network – the Story of Dubious Friendly Matches’ Futbolgrad 27 January 2017.
18 h!p://
Malta Football Players Associa
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 Aairs, March 2012 h!p://
23 Model Criminal Law Provisions for the Prosecution of Competition Manipulation (2013, UNODC/IOC)
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
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.
24 United Nations Convention against Transnational Organized Crime parties,
Malta Football Players Associa
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
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
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
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
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
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
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 ocials 19.0%
Players 14.8%
Match Ocial 9.4%
Organiser/agent 8.3%
Someone else 12.0%
Don’t know 17.7%
Never confronted with
the issue
26 h!ps://
27 h!ps://
28 ‘Oefendual tussen de verhuisdozen’ Dagblad De Limburger 13/7/2017.
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
Where were players approached to fix a
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
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://
30 As multiple answers were possible, the totals do not add up to 100%.
Malta Football Players Associa
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
Friendly Ocial
Club ocials 19.0% 25.5%
Players 14.8% 19.2%
Match Ocial 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
Friendly Ocial
Club ocials 26.3% 27.2%
Players 15% 18.2%
Match Ocial 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 Ocial 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
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://
Players playing in a game they knew was
Friendly Ocial
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 Ocial
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
ocial match
Friendly Ocial
Greece 23.3% 45.5%
Cyprus 16.4% 11.2%
Malta 9.6% 23.9%
Total 16.5% 19.6%
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://
Malta Football Players Associa
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-
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
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
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
Participating will aid criminal organisations
Participating will directly harm the sport that
billions of people love
34 h!ps://
35 h!ps://
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://
38 h!ps://
39 h!ps://!on-app-eective-while-protecting-players-anonymity-says-pasp-president/
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
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
Figure 2. Suspicious friendlies by country
5.%/' 1
40 h!ps://
41 h!ps://
42 h!ps://
Malta Football Players Associa
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
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
Country TOTAL
Cyprus 23
Turkey 13
Spain 5
Netherlands 5
Bulgaria 4
Croatia 4
Austria 4
Slovenia 2
Slovenia 1
Poland 1
43 h!ps://
44 Situation report: The involvement of organised crime groups in sports corruption. Europol (2020), p16.
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).
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
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
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
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
46 h!p://
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://
Malta Football Players Associa
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
50 h!ps://
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
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
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
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.
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
Figure 5. Friendlies played in Austria
Category A club
Year Friendlies
2016 274
2017 294
2018 287
2019 245
2020 91
Source: ÖfB
All clubs proposing to play in Austria must
register with the Österreichischer Fußball-Bund,
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://
55 h!ps://
56 Interview 18/2/2019
57 h!p://
58 Alfredo Lorenzo Mena - Director de Integridad y Seguridad, Integrity and Security Oicer - FPF - August 2019
59 Rute Soares – Coordenadora, Integridade e Compliance | Integrity and Compliance - RFEF - August 2019
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
“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://
62 h!p://
63 Interview, Brian Horne, 23/9/2020
Malta Football Players Associa
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,
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
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:// Get Rich with Dutch Amateurs Feel Like a Pro 6/1/2016
65 h!p://
66 Interview with Jake Marsh, STATS Perform global head of integrity, 3/5/2019
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.
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
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
Country Clubs Clubs
Top destination Countries Non-
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
Country Clubs Clubs
Top destination Countries Non-
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 Oicer Newsle!er No50 15/6/2016.
69 h!ps://
Malta Football Players Associa
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
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://
Malta Football Players Associa
Raków Częstochowa vs Mariupol
(Club Friendly)
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
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
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://
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
diicult 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://
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
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
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
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
“From next season, it is necessary to
introduce information procedures for the
organisation of friendly matches during
preparatory camps especially in Turkey or
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
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.
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.
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
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.
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://
83 Typology of Sports Manipulations – Interactive Typology Tool (Council of Europe, June 2020), p6
Malta Football Players Associa
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
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
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
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://
85 Confirmed by UAF Head of Ethics Francesco Baranca by What’s App, 24/3/2021.
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
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
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://
Malta Football Players Associa
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
87 h!ps://
88 Interview with Evgheni Zubic, integrity manager at the Moldovan Football Federation, 8/4/2021.
89 h!ps://
90 See: h!ps://!ing/comments/4sz01x/should_i_abstain_from_be!ing_on_the_club/
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
“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
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://
Malta Football Players Associa
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
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
‘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 $770bn in turnover. In 2019, this figure
represented 16% of all gambling gross win.
Gambling included betting, casino/poker,
bingo, lotteries and gaming machines. Betting
is the fastest growing gambling segment and
is forecast to grow at over double the rate of
the overall gambling industry over the next five
Online betting is the fastest growing segment of
betting. It has been growing substantially faster
than land-based betting for a number of years.
In 2019, online betting accounted for 45% of all
betting gross win. In 2020, H2 calculates that
online betting will account for more gross win
than land-based for the first time. Although this
was primarily due to the enforced closure of
retail betting shops during the pandemic, online
is forecast to remain the dominant channel
going forwards.
Figure 8. Global Betting Turnover and Gross Win 2012-25e (US$bn)
Source: H2 Gambling Capital, May 2021
Malta Football Players Associa
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://!ing-sites/
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
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
Figure 13. Global Pre-Match vs In-Play Online Sports Betting Gross Win % 2012-25e
Source: H2 Gambling Capital, May 2021
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
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
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.
Malta Football Players Associa
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
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
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.
93 h!ps://!!ing-revenue-comes-from-live-in-play-be!ing
94 h!ps://
95 h!ps://
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
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
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
register attendance with the host club.
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 oer youth or reserve friendly matches.
Malta Football Players Associa
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.
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
The number of friendly matches in Europe that
are covered by data companies ranges from
2,000 games (5% of European coverage) to
3,000 games (6.8% of European coverage)
and up to 6,000 games (14% of European
coverage). One data company noted that
“a lot of friendlies come out of existing
data agreements” and another agreed that
commercial rights can be agreed for some
friendly matches, but added: “Typically,
friendlies do not have rights attached to them
since they often bring together teams outside
of rights holder owned competitions.”
The survey sought to understand what the
minimum levels of information that providers
generally seek to establish before offering
coverage of a friendly match. Across all
responses, minimum information included:
The date of the match and the kick-off time
The teams who are involved in the match
The level of the squads playing in the
match, i.e., are the team’s a first XI, youth,
reserves, or women’s team96
Data companies said they take information
for live coverage of friendlies from one or
more of the following:
their representatives at events (aka scouts)
club websites
other internet sources e.g., broadcast of the
match on Facebook
match agents and club officials
All respondents preferred a scout at the
actual ground to comply with their own risk
management processes, but this is not always
the case and games can be offered using other
Scouts are background checked prior to
employment and their performance monitored
using Key Performance Indicators. Typically,
date, KO time and venue must be corroborated
by multiple sources and GPS is collected from
the device of the data scout to ensure each
data collector is at the correct venue. Data
scouts also asked to confirm their attendance
with pre-match photos. This is to prevent any
potential corruption and data being streamed
from games that do not exist. An audio stream
is requested and at least one data company
used a mystery scouting system, where another
member of staff attends games unannounced
to check on scouts.
Data companies report that not all friendly
matches are played over a 90-minute period,
or even 45 minutes each way and can involve
unlimited substitutes. One data company
reported: “Just getting the information can be