If your offices, like ours, are currently filled with colorful jerseys and employees furtively checking scores on their phones, you know that soccer (or football or futball) has the attention of much of the world right now.
The World Cup offers a unique training opportunity for in-house compliance officers and Ken Bensinger’s new book, Red Card: How the U.S. Blew the Whistle on the World’s Biggest Sports Scandal, provides a ready-made training module.
Red Card is about FIFA — the best known, but far from only, example of shoddy governance in the “non profit” international sports world — but it is also a case study about all that can go wrong in an organization awash with cash but hostile to reform.
In a recent podcast interview about his book, Ken and I do a sort of criminal call and response. I name a type of financial misconduct, and Ken provides examples of how FIFA engaged in that misconduct — lively and colorful examples of conflicts of interest, self-dealing, fraud, money laundering and, of course, rampant and sustained bribery. The book also covers more esoteric topics, including MLATs, SARs and extradition. From a compliance perspective, Red Card really does have it all.
Our little game of “violation bingo” can easily be adapted by in-house experts and used as an engaging training module based on each industry’s industry and risk profile. Sports examples floated by the participants can then be used to prompt discussions about safeguards that might have prevented or uncovered the misconduct. These sorts of violations are familiar to all compliance professionals, but setting them in a familiar context can help to make them fresh and engaging for everyone involved in the training.
If you’re looking for additional resources to spur conversation, there’s a great post on the FCPA Blog by Jessica Tillipman explaining why Chuck Blazer (the FIFA executive at the heart of the story) definitely should not be considered a whistleblower.
You can also listen to this podcast by Richard Conway of BBC Sports about the scope of doping in sports, which reached a peak during the Sochi Winter Olympics, and the role of a key whistleblower –now in witness protection — in uncovering the misconduct.
And in this book and podcast, you can hear Declan Hill describe the menace of match-fixing and provide an analysis of the organized crime behind the bribery and extortion that threaten to turn sport into mere theater.
Looking to the future, a post on the FCPA Blog earlier this month by Andy Spalding describes the work done by the International Olympic Committee to ensure more transparency within host countries and encourages FIFA to follow the IOC model.
The role that compliance now plays in any discussion about the integrity of sports gives partial confirmation to the theory set forth by Dick Cassin in his fun and only slightly hyperbolic FCPA Blog post earlier this week.
From FIFA’s World Cup and the Olympic Games down to college basketball, sport is threatened by financial crime, conflicts of interest and predatory practices at all levels. For those who work in compliance and enjoy the thrill of competitive sports, weaving the two together in a lively, compelling and memorable training experience can advance the interests of both communities.
Alexandra Wrage is president and founder of TRACE. She is the author of Bribery and Extortion: Undermining Business, Governments and Security, co-editor of How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes, and the host of the financial crime podcast Bribe, Swindle or Steal. She’s a former member of FIFA’s failed Independent Governance Committee. She travels to each Winter Olympics to cheer for the Canadian men’s and women’s hockey teams; she is still not ready to talk about what happened in PyeongChang! For other excellent soccer stories to read during this World Cup season, she recommends Masters of Modern Soccer by Grant Wahl and The Away Game, about Qatar’s global search for soccer talent, by Sebastian Abbot [podcast].
Chuck Blazer was a government informant. However, for those who know the entire story, prior to becoming a government informant, Blazer blew the whistle on the scheme to buy votes in the race for the Presidency of FIFA. Mohammed bin Hammam passed out envelopes filled with cash to officials of Concacaf in order to buy their support. Blazer was the person who blew the whistle of this activity and this act brought him in direct conflict with Jack Warner– the former President of Concacaf. We may never know why Blazer did this. However, it put him in jeopardy because Warner knew of Blazer's misconduct and in fact was part of the same conspiracy to defraud Concacaf.
Whatever Blazer's, reason, bin Hammam's acts of bribery played a large role in the eventual disrobing of FIFA.
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