Compliance
Continuous development of FIFA Compliance 3.0
In September 2021, the Compliance Subdivision commenced the transition to an integrated compliance portal consisting of five modules. These are due diligence, investigation and whistleblowing, conflicts of interest, gifts and hospitality and policy and training. The system will manage FIFA’s compliance programme in a more efficient way and further automate and streamline FIFA’s internal compliance and business processes.
The first module to be implemented focuses on due diligence, with the aim of better controlling and managing third-party risk across FIFA and its subsidiaries. The other modules are scheduled to be implemented in the course of 2022 to further deliver on FIFA’s mission to leverage compliance technology for the benefit of football.
Testing and monitoring
Testing and monitoring are integral parts of FIFA’s compliance programme. To reinforce the second line of defence, the Compliance Subdivision continued to perform a significant amount of testing to assess the design and effectiveness of the programme. All findings were appropriately addressed and risk-based measures were implemented.
Training
The Compliance Subdivision continued its efforts to regularly train all FIFA team members on compliance matters. In light of the COVID-19 pandemic, training had to be conducted digitally. A new training plan and strategy was developed and is being implemented to help cement awareness among staff members as to their roles and responsibilities as both employees and representatives of FIFA. In addition, refresher and targeted training sessions continue to be delivered, as well as ensuring that all new FIFA joiners are educated on compliance matters as part of the official induction process.
Q22 compliance programme
Through a dedicated, locally appointed compliance officer, the Q22 joint venture continues to focus its efforts on mirroring FIFA’s compliance programme while adapting to the specific needs of the local market. The pillars of the programme include the establishment of policies, face-to-face training and the creation of a whistleblowing channel.
Preventive compliance support mission
In addition to putting the FIFA Compliance Handbook at the disposal of all 211 member associations, the Compliance Subdivision is also actively supporting each member association by implementing corresponding compliance programmes locally.
In 2021, the Compliance Subdivision visited member associations and supported many more remotely in implementing appropriate measures to fight fraud and corruption in football. A detailed three-year strategic action plan to implement the compliance programme was drawn up in a strong collaborative effort. The support offered by FIFA included staff training, introducing local compliance officers to FIFA’s compliance programme and the professional development of member association employees in relation to relevant topics in the field.
“The support offered by FIFA included staff training, introducing local compliance officers to FIFA’s compliance programme and the professional development of member association employees in relation to relevant topics in the field.”
Audits of use of development funding
The Compliance Subdivision continues to manage the forensic reviews of member associations, coordinating the approach with the Member Associations Division as well as with the secretariat to the Ethics Committee. It actively helps to follow up on findings and supports the implementation of mitigation measures at member association level in coordination with the Member Associations Financial Governance & Oversight Services Department.
FIFA World Cup Legacy Fund
The Compliance Subdivision continued its efforts to advise FIFA teams and was also in direct contact with the compliance officers supporting compliance initiatives and the development of a compliance framework at local level. The contract of agreed objectives for the 2018 FIFA World Cup Legacy Fund has been signed with the Football Union of Russia (FUR), including the requirement for the implementation of a robust compliance programme. In order to fulfil initial criteria, the FUR has engaged a qualified compliance specialist responsible for overseeing the management of compliance and reputational risks.
Data protection awareness campaign and FIFA DPO Network event
The FIFA DPO Network event took place on 14 October 2021, with 64 external participants. During the event, a FIFA data protection awareness video was shared with representatives of the member associations and data protection officers (DPOs) from leagues and clubs. The event covered two main topics:
Stadiums and technology
International data transfers
Implementation of FIFA’s consent management tool
The implementation of a consent management module was an important milestone, allowing FIFA to comply with the consent management requirements under the General Data Protection Regulation. The tool allows FIFA to document consent given by individuals, enabling access rights to be handled automatically for holders of a FIFA.com account.