The Pre-Game Is the Whole Game

Mega sporting events like the 2026 FIFA World Cup and 2028 Los Angeles Olympic Games rank among the world's premiere commercial and cultural stages – offering entertainment, national pride, and business opportunities for companies, host countries, and participants. But their scale, global visibility, and prestige can present legal risks when those events are not carefully managed. The significant commercial activity that these events generate often involve government stakeholders, international sporting organizations, extensive third-party networks, and high-profile hospitality opportunities – creating heightened exposure to bribery, fraud, money laundering, and other forms of corruption. This alert, the first of a broader series examining the legal and compliance risks associated with major sporting events, focuses on anti-corruption risk and the impacts of US Department of Justice's (DOJ) evolving enforcement priorities.

Where Business, Government, and Sport Collide: Fraud and Corruption Risks at Major Sporting Events

Corruption risk in major sporting events can surface across both public and private sector contexts — implicating everyone from government officials overseeing host bids to private sports organizations controlling commercial and media rights.[1]

The corruption risk is not just a Foreign Corrupt Practices Act (FCPA) issue. Companies frequently interact with government officials responsible for permits, customs clearances, venue approvals, immigration matters, security coordination, and other regulatory functions. Depending on the circumstances, benefits provided to such officials may implicate the FCPA, the Foreign Extortion Prevention Act (FEPA), domestic bribery laws, and related anti-corruption statutes. Companies also interact with officials of sporting organizations, including FIFA, the International Olympic Committee (IOC), national federations, and other private governing bodies. Because these individuals are not 'foreign officials' solely by virtue of their positions under the FCPA, payments or benefits provided to them may create exposure under commercial bribery laws, honest services fraud, wire fraud, money laundering statutes, and analogous foreign anti-corruption laws rather than the FCPA.

Hospitality presents a particularly acute risk in the sporting-event context. Although the current DOJ administration has indicated[2] that it does not intend to focus enforcement resources on routine and bona fide business expenditures, hospitality associated with major sporting events may warrant heightened scrutiny. Premium tickets, opening ceremonies, championship matches, hospitality suites, and other VIP experiences often carry substantial monetary and intangible value that extends well beyond a typical business meal or customary hospitality expenditure. The more exclusive or difficult-to-obtain the experience, the harder it may be to characterize as routine hospitality.

Other aspects of these major events also create conditions ripe for fraud and corruption, such as:

• High-value commercial rights and licensing opportunities that can incentivize improper payments.
• Extensive government interaction involving officials with significant discretionary authority.
• Opportunities for organized criminal groups to exploit governance gaps and cross-border coordination challenges.[3]
• Compressed timelines that pressure payment for expediting processes.
• Substantial hospitality and promotional spending involving government officials and decision-makers at sporting organizations.

Few commercial environments combine such risk factors in a single setting. As a result, companies may face exposure across a broad range of legal regimes involving both public sector and private sector decision-makers. Against that backdrop, companies should view DOJ's evolving enforcement priorities as a call to get ahead of the whistle and stress-test their compliance programs now – before the high-profile enforcement game is underway.

Same Game, New Priorities: What Has (and Has Not) Changed in US Enforcement

Recent DOJ guidance[4] has not diminished these risks; rather, it signals a shift in enforcement priorities.

The DOJ's most recent white collar and FCPA guidance now emphasize promoting American interests and aligning enforcement with foreign policy priorities with heightened attention to corruption matters involving cartels, transnational criminal organizations, designated foreign terrorist organizations (FTOs), money laundering, sanctions evasion, or broader national security concerns.[5] Even a corrupt payment to a foreign official who has, wholly separately, accepted a bribe payment from a cartel, is sufficient nexus to trigger scrutiny under the new guidance.

The guidance also specifically references the Foreign Extortion Prevention Act (FEPA), which criminalizes the demand side of foreign bribery.[6] Major sporting events can create scenarios in which foreign officials may solicit or demand improper payments in exchange for permits, customs clearances, venue approvals, security coordination, immigration-related approvals, or other governmental action. Such conduct may implicate FEPA.

The designation of certain cartels as FTOs further raises the stakes. Companies may face exposure under 18 U.S.C. § 2339B if payments, directly or indirectly, provide material support to a designated organization. DOJ's prosecution of Lafarge[7] for making benefits to terrorist groups to protect its operations in Syria demonstrates that payments made to preserve business operations can create significant liability where the company knows or should know that criminal or terrorist groups are benefiting. Companies supporting major sporting events may encounter heightened risk when operating through intermediaries or business partners in jurisdictions where cartels, organized criminal groups, or designated FTOs exert influence over commercial activity.

Notably, DOJ's more recent guidance focused on corporate enforcement continues to emphasize that voluntary self-disclosure, full cooperation, and timely remediation remain central considerations in corporate charging decisions. Companies satisfying these requirements may be eligible for a declination absent aggravating circumstances, highlighting the continued value of effective compliance programs and rapid internal response processes.[8]

Importantly, DOJ's enforcement authority has not changed. Prosecutors retain the same statutory tools available before these policy shifts; what has changed is the type of matters most likely to receive investigative resources and charging approval.

The Expanded Landscape of Corruption Exposure

With the 2026 World Cup concluding and the 2028 Olympics on the horizon, companies involved in major sporting events should not view current enforcement signals as a basis for deprioritizing compliance. Enforcement risk has evolved—not receded.

While compliance personnel appropriately focus on matters involving government officials, engagement with business counterparties may create DOJ scrutiny as well. Courts have upheld a theory of honest services fraud related to prosecutions of commercial bribery connected to sporting events where a qualifying fiduciary duty exists and the scheme has a sufficient US connection.

Conduct once viewed primarily through an anti-corruption lens may also trigger exposure under anti-money laundering, sanctions, national security, and material support statutes. This shift is particularly significant where organized criminal groups may influence regular commercial activity. In such environments, inadequate third-party diligence may create exposure extending well beyond traditional bribery concerns. Moreover, enforcement priorities can change significantly between administrations, with statutes of limitation enabling prosecutors to scrutinize conduct years after it occurs, meaning conduct occurring today may be evaluated under a substantially different enforcement landscape tomorrow.

Criminal Exposure

• FCPA anti-bribery provisions remain fully enforceable. The five-year statute of limitations means current conduct may create exposure under future administrations and the statute of limitations runs from the last act undertaken in furtherance of the conduct.
• Honest services and wire fraud prosecution theories remain viable. Second Circuit precedent and related case law applying these statutes to foreign commercial bribery remain controlling or persuasive authority and continue to constitute good law.
• FTO designations materially alter the risk calculus when operating in jurisdictions where cartels operate throughout the regular economy. Potential liability under the Anti-Terrorism Act and 18 U.S.C. § 2339B for the provision of material support to FTOs significantly heightens exposure.

Regulatory Exposure

• Books and records and internal controls violations can create exposure even without proof of an actual bribe. The SEC's BHP Billiton settlement arising from hospitality in connection with the 2008 Beijing Olympics illustrates that even legitimate and accurately recorded event-related expenditures may create exposure where controls governing selection, approvals, documentation, and monitoring are inadequate.[9]
• Foreign regulators continue to expand cross-border cooperation and information sharing, increasing parallel enforcement risk. DOJ has also indicated a preference in some cases to defer to foreign authorities where conduct does not significantly impact US interests, making multijurisdictional investigations increasingly likely.[10]

Civil Exposure

• State attorneys general remain active. Statutes such as New York's Martin Act and California's Unfair Competition Law enable enforcement without reliance on federal authorities.
• Derivative and civil litigation pose growing risk. Civil RICO claims and other private litigation—from shareholders, lenders, insurers, and counterparties—are increasingly used to pursue corruption-adjacent theories, including in the sports and media rights context.

The 2028 Playbook: Compliance Considerations for What's Ahead

Compliance risks associated with major sporting events vary significantly depending on a company's role. Looking ahead to the 2028 Los Angeles Olympics and beyond, companies involved should consider whether their compliance programs adequately address their corruption risk based on their perceived level of exposure. Further, they should also tailor their risk assessments and controls to the specific activities they undertake, rather than relying on a one-size-fits-all compliance approach.

• Media Rights Holders, Broadcasters, and Licensing Participants: Companies involved in acquiring, selling, or negotiating media, sponsorship, marketing, or licensing rights face heightened risks during bid processes and rights negotiations, often relying on consultants, agents, or other intermediaries to interface with sporting organizations and rights holders, which can increase commercial bribery, fraud, and third-party exposure. Compliance programs should include enhanced diligence on intermediaries, oversight of success fee arrangements, documented negotiations, and controls around interactions with decision-makers responsible for awarding valuable commercial rights.
• Sponsors and Hospitality Providers: Official sponsors and hospitality providers face considerable exposure arising from ticket allocation, VIP access, event-related travel, and entertainment. Risks are heightened where guests include government officials, employees of state-owned enterprises, or individuals involved in pending regulatory, procurement, or commercial decisions. Companies should establish clear approval processes, document legitimate business purposes, monitor allocation of premium tickets and hospitality packages, and apply heightened review to invitations extended to government-affiliated personnel.
• Corporate Guests, Customers, and Event Attendees: Companies using major sporting events to entertain customers, prospective clients, or business partners should carefully evaluate gifts, travel, lodging, premium event access, and other hospitality benefits. While event-related hospitality is not inherently improper, exclusive tickets, hospitality suites, opening ceremonies, and other high-demand experiences may present elevated risk because of their value and scarcity. Companies should ensure that such benefits remain proportionate, are supported by legitimate business purposes, and comply with applicable anti-corruption, ethics, and local law requirements.

Across all categories, companies should conduct event-specific risk assessments, strengthen third-party oversight, review hospitality controls, enhance financial controls, and ensure that reporting and investigations protocols are capable of identifying and escalating potential issues promptly.

• Conduct an event-specific risk assessment: Identify government touchpoints, state-owned entities, and organizing bodies and assess whether existing controls adequately address those risks. Consider using AI-enhanced solutions to work alongside legal and compliance personnel to map business activities, government touchpoints, and high-risk jurisdictions to flag higher-risk transactions faster.
• Integrate anti-corruption, sanctions, AML, and third-party diligence processes: Avoid siloed compliance workstreams and evaluate whether their event-related due diligence processes adequately identify beneficial ownership, sanctions exposure, politically exposed persons, cartel affiliations, and other indicators of heightened corruption or national security risk.
• Review gifts, entertainment, travel, and hospitality controls: Assess existing controls for gaps and ensure clear methods to evaluate, review, approve, and document gifts and hospitality for both government officials and commercial recipients.
• Strengthen third-party management and oversight: Conduct enhanced vetting of agents, consultants, and local partners and look for red flags in beneficial ownership structures; consider leveraging AI-assisted diligence to accelerate beneficial ownership reviews against PEP/sanctions databases. Scrutinize intermediaries involved in licensing, permits, or access and monitor for links to politically exposed persons, cartels, or sanctioned groups. Incorporate contractual safeguards with robust anti-corruption representations, audit rights, and termination clauses, and FCPA / local law compliance certifications.
• Enhance financial controls: Monitor event-related spending, flag unusual payment structures, and verify the accuracy of books and records supporting hospitality and promotional expenses. Continuous transaction monitoring can help to detect outlier payment structures and anomalous spending patterns. Conduct a post-event audit of high-risk expenditures and third-party engagements.
• Deliver targeted training: Provide scenario-based training to commercial and marketing teams and reinforce expectations before major events.
• Evaluate investigations capabilities and self-disclosure readiness: With DOJ's renewed emphasis on voluntary self-disclosure, cooperation, and remediation as factors in charging decisions and potential declinations,[11] ensure that reporting channels, investigations protocols and escalation procedures facilitate prompt internal reviews to preserve the option of timely self-disclosure, if the matter rises to that level.
• Review incident response and crisis management plans: Confirm that a plan is in place and appropriately tailored to the Company's structure and operations. Ensure that the plan, roles, and actions have been appropriately socialized with key stakeholders. Consider conducting tabletop exercises involving hospitality, third-party, and government-interaction scenarios to test the efficacy of the plan and response.

For companies operating on the world's largest commercial stages, compliance is worth the cost of admission – getting it wrong can cost far more. DOJ's enforcement priorities may change, but the fundamental compliance imperative has not: corruption-related misconduct may now trigger exposure under a broader field of legal frameworks than ever before. In this environment, proactive compliance, robust third-party diligence, and effective controls before the game starts is still the best defense.

Key Takeaways

• Major sporting events create heightened exposure across both public and private sector corruption frameworks. High-value hospitality, sponsorships, media rights, licensing opportunities, procurement activities, and extensive government interaction can create risks under the FCPA, domestic bribery laws, commercial bribery statutes, honest services fraud, wire fraud, money laundering laws, and related enforcement regimes. Recent DOJ guidance also specifically flags a focus on FEPA which reaches the demand side of foreign bribery.
• DOJ's stated enforcement priorities have shifted, but its enforcement authority has not. Corruption matters involving cartels, transnational criminal organizations, designated FTOs, money laundering, national security concerns, or harm to US interests are likely to draw increased scrutiny. The substantial commercial activity generated by major sporting events—often involving layered ownership structures, third-party intermediaries, and opaque commercial arrangements—can increase the risk that companies unknowingly engage with actors connected to organized crime, creating exposure that extends well beyond traditional anti-corruption concerns.
• Prosecutors retain significant tools to pursue foreign commercial bribery schemes. Honest services fraud, wire fraud, and related anti-fraud theories remain available tools for prosecuting certain foreign commercial bribery schemes involving private sporting organizations where a sufficient US nexus exists.
• Sporting event hospitality presents unique compliance risks. Premium tickets, hospitality suites, opening ceremonies, championship events, and other exclusive experiences may exceed what enforcement authorities consider routine and bona fide business hospitality, particularly when government officials or key decision-makers are involved.
• Even legitimate event-related expenditures can create liability where controls are inadequate. Books and records, internal controls, and disclosure-related risks remain significant for companies sponsoring, hosting, or participating in major sporting events.

[1] A number of high-profile matters illustrate corruption risk in major sporting events — from the FIFA prosecutions concerning commercial bribery for media rights to the bribery scheme tied to Rio de Janeiro's successful bid for the 2016 Olympic Games. Together, they show that such risk can surface in both public and private sector contexts. See Organized Crime and Corruption Reporting Project (OCCRP), Former Rio Governor Admits to Bribing Olympics Officials (July 5, 2019), https://www.occrp.org/en/news/former-rio-governor-admits-to-bribing-olympics-officials.

[2] US Dep't of Justice, Office of the Deputy Attorney General, Memorandum, Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA) (June 9, 2025) https://www.justice.gov/dag/media/1403031/dl?inline.

[3] A 2024 UN report examining the key vulnerabilities for corruption and bribery risks associated with the FIFA World Cup and upcoming Olympic Games highlights the growing threat of organized crime. U.N. Office on Drugs & Crime, Protecting the FIFA World Cup 2026 and 2028 Summer Olympics from Corruption: 5 Key Takeaways (June 14, 2024), https://www.unodc.org/unodc/frontpage/2024/June/protecting-the-fifa-world-cup-2026-and-2028-summer-olympics-from-corruption_-5-key-takeaways.html.

[4] See, Matthew R. Galeotti, Head of the Criminal Division, US Dep't of Justice, Memorandum, Focus Fairness, and Efficiency in the Fight Against White-Collar Crime (May 12, 2025), https://www.justice.gov/criminal/media/1400046/dl?inline.

[5] Recent enforcement actions reflect this approach, including DOJ's PEMEX-related FCPA conviction and the TIGO Guatemala resolution, both of which involved allegations linking corruption-related conduct to cartels.

[6] The May 2025 White Collar Enforcement Plan identifies bribery, fraud, money laundering, and material support to FTOs among the categories of misconduct warranting heightened enforcement attention. Likewise, the June 2025 FCPA Guidelines, which ended DOJ's temporary pause on FCPA enforcement, direct prosecutors to prioritize cases involving: national security and strategic industries; cartels and transnational criminal organizations; economic competitiveness and harm to US companies; and sophisticated or high-value bribery schemes.

[7] United States v. Lafarge S.A., No. 1:22-cr-00444 (E.D.N.Y. Oct. 18, 2022) (guilty plea and sentencing for conspiracy to provide material support to ISIS and the al-Nusrah Front).

[8] US Dep't of Justice, Department‑Wide Corporate Enforcement and Voluntary Self‑Disclosure Policy, Press Release (Mar. 10, 2026) https://www.justice.gov/dag/media/1430731/dl?inline (2026 DOJ Press Release); see also, Recalibrating the Disclosure Decision: Investigation Costs, Detection Risk, and the AI Inflection Point, Steptoe International Compliance Blog (Apr. 2, 2026).

[9] Notably, the matter did not involve allegations of direct bribery but instead focused on internal controls deficiencies, underscoring the breadth of potential exposure associated with event-related hospitality programs. In BHP Billiton, the SEC alleged that the company failed to design and maintain adequate internal controls to manage the corruption risks associated with inviting government officials to the 2008 Beijing Olympics. BHP Billiton was a major sponsor of the 2008 Beijing Olympics and hosted an extensive hospitality program for customers, suppliers, business partners, and government officials. As part of this program, the company invited close to 200 government officials and employees of state-owned enterprises to attend the Olympics at company expense, ultimately paying for about 60 officials and their guests to attend. The hospitality packages included: Olympic event tickets, luxury hotel accommodations, meals and entertainment, sightseeing excursions, and in most cases, business-class airfare. In re BHP Billiton Ltd. & BHP Billiton Plc, Exchange Act Release No. 74,998, Admin. Proc. File No. 3-16546 (May 20, 2015).

[10] The DOJ's March 2026 declination with French medical device company Balt SAS underscores both increasing cross-border cooperation and DOJ's willingness to defer to foreign authorities where US interests are limited. Although DOJ declined prosecution under its Corporate Enforcement Policy, it coordinated closely with France's Parquet National Financier and expressly credited Balt's parallel French resolution and compliance obligations, highlighting the growing likelihood of multijurisdictional investigations and coordinated enforcement outcomes. See, e.g., US Dep't of Justice, Justice Department Resolves Foreign Bribery Investigation with Balt SAS; Healthcare Executive and Sales Consultant Indicted in Alleged Years-Long Foreign Bribery Scheme, Press Release (Mar. 19, 2026) https://www.justice.gov/opa/pr/justice-department-resolves-foreign-bribery-investigation-balt-sas-healthcare-executive-and.

[11] 2026 DOJ Press Release.