UEFA Punishes CSKA Moscow for Racist Behavior with Partial Stadium Ban

Last week, Business of Soccer considered UEFA’s investigation into Manchester City midfielder Yaya Toure’s racism claims against CSKA Moscow and posited that UEFA had two opportunities to establish its purported strong stance against racism in European football.


On Wednesday, we learned that the UEFA Control and Disciplinary Body (the “CDB”) had reached a decision, stating: “Following the charge of racist behaviour by CSKA supporters during the Manchester City match . . . , the  Control and Disciplinary Body has ordered the partial closure of the Arena Khimki, where CSKA play their home games in UEFA competition: specifically, to close sector D of the stadium during the club’s next UEFA competition home match [against Bayern Munich on November 27].”

Under Article 14 of the UEFA Disciplinary Regulations, if a member association or club supporters are responsible for racist behavior, the minimum punishment for the first offense is a partial stadium closure.  The CDB levied that minimum punishment against CSKA Moscow.  Arena Khimki, which has a capacity of 18,636, has roughly 5 sections: A, B, C, D, and a section labeled “VIP.”  Under the UEFA sanctions, Sector D (see image, below) will not be open for fans during the Bayern Munich game on November 27.  Given the relative size of that section, one could question whether the CDB’s punishment represents a slap on the hand or a measured response.image description

The CDB did not explicitly discuss its factual findings relating to the investigation into Toure’s claims.  Rather, the press release from UEFA stated only that sanctions against CSKA Moscow were levied and that the punishment was a partial stadium closure.  It is therefore difficult to fully understand the nature of the punishment against CSKA Moscow.  For example, if the CDB was unable to definitively determine that racist behavior occurred or, alternatively, found the evidence to be ambiguous, the punishment could be considered a strong reaction to Toure’s claims.  If the CDB determined, however, that CSKA Moscow supporters clearly engaged in racist behavior, closing only Sector D of the stadium appears at odds with UEFA’s zero tolerance policy against racism.

UEFA went on to say:

The fight against racism is a high priority for UEFA. The European governing body has a zero tolerance policy towards racism and discrimination on the pitch and in the stands. All forms of racist behaviour are considered serious offences against the disciplinary regulations and are punished with the most severe sanctions. Following the entry into force of the new disciplinary regulations on 1 June, the fight against racist conduct has been stepped up a level – resulting in more severe sanctions to deter any such behaviour.

Whether UEFA has taken a  stand against racism regarding of Toure’s claims is up for debate, and ultimately is best understood in light of its factual conclusions, which were not published.  Unfortunately, there is little question that UEFA will have multiple opportunities to revisit its approach to punishing racism in football.  For UEFA, more clarity regarding the CDB’s factual conclusions and the impact of those conclusions on the severity of the punishment may serve as a greater deterrent to future behavior.

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