Match-fixing is one of the most serious threats to professional football. As noted in one of the decisions of the Court of Arbitration for Sport (CAS), CAS 2014/A/3628, "… the protection of the integrity of the competitions is absolutely essential for UEFA, as match fixing is considered to be the biggest threat to sport because it touches at the very essence of the principles of loyalty, integrity and sportsmanship". In this article CAS decisions for the period 2009-2014 on cases related to the liability of clubs for match-fixing by officials or players are systematically introduced into scientific circulation. For this purpose, the authors consider the arguments of the parties and CAS in disputes and make the following conclusions. First, the arbitration is not inclined to impose a conditional sanction or reduce the size of the sanction on the basis of proportionality. Secondly, CAS considers an administrative measure to be different in nature from sanctions and therefore not subject to the principle of proportionality. Thirdly, the application of the principle of strict liability allows to hold the clubs that participated in match-fixing activities liable without proving the existence of the club's consent to illegal actions. Fourthly, in order to protect the integrity of sport CAS accepts the use of a wide range of evidence to confirm the fact of match-fixing, including the evidence, the application of which is deemed unacceptable in national legal systems.

The subject. This article is devoted to the content of the principle of proportionality in disputes about the strict liability of football clubs for the behavior of spectators. The proportionality means that the sanction corresponds to the offense and it has two dimensions. Firstly, the more serious the offense is the higher the sanction should be. Secondly, proportionality protects sport from unreasonably low sanctions while the violation is serious.The purpose of the study is the content of the principle of proportionality: the use of related principles of sports jurisprudence, exceptional circumstances (mitigating and aggravating) in the practice of applying clubs` strict liability for spectators` behavior in UEFA competitions over the period 2007-2021. Liability without fault increases the value of investigating the factual circumstances of a dispute. The broad discretion of the bodies raises the question of the validity of the choice of aggravating circumstances or the refusal of mitigating circumstances. Therefore, the jurisdictional authority in each specific dispute must search for exceptional circumstances thereby fulfilling the principle of proportionality. The second important nuance of strict liability in the UEFA regulations is the difference in the interconnection between violations and sanctions. In some articles, the sanction is predetermined. It is possible to reduce such a sanction only in the presence of an exceptional circumstance and to increase it in the presence of an aggravating circumstance. Separately considered, in conjunction with the principle of proportionality, other principles: principles of predictability of sanctions, equal treatment, the precedent value of decisions on similar disputes (stare decisis).Methodology. The methodological basis of the stated research involves the generalization and analysis of the practice of two institutions of sports jurisprudence. Firstly, the jurisdictional bodies of UEFA are publicly available, as well as available to the author, but currently not available for free download on the UEFA website. Secondly, the relevant decisions of the Court of Arbitration for Sport are in the public domain. Turning to the approaches of law enforcement officers regarding the content of the principle of proportionality meant comparing positions that did not differ in inconsistency. As a result of the analysis of the practice were systematized and identified typical exceptional circumstances, unique exceptional circumstances, and specific enforcement of the principle of proportionality.The main results of research and the field of their application. The article examined the normative limits of sanctions in the UEFA Disciplinary Regulations; exceptional circumstances affecting the choice of sanction; search by the law enforcement officer of the content of exceptional circumstances; principles of predictability of sanctions, equal treatment, the precedent value of decisions on similar disputes (stare decisis) in connection with the verification of sanctions for proportionality. Compliance with the principle of proportionality, in this case, should protect the club from an unreasonably harsh and grossly disproportional sanction. Therefore, it is important to analyze the factual circumstances: which of them are mitigating and which are aggravating. In other categories of offenses, the sanction remains at the discretion of the jurisdictional authority. In such violations, the principle of proportionality takes on a special value. The more flexibility in the choice of sanction is, the higher is the risk of abuse by the jurisdictional bodes. UEFA`s enforcement practice is seeking exceptional circumstances that are not consistent enough to be predictable. Some consistency exists only concerning aggravating circumstances. There is an unreasonably strict approach to mitigating circumstances. The practice of CAS does not differ from the practice of UEFA in terms of strict liability compositions. The principle of proportionality in sports jurisprudence can be interconnected with other legal concepts. Such concepts are equal treatment, predictability, and so-called stare decisis.Conclusions. For the slightly undisputed observance of the principle of proportionality, several requirements must be fulfilled. First, analyze the factual circumstances to find exceptional circumstances among them. Secondly, always choose the minimum sanction in the absence of aggravating circumstances, since strict liability is a forced legal institution. Thirdly, indicate in the decisions what circumstances are mitigating, what aggravating circumstances have been established, and how they both affect the choice of a sanction. Fourth, use the previous decisions of the UEFA`s jurisdictional bodies and CAS of the strict liability offenses when the actual circumstances are close.

В статье анализируется практика принятия решений CAS в отношении критериев признания статуса юрисдикционных решений для писем и сообщений органов спортивных федераций. Кроме того, дается определение понятия "решения", данное в соответствии с практикой CAS. При этом по существу рассматриваются форма и содержание решений международных спортивных федераций, передаваемых субъекту спорта. The article analyzes the practice of CAS decision-making in relation to the criteria for recognizing the status of jurisdictional decisions for letters and messages of Sports Federations' bodies. In addition, the article provides a definition of the concept of “decision”, given in accordance with the CAS practice. At the same time, the form and content of decisions of international sports federations transmitted to the subject of sport are considered in essence.

В статье проводится сравнение положений ст. 184 УК РФ (Оказание противоправного влияния на результат официального спортивного соревнования) и соответствующих статей Дисциплинарного Регламента Федерации Хоккея России. Автор произвел сравнение составов анализируемых правонарушений: объекта, субъекта, объективной стороны и субъективной стороны и указал их сходства и отличия. The article compares the provisions of Article 184 of the Criminal Code of the Russian Federation (Illegal influence on the result of an official sports competition) and the corresponding articles of the Disciplinary Regulations of the Russian Ice Hockey Federation. The author compared the components of the analyzed offenses: the object, the subject, the objective side and the subjective side, and indicated their similarities and differences.