(New York) – A flawed human rights assessment of Saudi Arabia’s FIFA 2034 World Cup bid by AS&H Clifford Chance, part of the global partnership of London-based law firm Clifford Chance, leaves the global firm at risk of being linked to abuses which result from the tournament, 11 organizations, including Human Rights Watch, said today.
AS&H Clifford Chance, which is based in Riyadh and sits within Clifford Chance’s integrated global partnership, produced an “independent human rights context assessment” that was published by FIFA. The assessment has helped pave the way for Saudi Arabia to be confirmed as 2034 hosts on December 11, 2034. But it contains no substantive discussion of extensive and relevant abuses in Saudi Arabia, documented by multiple human rights organizations and UN bodies, and has formed the basis of Saudi Arabia’s human rights strategy for the tournament, which was described by Amnesty International as a “whitewash.”
The 11 organizations, which include a Saudi Arabian diaspora organization, Gulf human rights groups, and labor organizations, as well as Football Supporters Europe, Amnesty International, and Human Rights Watch, wrote to Clifford Chance’s Global Managing Partner, setting out in detail all the concerns in a statement and inviting the authors to publish an updated report. The firm, which says that it works in partnership with “some of the world’s leading NGOs and civil society organizations,” said in response that it would be “inappropriate” to offer any further comment on the report and shared a link to publicly available company policies.
“It has been clear for more than a year now that FIFA is determined to remove all potential obstacles to make sure it can hand Saudi Arabia’s Crown Prince Mohammed bin Salman the 2034 World Cup,” said James Lynch, co-director of the FairSquare human rights organization, which led the joint approach to the law firm. “By producing a shockingly poor report, AS&H Clifford Chance, part of one of the world’s largest law firms that makes much of its human rights expertise, has helped to remove a key final stumbling block.”
Saudi Arabia’s already dire human rights record has deteriorated under the de facto rule of Crown Prince Mohammed bin Salman, who has presided over a soaring number of mass executions, torture, enforced disappearance, severe restrictions on free expression, repression of women’s rights under the male guardianship system, LGBTI+ discrimination, and the killing of hundreds of migrants at the Saudi Arabia-Yemen border. The country’s abusive kafala (labor sponsorship) system, as well as the prohibition on trade unions and lack of enforcement of labor laws continues to lead to the widespread exploitation of migrant workers.
The 11 organizations warned Clifford Chance that, through the production of its human rights assessment by AS&H Clifford Chance, there is a risk that the firm could be linked to potential adverse human rights impacts resulting from a Saudi Arabia-hosted tournament.
“AS&H Clifford Chance had the chance to write a credible assessment of risks that are relevant to the 2034 World Cup,” said Julia Legner, executive director of ALQST for Human Rights, a Saudi Arabian diaspora organization. “Instead, they have produced an artificially limited, misleading, and overly positive perspective that serves only to whitewash the reality of abuse and discrimination faced by Saudi Arabia’s citizens and residents.”
In their memorandum to Clifford Chance, the organizations set out, and requested comment on, three overarching concerns about the assessment. Taken together, these undermine the report’s claim to provide an independent assessment of the human rights context in Saudi Arabia, relevant to the hosting and staging of the 2034 World Cup.
- AS&H Clifford Chance agreed to a decision by FIFA and the Saudi Arabian Football Federation (SAFF) to effectively exclude analysis of Saudi Arabia’s record on multiple critical human rights such as violations of freedom of expression, LGBTI+ discrimination, the prohibition of trade unions, or forced evictions, either because Saudi Arabia has not ratified the relevant treaties or because SAFF did not accept them as “applying.” Any assessment that does not recognize these as relevant human rights risks for a World Cup in Saudi Arabia cannot be considered credible.
- The assessment made highly selective use of the findings of UN bodies on Saudi Arabia, leaving out damaging judgments. For example, it fails to reference one UN body’s concern at receiving reports that “torture and other ill-treatment are commonly practised in prisons,” or another that notes that “women and girls who are victims of sexual abuse risk facing criminal proceedings if they press charges”. It does not mention that Saudi Arabia is currently facing a labor complaint at the UN brought by Building and Woodworkers International, an international trade union. No reports by UN special rapporteurs are included, meaning for example that there is no reference to the imposition of the death penalty in relation to the crown prince’s flagship giga-project Neom, nor the murder of the Saudi Arabian journalist Jamal Khashoggi.
- There is no evidence that AS&H Clifford Chance consulted external experts, such as people who might be affected by human rights abuses linked to the tournament, Saudi Arabian human rights experts or organizations, international human rights organizations, or trade unions. No work by such groups is referenced. The report, for example, ignores Amnesty International’s 2024 91-page report, “Playing a Dangerous Game? Human Rights Risks Linked to the 2030 and 2034 FIFA World Cups.”
The Independent Context Assessment Prepared for the Saudi Arabian Football Federation in relation to the FIFA World Cup 2034 can be found on FIFA’s website. FIFA’s Human Rights Policy, adopted in 2017, outlines its responsibility to identify and address adverse human rights impacts of its operations, including taking adequate measures to prevent and mitigate human rights abuses.
Clifford Chance is one of the world’s largest law firms. It has made multiple commitments concerning its human rights responsibilities, including in its company code. The firm states on its global website that its client base in Saudi Arabia, delivered “through AS&H Clifford Chance,” includes “key Saudi Ministries and government-owned entities as well as a wide range of government owned, privately and publicly held Saudi and international businesses, listed companies and financial institutions.”
These Saudi clients include the Public Investment Fund. AS&H Clifford Chance is a Joint Venture (JV) between Clifford Chance and AS&H that has been registered in Saudi Arabia since 2023. It is integrated within Clifford Chance’s global firm, “follows [the global firm’s] processes and practices,” and employs a number of Clifford Chance partners, including a “Senior Clifford Chance partner.” The Independent Context Assessment refers readers to the global Clifford Chance website.
Signatories:
- FairSquare
- ALQST for Human Rights
- Amnesty International
- The Army of Survivors
- Building and Woodworkers International
- Equidem
- Football Supporters Europe
- Gulf Centre for Human Rights
- Human Rights Watch
- Middle East Democracy Center
- Migrant-Rights.org
