Sanctions on Norwegian Club Brann Over ‘UEFA Mafia’ Chants Overturned

The Court of Arbitration for Sport (CAS) has set aside the sanction of EUR 5000 imposed by the UEFA Control, Ethics, and Disciplinary Body (“CEDB”) on Norwegian sports club Brann for a disciplinary breach.

The sanctions were imposed due to an incident that occurred during a UEFA Women’s Champions League match on 31 January 2024. During the match, Brann’s supporters chanted “UEFA MAFIA” for approximately 20 seconds in response to the referee’s decision to award a free kick to the opposing team for a foul committed by one of Brann’s players.

The sports club contended that the chant was an innocent, satirical outburst, which may be characterised as a spontaneous and subjective expression of frustration and which is protected by the right of freedom of expression. UEFA asserted that the chant was a prime example of a highly offensive and defamatory message that was not fit for a sports event and clearly breached Article 16(2)(e) of the UEFA Disciplinary Regulations.

The CAS panel concluded that the club was not strictly liable for the conduct of its supporters. Moreover, the short, isolated, and fleeting football chant of the Norwegian fans directed to UEFA constituted an inappropriate expression of frustration but did not fall within the category of provocative messages of an offensive nature that would encourage football supporters from either team to engage in aggressive, disruptive behaviour or threaten order and security in the stadium, within the scope of Article 16 (2)(e). Further, the UEFA Match Delegate Report had recorded the atmosphere during the match as “excellent” and had not reported on any security concerns arising because of the chant.