AS&H Clifford Chance’s assessment contains no substantive discussion of Saudi’s extensive and relevant abuses

11 human rights groups, football supporters and worker organisations join forces to voice deep concern

‘FIFA must insist on a proper assessment and meaningful human rights strategy or its flagship tournament will be tarnished by severe human rights violations’ - Steve Cockburn

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 organisations 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 and has helped pave the way for Saudi Arabia to be confirmed on 11 December as the 2034 hosts, as is widely expected to happen.

The assessment contains no substantive discussion of extensive and relevant abuses in Saudi Arabia documented by multiple human rights organisations and UN bodies. It formed the basis of Saudi Arabia’s human rights strategy for the tournament, which Amnesty International described as a “whitewash”.

The 11 organisations – which include a Saudi Arabian diaspora organisation, Gulf human rights groups, and labour organisations, as well as Football Supporters Europe, Amnesty and Human Rights Watch – wrote to Clifford Chance’s Global Managing Partner setting out in detail all of their concerns with the statement, and invited 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 organisations”, said in response last week that it would be “inappropriate” to offer any further comment on the report and shared a link to publicly available company policies.

Dire human rights record

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 (labour sponsorship) system, as well as the prohibition on trade unions and lack of enforcement of labour laws continues to lead to the widespread exploitation of migrant workers.

The organisations have 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.

In their memorandum to Clifford Chance the organisations set out and requested comment on three overarching concerns about the assessment. Taken together, these fatally 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 to effectively exclude analysis of Saudi Arabia’s record on multiple critical human rights such as 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 the Saudi Arabian Football Federation did not accept them as “applying”. Any assessment that does not recognise 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 judgements. 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 which 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 labour 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, there is no reference to the imposition of the death penalty in relation to the Crown Prince’s flagship giga-project NEOM, or the murder of 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 organisations, international human rights organisations, or trade unions. No work by such groups is referenced. The report, for example, ignores Amnesty’s 2024 91-page report ‘Playing a Dangerous Game? Human Rights Risks Linked to the 2030 and 2034 FIFA World Cups’.

Amnesty has written to FIFA asking it to confirm on what basis the organisation agreed with the Saudi Arabian Football Federation to limit the scope of the rights assessment conducted by AS&H Clifford Chance. As of 25 October, FIFA had not responded.

James Lynch, FairSquare co-director, said: 

“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. 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.”

Julia Legner, Executive Director of ALQST for Human Rights, a Saudi Arabian diaspora organisation, said:

“AS&H Clifford Chance had the chance to write a credible assessment of risks that are relevant to the 2034 World Cup. 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.”

Steve Cockburn, Amnesty International’s Head of Labour Rights and Sport, said:

“The severe risks of hosting the 2034 World Cup in Saudi Arabia are clear and well-known - without huge reforms, critics will be arrested, women and LGBTI+ people will face discrimination, and workers will be exploited on a massive scale. It is incredible that AS&H Clifford Chance omitted such glaring risks from its assessment and scandalous that FIFA paved the way for them to do so. FIFA must now insist on a proper assessment and meaningful human rights strategy or its flagship tournament will inevitably be tarnished by severe human rights violations.”

Martha Waithira, Equidem investigator, said:

"As a former domestic worker in Saudi Arabia from Kenya, I know that women like me are often treated like slaves. Women especially face sexual and other gender abuse. I'm in regular contact with workers in horrific situations in Saudi Arabia. Now, the hundreds of thousands of people expected to arrive in Saudi Arabia to build stadiums and clean hotels ahead of the World Cup are at great risk of severe exploitation and even death. How can these realities have escaped AS&H Clifford Chance’s attention?”

Stated commitments to human rights



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 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.

Full list of 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