The case involves Russian sprinter Rudolf Verkhovykh appealing a decision by the Russian Anti-Doping Agency (RUSADA) regarding a violation of prohibited association rules. The dispute centers on Verkhovykh's association with coach Vladimir Kazarin, who had been banned for life due to anti-doping violations. The Court of Arbitration for Sport (CAS) ruled on several key legal and factual issues, emphasizing that anti-doping rules reflect a global consensus on fair sport and should be respected as such. For Article 2.10 of the Russian Anti-Doping Rules (ADR) to apply, an athlete must have been previously advised in writing about the disqualifying status of the associated person and the consequences of prohibited association, with the athlete having a reasonable opportunity to avoid the association. The form of written notice is not strictly defined, and the WADA Guidelines' template is not mandatory.
Verkhovykh began training with Kazarin in 2016, unaware of the coach's lifetime ban imposed in 2017. Despite informal warnings, Verkhovykh continued training with him. In 2018, RUSADA investigated but did not formally record the coach's presence at training camps. Verkhovykh was questioned and signed a statement acknowledging the risks of prohibited association but later denied the association under the coach's instructions. RUSADA charged Verkhovykh in 2019, marking the first formal communication about the rule's implications. The CAS upheld RUSADA's decision, finding Verkhovykh had been adequately informed of the risks and failed to prove the association was unavoidable. The ruling reinforces strict adherence to anti-doping regulations, emphasizing athletes' responsibility to avoid banned personnel, even under financial or coercive pressures.
The case underscores the importance of clear communication from anti-doping agencies and the rigorous standards applied in enforcing anti-doping rules. The Prohibited Association Rule, introduced in the 2015 WADA Code, bars athletes from associating with support personnel serving a period of ineligibility, provided the athlete has been formally notified of the consequences. The Sole Arbitrator concluded that the written statement prepared by Verkhovykh during a meeting with RUSADA satisfied the requirements of Article 2.10, as it explicitly warned him of disqualification risks for associating with the coach. The arbitrator dismissed Verkhovykh's claims of procedural unfairness, including alleged intimidation and confidentiality breaches, noting that the CAS has full authority to review and cure any procedural flaws from prior proceedings.
The decision highlights the balance between strict rule adherence and the practical challenges of enforcing anti-doping policies. The Sole Arbitrator emphasized that the Prohibited Association Rule unambiguously requires written advance notice to athletes before they can be charged with a violation, ensuring fairness and predictability in the application of anti-doping regulations. The case also illustrates the broader context of anti-doping enforcement, where athletes may face sanctions not for direct doping but for associations with banned individuals. The final ruling upheld RUSADA's decision, reinforcing the importance of compliance with anti-doping regulations and the clarity of warnings provided to athletes. The case serves as a precedent for the strict interpretation and enforcement of anti-doping rules, particularly those involving indirect violations like prohibited association.