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  • 7/29/2019 Australia drugs report

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    ORGANISED CRIMEAND DRUGS IN SPORTNew Generation Performance and Image Enhancing Drugs and Organised

    Criminal Involvement in their use in Professional Sport

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    Correspondence should be addressed to:

    Cief Execuve Ocer

    Australian Crime Commission

    PO Box 1936 Canberra Cit

    ACT 2601

    Telephone:

    02 6243 6666 (from witin Australia)

    61 2 6243 6666 (internaonal)

    Facsimile:

    02 6243 6687 (from witin Australia)

    61 2 6243 6687 (internaonal)

    Published February 2013

    Te informaon contained in tis report is produced b te Australian Crime Commission (ACC).

    Commonwealt of Australia 2013.

    Tis work is coprigt. Apart from an use as permied under te Coprigt Act 1968, no part ma

    be reproduced b an process witout wrien permission from te Cief Execuve Ocer, Australian

    Crime Commission.

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    ORGANISED CRIMEAND DRUGS IN SPORTNew Generation Performance and Image Enhancing Drugs and Organised

    Criminal Involvement in their use in Professional Sport

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    4/472AUSTRALIAN CRIME COMMISSION - ORGANISED CRIME AND DRUGS IN SPORT

    OVERVIEW 4AIM AND SCOPE 5

    LIMITATIONS ON DISCLOSURE OF FINDINGS 6

    KEY FINDINGS 7

    Nature of te treat 7

    Te PIEDs market 7

    Te role of organised crime 7

    Use b professional atletes 8

    Te role of sports sciensts, coaces and oter facilitators

    9

    THE IMPORTANCE OF SPORT IN AUSTRALIA 10

    PERFORMANCE AND IMAGE ENHANCING SUBSTANCES 12

    Growt ormone releasing pepdes 13

    Growt ormone variants 14

    Selecve androgen receptor modulators 14

    Insulin-like growt factors (IGF-1) 15

    Mecano growt factor (MGF)

    15

    Oter substances 16

    PEPTIDE AND HORMONE CONSUMERS 17

    Elite atletes 17

    Sub-elite atletes 18

    Bodbuilders 19

    An-ageing clinic clients 20

    Use on animals 21

    Monitoring future demand 21

    SOURCES OF PEPTIDES AND HORMONES 22

    Online suppliers 22

    An-ageing clinics 24

    Medical praconers 25

    Compounding parmacies 26

    Sports sciensts and ig performance sta 26

    Administraon of untested substances to atletes 28

    Supplement suppliers 28

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    ORGANISED CRIME, DRUGS AND SPORT 30

    Organised criminal links 30

    Organised criminal inltraon of unregulated markets 32

    Inltraon troug legimate business 32

    Illicit drug use and criminal associaons 33

    VULNERABILITIES TO INTEGRITY MECHANISMS 34

    Contractors and consultants 34

    Inconsistent integrit oversigt in professional sport 35

    CONCLUSION 36

    APPENDIX ONE OVERVIEW OF PEPTIDES 38

    APPENDIX TWO SUMMARy OF LEGAL STATUS AND STATUS IN

    SPORT OF PEPTIDES AND hORMONES 40

    APPENDIX ThREE SUMMARy OF PIEDs 41

    ACRONyMS 43

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    6/474AUSTRALIAN CRIME COMMISSION - ORGANISED CRIME AND DRUGS IN SPORT

    In 2011, te Australian Crime Commission (ACC) igligted treats to te integritof professional sport and concluded tat tere was potenal for organised crime to

    inltrate sport in Australia, as as occurred overseas.

    Data from te ACCs 201011 Illicit Drug Data Report indicated tat te market for

    Performance and Image Enancing Drugs (PIEDs) as expanded, wit record numbers

    of seizures, detecons and arrests and increasing reports b users tat te were

    injecng tem. Te ACC also received informaon from te Australian Sports An-

    Doping Autorit (ASADA), as part of te ACCs roune monitoring of all illicit drug

    markets, wic suggested a potenal treat to a number of sports from te use of new

    generaon PIEDs.

    In earl 2012, te ACC, wit te assistance of ASADA1, began a project to consider te

    extent of use of PIEDs b professional atletes, te size of tis market and te extent of

    organised criminal involvement. Tis project focused parcularl on a new form of PIEDs,

    known collecvel as pepdes and ormones. Tese substances ma provide eects

    similar to anabolic steroids and are considered b users to be next generaon PIEDs.

    Some of tese substances are perceived b atletes to be undetectable, making tem

    aracve to tose seeking to gain an unfair advantage.

    Tis report provides a summar of ndings from tis project. In parcular, te ACC as

    now idened use of tese substances, wic are proibited b te World An-Doping

    Agenc (WADA), b professional atletes in a number of sports in Australia. Widespread

    use as been idened or is suspected in a number of professional sporng codes.

    In detailing te nature and extent of tis treat to te professional sporng industr

    and te Australian Communit, tis report provides an important opportunit for

    Government, regulator bodies and te sporng industr to address tese issues ead on.

    1 Te ACC as collaborated wit ASADA trougout tis project and references to te ACC in tis report sould be

    understood to impl and reect te outcomes of tis collaboraon. As te appropriate regulator agenc, ASADA will

    conduct its own invesgaon of maers raised b tis project.

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    Te project, code named Project Aperio, was a 12-mont ACC invesgaon, supportedb ASADA and te Terapeuc Goods Administraon (TGA), wic examined te

    following four ke issues:

    new generaon PIEDs, tat were previousl considered to be onl used b elite

    atletes and are now widel available

    te involvement of organised criminal idenes and groups in te distribuon of new

    generaon PIEDs

    te use of WADA proibited substances b professional atletes in Australia

    current treats to te integrit of professional sport in Australia.

    Based on intelligence provided to te ACC, Project Aperio primaril considered two

    major sporng codes in Australia and collected incidental intelligence relang to oter

    sporng codes.

    Tis report does not provide a compreensive summar of all relevant acvit of

    concern in all sports, or all sporng clubs and francises in Australia. Rater it represents

    a snapsot of te acvit, derived from te intelligence wic formed te original basis

    of te inquiries and te need for te ACC to focus on te role of organised crime in te

    PIEDs market. It is likel, given te level of demand for PIEDs and te diverse sources of

    suppl, tat te use of WADA proibited substances is more widespread tan idened

    in tis report.

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    Legal provisions prevent te ACC from publicl disclosing detailed informaon about te

    nature of te maers contained in tis report. Tis includes te disclosure of informaon

    specicall referencing plaers, clubs and an informaon tat could idenf oter

    individuals involved. Parcular sporng bodies ave received classied briengs on

    maers relevant to tem.

    As suc, te report focuses on describing te broad nature of te acvies, treats and

    vulnerabilies and includes intelligence judgements about te likel future trajector of

    tese issues.

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    Despite being proibited substances in professional sport, pepdes and ormones are

    being used b professional atletes in Australia, facilitated b sports sciensts, ig-

    performance coaces and sports sta. Widespread use of tese substances as been

    idened, or is suspected b te ACC, in a number of professional sporng codes in

    Australia. In addion, te level of use of illicit drugs witin some sporng codes is

    considered to be signicantl iger tan is recorded in ocial stascs.

    Te ACC as also idened tat organised crime idenes and groups are involved in te

    domesc distribuon of PIEDs, wic includes pepdes and ormones. If le uncecked,it is likel tat organised criminals will increase teir presence in te distribuon of

    pepdes and ormones in Australia.

    Te ACC as idened signicant integrit concerns witin professional sports in

    Australia related to te use of proibited substances b atletes and increasing

    associaons of concern between professional atletes and criminal idenes.

    Furter ke ndings, summarised into relevant topics are outlined below.

    Te PIEDs market in Australia is large and diverse, wit a wide range of substances being

    used b a broad cross-secon of te communit.

    PIEDs previousl considered to onl be available to elite atletes and used in

    sopiscated sports doping programs due to te expense and complexit of teir

    administraon, are now widel available. A igl protable and organised market as

    been establised around te sourcing and suppl of new generaon PIEDs.

    Te growt ormone releasing pepde (erein referred to as pepdes), ormone

    and anabolic steroid markets are assessed b te ACC to be one and te same, wit

    individuals tracking anabolic steroids also distribung pepdes and ormones.

    Organised criminal idenes and groups are acve in te tracking of PIEDs tat are

    being used b elite atletes in Australia. Organised crime groups are taking advantage

    of te current legislave and regulator situaon wereb persons and enes wo

    suppl certain substances to atletes wic are proibited under te WADA Code do not

    commit a crime in Australian jurisdicons. however, atletes wo use te substances

    face substanal sporng bans. Tis is a signicant legislave and regulator vulnerabilit.

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    Professional sport in Australia is igl vulnerable to organised criminal inltraon

    troug legimate business relaonsips wit sports francises and oter associaons.

    Tis is facilitated b a lack of appropriate levels of due diligence b sporng clubs and

    sports governing bodies wen entering into business arrangements.

    Tere is also increasing evidence of personal relaonsips of concern between

    professional atletes and organised criminal idenes and groups.

    Te ACC as idened widespread use of

    pepdes and ormones b professional

    atletes in Australia. Given tat man of

    tese substances are proibited for use b

    atletes b WADA, atletes wo use tese

    substances ave potenall commied

    an-doping rule violaons.

    Wile intelligence conrms te use of

    pepdes in major sporng codes, it furter

    suggests tat individuals in a range of oter

    codes ma also be using pepdes.

    Mulple plaers across some sporng codes and specic clubs witin tose codes

    are suspected of currentl using or aving previousl used pepdes, wic could

    constute an an-doping rule violaon. Te level of suspected use of pepdes varies

    between some sporng codes, owever ocials from a club ave been idened as

    administering, via injecons and intravenous drips, a variet of substances, possibl

    including pepdes. Moreover, te substances were administered at levels wic were

    possibl in breac of WADA an-doping rules.

    Te use of pepdes and ormones is linked to a culture in some professional sports in

    Australia of administering untested and experimental substances to atletes in te ope

    te will provide an advantage in te igl compeve world of professional sport. In

    some instances, te substances are not et approved for uman use.In addion to elite atletes using pepdes and ormones, tese substances are also

    being used b sub-elite atletes compeng at various levels of compeon, for example

    at te state and club level.

    Illicit drug use b professional atletes is more prevalent tan is reected in ocial

    sports drug tesng program stascs, and tere is evidence tat some professional

    atletes are exploing loopoles in illicit drug tesng programs.

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    Some coaces, sports sciensts and support sta of elite atletes ave orcestrated and/

    or condoned te use of proibited substances and/or metods of administraon.

    Sports sciensts are now inuenal in professional sport in Australia, wit some of tese

    individuals prepared to administer substances to elite atletes wic are untested or not

    et approved for uman use.

    In man Australian sporng codes, sports sciensts ave gained increasing inuence over

    decision making witin te clubs. Some sports sciensts and doctors are experimenng

    on professional sportspersons in an eort to determine if parcular substances can

    improve performance witout being detected.

    Complicit medical praconers are a ke conduit troug wic pepdes and ormonesare being supplied to atletes and oter individuals on prescripon. In some cases,

    medical praconers wo are prescribing pepdes, ormones and oter PIEDs are

    engaging in lax, fraudulent and unetical prescribing pracces, suc as prescribing

    controlled drugs in false names.

    Some an-ageing clinics ave been idened as a ke source of suppl of parmaceucal

    grade WADA proibited PIEDs to atletes, in some cases witout prescripon.

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    Internaonall and domescall, sport as become a igl protable global enterprise.

    Based on te latest available Australian Bureau of Stascs data,2 in 2006 te total

    annual income generated b te sport and recreaon industr in Australia was esmated

    at A$8.82 billion, a gure wic will ave

    grown substanall since ten. Apart from

    te direct contribuon of sport to te

    Australian econom, tere is intangible

    value from te success of Australian

    teams and atletes on te internaonal

    stage and te abilit to sowcase Australia

    on te internaonal stage wen it osts

    major events.

    Te concept of fair pla is a ke

    foundaon for amateur and professional

    sport in Australia. The Essence of

    Australian Sport,3 a document produced last ear b te Australian Sports Commission

    (ASC) in consultaon wit te sports industr, provides a statement on wat sport in

    Australia stands forits core principles and values.

    Tis document notes: Australians are proud of teir sporng abilit and reputaon as

    a naon of good sports, and our societ expects ig standards of beaviour from all

    people involved in sport.4

    Te ACC and ASADA ave idened signicant issues in professional and sub-elite sport

    in Australia wic undermine te principles of fair pla as a direct consequence of te

    use of PIEDs.

    Te importance of fairness is idened as one of te ke principles in The Essence of

    Australian Sport. Te document states tat plaers of sport at all levels sould strive to

    upold te principles of fairness and operate in te spirit of te rules, never taking an

    unfair advantage, and making informed and onourable decisions at all mes.

    It goes on to state: ...it is vital tat te integrit of sport is maintained. Te main

    responsibilit for tis lies wit decision makers at ever level of sport, wo sould ensure

    2 Australian Bureau of Stascs (ABS) 2006, Sport and psical recreaon services, Australia-200405, ABS, Canberra.

    3 Te Australian Sports Commission (ASC) 2012, Te essence of Australian sport, Canberra, n.d., viewed 20 November

    2012, .

    4 ibid., p.2.

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    tat all policies, programs and services are based on te principles of fairness, respect,

    responsibilit and safet.5

    Apart from te potenal impact on spectators and teir loss of fait in sport arising from

    integrit issues around te use of proibited substances, te increasing link between

    sports and wagering markets means te issues idened b te ACC and ASADA also

    ave major implicaons for te integrit of sports beng markets. Individuals and teams

    engaged in te use of proibited substances ave an unfair advantage, wic can be

    exploited b persons wit inside informaon.

    Wile tere is a long istor of beng on sports, te market as expanded

    signicantl in recent ears wit growt of up to 13 per cent annuall. Beng on

    racing6 remains te largest beng market in Australia, increasing 69 per cent between

    200001 and 201011. Wagering on oter sports increased b 278 per cent over te

    same period.7

    5 ibid., p.2.

    6 Racing includes torougbred orse racing, and arness and greound racing.

    7 In 200001, of te esmated A$12.8 billion wagered on racing and oter sports in Australia, A$880 million was

    wagered on sports oter tan racing. In 201011, A$23.5 billion was wagered on racing and sports in Australia, wit

    A$3.3 billion being wagered on sports oter tan racing; Australian Racing Board Limited 2011,Australian Racing Fact

    Book; A guide to the Racing Industry in Australia , Australian Racing Board, Sdne.

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    Te principal substances idened troug Project Aperio as being used were:

    growt ormone releasing pepdes (CJC-1295, GhRP-2, GhRP-6 and hexarelin)

    growt ormone variants (AOD-9604)

    selecve androgen receptor modulators (SARMs)

    insulin like growt factor (IGF-1) and mecano growt factor (MGF).

    For te purposes of tis report, tese substances will be collecvel referred to as

    pepdes and ormones. A summar of te legal status and status of tese substances in

    professional sport is detailed in Appendix Two.

    Te Australian PIEDs market as expanded rapidl in recent ears. Tis is evidenced b:

    increased border seizures, wit te number of PIEDs detected at te Australian

    border rising from 2695 in 200910 to 5561 in 201011, a 106 per cent

    increase, and te igest recorded number of PIEDs detecons at te border in

    te last decade8

    an increase of 255 per cent between 200910 and 201011 in te number of

    ormones detected at te Australian border b te Australian Customs andBorder Protecon Service

    te igest number on record of naonal steroid seizures and arrests in

    201011 b Australian law enforcement agencies9

    an increasing number of individuals reporng te injecon of PIEDs

    more tan alf of te males wo were new to injecng in 2011 were reportedl

    injecng PIEDs.10

    Wile anabolic steroids remain te most widel recognised PIEDs, an arra of drugs

    tat were originall developed for te treatment of medical and ormonal disorders bmanipulang te bods ormonal sstem are now also being used as PIEDs.

    8 Australian Crime Commission (ACC) 2012,Australian Illicit Drug Report 201011, ACC, Canberra.

    9 ibid.

    10 Universit of New Sout Wales (UNSW) 2012,Australian NSP Survey: Naonal Data Report 20072011, UNSW, Sdne.

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    In recent ears, pepdes ave become increasingl popular among professional

    and amateur atletes, bodbuilders, and as a fountain of out witin te

    an-ageing fraternit.

    Growt ormone releasing pepdes smulate release of an increased level of uman

    growt ormone (Gh), wic as a istor of misuse b atletes and ma pla an

    important role in muscle and bone growt.

    Wile pepdes can be used on teir own to promote muscle growt, tese substances

    are also used in combinaon wit anabolic steroids to maintain muscle gains.

    Pepdes ave become popular wit elite atletes given te abilit of tese substances

    to smulate Gh producon, resulng in possible anabolic eects. Anecdotal reports

    suggest pepdes assist in reabilitang so ssue injuries. however, bot tereabilitave properes and broader benets of pepdes to atletes (wo tpicall ave

    iger levels of Gh) are et to be sciencall proven.

    Pepdes are also marketed as an an-ageing medicine given teir abilit to increase Gh

    levels and compensate for te natural decline in Gh associated wit ageing.11

    From an an-doping perspecve, te abilit to detect pepde use is complex, as tese

    substances are rapidl metabolised.

    Pepdes are classied as a Scedule 2 (S2) proibited substance on te WADA Proibited

    List and are terefore proibited for use b professional atletes bot in and out ofcompeon. Pepdes ave been a WADA proibited substance since at least 2008.

    As noted previousl, te principal pepdes idened b te ACC and ASADA as being

    misused in bot professional sports and te broader populaon are:

    CJC-1295

    GhRP-6

    hexarelin.

    Pepdes are sold eiter as a transdermal cream or in a soluon for injecon as per te

    examples in Figure 1. As sown in Figure 1, te soluon for injecon clearl states on te

    label tat tese substances are For Researc Purposes Onl. A compreensive overview

    of te various pepdes currentl being used in Australia is provided in Appendix Two and

    Appendix Tree.

    11 Gh levels peak during cildood and adolescence and ten consistentl decrease troug adultood.

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    FIGURE 1: GhRP-6 transdermal cream (on le) and GhRP-6 soluon for injecon (on rigt)

    Most pepdes are listed under Scedule 7A Item 3 of te Customs (Proibited Imports)

    Regulaons 1956. Furter, under Regulaon 5 of tese Regulaons, Scedule 7Asubstances are classied as proibited imports unless te importer as a permit to

    import issued b te TGA.

    AOD-9604 is a variant of growt ormone wic as fat burning properes and ma be

    used b atletes to increase power to weigt raos b beer ulisaon of fat stores.

    AOD-9604 is about to enter pase tree clinical trials.12 During pase two clinical trials it

    was also found to ave an anabolic eect on carlage ssue and ma promote carlage

    creaon and repair and ave a capacit to enance muscle formaon.13

    AOD-9604 is not currentl a WADA proibited substance.

    Unlike testosterone wic as anabolic and androgenic14 eects, Selecve Androgen

    Receptor Modulators (SARMs) appear to onl act on anabolic receptors tat cause ssue

    (bone and muscle) growt. Tis causes a low tendenc for undesirable androgenic side

    eects wic include te development of male caracteriscs in females and baldness

    and breast ssue development in males (gnecomasa).

    12 Pase III clinical trials involve greater numbers of paents and are undertaken for te purpose of determining

    weter te medicine confers clinical benet in te disease/s for wic eecveness was demonstrated in Pase II

    clinical trials. Te also determine te nature and likeliood of an side eects. Pase III clinical trials are undertaken

    if te Pase II clinical trials indicate te medicine as potenal benet tat outweigs te azards.

    13 Calzada ASX announcement (Calzada) 2012,AOD9604 Shows Posive Results in Carlage and Muscle Repair Models,

    viewed 24 Januar 2013, .

    14 Androgenic side eects of steroid use include acne, musculoskeletal injuries, cardiovascular disease, impaired liver

    funcon and gnecomasa.

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    Te use of SARMs b elite atletes is well documented, wit tese substances believed

    to ave been widel used since at least 2008. Wit te availabilit of suitable standards,

    some SARMs can be detected. SARMs are reported to be used in combinaon wit oter

    PIEDs, including Gh. SARMs are classied as a Scedule 1 (S1)-anabolic agent on teWADA Proibited List and are a proibited substance for elite atletes bot in and out of

    compeon.

    Te sceduling of SARMs was recentl considered b te TGAs Advisor Commiee on

    Medicines and Sceduling, wic determined tat SARMs will be classied as a Scedule

    4 medicine and included in Appendix D in

    te Standard for te Uniform Sceduling

    of Medicines and Poisons (SUSMP) (Te

    Poisons Standard). Tis will make it illegal

    to possess SARMs witout legal autorit(troug prescripon). Tis cange in

    sceduling will take eect on 1 Ma 2013.

    IGF-1 is a ormone secreted b te liver

    and is one of te primar ormones

    necessar for cell growt in te bod.

    Atletes use IGF-1 for its anabolic eect in muscle and to facilitate te development

    of carlage and bone. In man cases, atletes will use Gh and IGF-1 in small doses to

    reduce te cances of returning a posive an-doping sample.

    MGF is derived from IGF-1 and assists ssue repair and adaptaon. It is expressed as

    a pulse following muscle damage (suc as aer weigt training) and is believed to be

    essenal for repair and growt of new cells. MGF is used b bodbuilders due to its role

    in muscle repair following exercise.

    Under te Poisons Standard, IGF-1 possesses te same status as anabolic steroids and is

    a Scedule 4 medicine, wit te addional control tat possession witout autorit is

    illegal (for example possession oter tan in accordance wit a legal prescripon). IGF-1

    and MGF are S2 proibited substances on te WADA Proibited List and are terefore

    proibited for use b professional atletes bot in and out of compeon.

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    Te ACC as idened te use of a range of oter substances b elite atletes,

    bodbuilders and oter users, some of wic are prescripon onl medicines. A

    summar of tese substances is provided below:

    Substance efct Regulatory Status

    Ipamorelin A pepde tat provides a

    possible anabolic eect

    Customs Proibited Import

    S2 of WADA proibited substances

    Sermorelin A pepde tat provides a

    possible anabolic eect

    Customs Proibited Import

    S2 of WADA proibited substances

    Melanotan Tanning agent and aprodisiac Scedule 4 in te Poisons Standard

    PT-141 Tanning agent and aprodisiac Scedule 4 in te Poisons Standard

    Follistan Promotes muscle growt Scedule 4 in te Poisons

    Standard. Addionall, possession

    witout legal autorit is illegal

    S4 (ormone and metabolic

    modulators) of WADA proibited

    substances

    Tmosin (TB-500) Injur recover Not regulated

    S2 of WADA proibited substances

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    A diverse group of individuals as been idened as users of pepdes and ormones.

    however, users can be categorised into tree main groups:

    elite and sub-elite atletes

    bodbuilders

    an-ageing clinic clients.

    Te ACC as also idened te administraon of pepdes and ormones to

    torougbred raceorses, wic is a breac of te Rules of Racing.

    Widespread use of pepdes as been idened, or is suspected b te ACC, in a number

    of professional sporng codes in Australia. Altoug te use of pepdes appears to be

    more widespread in some major codes, individuals from a number of oter sports are also

    suspected of using pepdes.

    Mulple plaers (in one code) from a number of clubs are suspected of currentl using or

    aving previousl used pepdes, wic could constute an an-doping rule violaon.16

    Some plaers ave also been idened as sourcing pepdes for personal use. An instance

    of team-based doping, orcestrated b some club ocials and coacing sta, as also been

    idened.

    Apart from te pepdes anabolic eects, it as been found tat injured elite atletes,

    parcularl plaers from one sporng code, ave been using pepdes to assist in

    reabilitang so ssue injuries.

    Wile te level of suspected use of pepdes varies between sporng codes, ocials

    from one club ave been idened as administering, via injecons and intravenous drips,

    a variet of substances, possibl including pepdes. Moreover, te substances were

    administered at levels wic were possibl in breac of WADA an-doping rules. Tis

    acvit was orcestrated b some club ocials and te clubs ig performance unit.

    Wile intelligence conrms te use of pepdes in major sporng codes, it furter suggests

    tat individuals in a range of oter codes ma also be using pepdes.

    15 For te purposes of tis report, elite atletes are deemed to be tose atletes wo are compeng in a recognised

    major compeon in Australia or wo are represenng Australia or wo are receiving pament and are considered to

    be professional atletes.

    16 Te issue of weter parcular atletes ave commied an an-doping rule violaon will be determined b teformal process wic governs ASADA invesgaons of tis tpe.

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    Apart from te use of pepdes b elite atletes, sub-elite atletes ave also been

    idened as using pepdes and ormones. Sub-elite atletes are considered a ig-risk

    group for doping due to:

    te igl compeve environment in aaining a posion in elite sport

    te abilit to make signicant gains in strengt and power troug te

    use of PIEDs.

    Pepdes and ormones ave been idened as being used at te sub-elite level in a

    number of sporng codes. Given te ease wit wic te various pepdes and ormones

    can be obtained, an movated sub-elite atlete is capable of acquiring and using tese

    substances as illustrated in Case Stud 1.

    Te fact tat PIEDs use is occurring at te sub-elite leveland it is from tese ranks

    tat elite atletes are selectedmeans tere is a treat to te integrit of professional

    sport in Australia.

    On 14 October 2010, Customs and Border Protecon intercepted a

    package from Canada wic contained ten, ve milligram vials of wite

    powder labelled GhRP-6. Subsequent inquiries b ASADA idened te

    addressee as a rugb union plaer in a state club rugb compeon.

    On 28 November 2010, Customs and Border Protecon intercepted apackage from Canada addressed to anoter individual from te same team.

    Tis package contained ve vials of wat was believed to be GhRP-6.

    Altoug it was not able to be establised in te invesgaon, ASADA

    assessed it as possible tat te two individuals wo ad imported tese

    substances were complicit in te importaon of GhRP-6 from Canada, and

    tat oter team members of tese individuals were using GhRP-6.

    Aer an extensive invesgaon b ASADA, te maer was referred to

    te Australian Rugb Union as a potenal an-doping rule violaon. Te

    ARU subsequentl imposed a four-ear ban on one individual for te

    possession and aempted tracking of GhRP-6, and te oter individual

    received a two-ear ban for possession of GhRP-6.

    As demonstrated b tis example, a rigorous and lengt invesgaon is

    undertaken in te administraon of an an-doping rule violaon.

    CASE STUDY 1

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    Wile te use of anabolic steroids b bodbuilders is well establised, pepdes and

    ormones ave become increasingl popular amongst bodbuilders. Given te istorical

    and widespread use of proibited substances in bodbuilding, bodbuilders are oen at

    te cung edge of doping trends.

    Te pepdes, IGF-1, MGF and SARMs ave gained a reputaon amongst te bodbuilding

    communit as being igl eecve anabolic agents and are deemed b bodbuilders

    to ave a number of advantages over steroids. Tis is because users do not experience

    te adverse and well recognised eects of prolonged anabolic steroid use, suc as liver

    damage and disrupon of ormonal producon.

    Similar to online illicit drug forums, te use of pepdes and ormones is te subject of

    extensive discussion in online bodbuilding forums. Users of pepdes and ormones use

    tese online forums to sare informaon on te eects, dosage and administraon of

    tese substances. Individuals are also discussing ow to combine pepdes and ormones

    wit anabolic steroids in stacks17 and ccles in order to increase te development of lean

    muscle, wile minimising te side eects associated wit use of tese substances.

    Case Stud 2 describes te perceived benets of combining use of pepdes and

    anabolic steroids.

    17 Steroids are tpicall used in ccles to reduce te side eects associated wit te disrupon of ormone producon

    due to steroid use. Users of PIEDs also combine mulple substances in order to eigten te eects of steroids andtese combinaons are known as stacks.

    A major side eect of using anabolic steroids in males is te disrupon

    of normal testosterone producon, wic as tpicall required

    individuals to cease using steroids in order to allow te bod to

    recommence te producon of testosterone. however, on cessaon

    of steroid use, individuals tpicall experience a signicant loss of te

    muscle gains tat were acieved troug te use of steroids.

    To maintain teir gains, steroid users tpicall ccle o steroids and

    commence wat is known as a post-ccle terap (PCT). Tis is done

    troug te administraon of a range of drugs suc as Nolvadex, an

    an-estrogen drug, and uman corionic gonadotropin (CG).

    Pepdes ave been idened b bodbuilders as igl eecve

    substances for use in a PCT, tereb allowing individuals to maintain

    muscular gains wile ccling o steroids.

    CASE STUDY 2

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    Individuals involved in bodbuilding, parcularl well known bodbuilders, are plaing a

    ke role in promong pepdes, increasing interest and demand for tese substances in

    te bodbuilding communit and b gmnasium users.

    Growt ormone-releasing pepdes ave become increasingl popular as an an-

    ageing product given te abilit of tese substances to naturall smulate Gh

    producon and address te normall low levels of Gh in older individuals. It is also

    reported tat tese pepdes are proving to be more eecve tan Gh as te

    promote te natural release of Gh as opposed to tradional Gh supplementaon

    terapies. Dedroepiandrosterone18 (DhEA) and testosterone ave also become

    increasingl popular as ormonal treatments to reverse te eects of ageing. 19

    Te use of Gh for an-ageing purposes is considered b te TGA to be o-label,

    meaning tat te drug is used outside te recognised terapeuc uses of te drug.

    Wile Gh and testosterone require a prescripon from a medical praconer,

    no suc requirement currentl exists for te suppl of growt ormone releasing

    pepdes. Consequentl, an-ageing clinics ave become major distributors of pepdes

    around Australia.

    Recentl, te American Associaon of Clinical Endocrinologists20 updated teir clinical

    guidelines for te use of Gh in clinical pracce following concerns about wat te

    Associaon called te unetical aspects of Gh terap for atletes and ageing

    individuals. Tese guidelines strongl recommend tat under no circumstances sould

    Gh be prescribed unless te paent as a clearl dened medical condion (suc as

    stunted growt), and tat Gh sould not be administered oter tan in accordance

    wit te approved uses of Gh.

    Te an-ageing industr bot overseas and in Australia as expanded signicantl in

    recent ears, in line wit te increasing range of an-ageing products being released

    onto te market.

    18 DhEA is a steroid ormone produced in te bod. It funcons as an endogenous precursor to more potent androgens

    suc as testosterone.

    19 Bross, R, Storer, T, Basin, S 1999, Ageing and Muscle Loss, Trends in Endocrinology and Metabolism, vol.10 (5),

    pp.194-198.

    20 Specialising in endocrinolog, diabetes, and metabolism, te American Associaon of Clinical Endocrinologists is a

    professional communit of psicians commied to enancing te abilit of its members to provide ig qualit

    paent care.

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    Te ACC as idened increasing interest in te administraon of pepdes to

    torougbred raceorses for te same reasons tat tese substances are used on

    umansinjur reabilitaon and to promote recover. Tese substances are proibited

    for use on raceorses, and altoug it is suspected tat pepdes are being administered to

    raceorses te extent of use across te industr is te subject of ongoing inquiries.

    Available data, including border seizures of PIEDs, naonal arrests for steroids and drug

    injecng data, all suggest tat te PIEDs market is expanding considerabl in Australia.

    however, in contrast to te amount of researc and knowledge tat exists on illicit drug

    use, formal academic researc into te use of PIEDs and te PIEDs market in Australia is

    extremel limited. Tis makes it dicult to quanf te size of and idenf canges in

    te PIEDs market.

    Furter researc and consideraon of te establisment of ke indicators to idenf

    canges in te Australian PIEDs market would assist in addressing tis current gap.

    An increase in te use of PIEDs is likel to result in te increased prevalence of injecon,

    as tis is te principal route of administraon of anabolic steroids and ormones.

    Increased levels of injecon ave alread been idened in te latest Needle Sringe

    Program (NSP) Surve, wic reported tat wile relavel small proporons of

    respondents reported last injecng PIEDs, a signicant increase in prevalence occurredover te period 2007 to 2011. Among males wo were new to injecng,21 more tan alf

    (53 per cent) reported last injecng PIEDs.22

    21 New to injecng is dened b te NSP stud as individuals wo ave been injecng for less tan 3 ears.

    22 Universit of New Sout Wales (UNSW) 2012,Australian NSP Survey: Naonal Data Report 20072011,

    UNSW, Sdne.

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    As illustrated in Figure 2, a igl organised network of individuals and companies are

    involved in te acquision and distribuon of pepdes and ormones. Tese include:

    on-line suppliers

    an-ageing clinics

    medical praconers

    compounding parmacies

    sports sciensts and ig performance sta

    sports supplement suppliers.

    FIGURE 2: Suppl cain from primar suppliers of pepdes and ormones troug

    to consumers

    Te suppl base to sasf increasing domesc demand for PIEDs is broad. PIEDs can be

    easil acquired from a multude of online stores based in Australia and overseas. Online

    stores oer a compreensive range of PIEDs, including anabolic steroids, DhEA, Gh,

    SARMs, IGF-1 and pepdes. however, as is te case wit anabolic steroids sold online,

    te qualit is potenall unreliable as te source of te products cannot be veried.

    hig performance

    coaces/sports sciensts

    Compounding

    Parmacists

    Cinese Bio-Cemical

    suppliers

    Parmaceucal

    Manufacturers

    Supplement SuppliersSub-elite/Recreaonal

    Atletes

    On-line suppliers

    (Domesc and Internaonal)Elite Atletes

    Medical Praconers Bodbuilders

    An-Ageing clinics

    (onsite Drs and

    osite Drs)

    Ageing clients

    Primar Sources Consumers

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    An example of te range of pepdes, ormones and oter substances available

    online is provided below (substances wic are currentl sceduled b te TGA are

    sown in italics):

    CJC-1295

    Follistan 344

    GhRP-2

    GhRP-6

    hexarelin

    HGH Frag 176-191

    IGF DES (1-3)

    IGF-1 LR3

    Ipamorelin

    Melanotan II

    MGF

    Modifed GRF 1-29

    PEG-MGF

    Tmosin Beta 4 (TB-500).

    Products are adversed in a manner to aract a number of user markets, including:

    strengt enancement/muscle enancement

    an-ageing

    fat loss

    injur reabilitaon

    libido enancement

    growt ormone decienc.

    A number of websites selling pepdes also oer oter prescripon onl drugs wic

    target te PIED user market, suc as aromatase inibitors. Tese inibitors are used in

    te treatment of breast cancer, but are also used to counter gnecomasa, wic is a

    side eect of anabolic steroid use.

    Te popularit of online stores as a source for pepdes and ormones is reected in

    te signicant increase in border detecons of ormones, wic increased 255 per cent

    between 200910 and 20102011.

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    Figure 3 illustrates te number of users and potenal users of pepdes and ormones

    using te internet to searc for informaon on tese substances. It also illustrates te

    ig level of interest in tese substances b Australians.

    FIGURE 3: Searces on Google using te term GhRP between Januar 2007 and Januar

    2013 sowing volume of searces, countries from wic searces emanate and related

    searces conducted.

    Notwitstanding te diverse sources of suppl for pepdes, te number of permits

    issued b TGA to allow lawful importaon is ver low. In parcular, data obtained fromte TGA indicates tat naonall no permits for te importaon of CJC-1295 or GhRP-6

    were issued in 2012 and tat in total onl six permits currentl exist for te importaon

    of CJC-1295, eleven permits for GhRP-2 and tree permits for GhRP-6.

    Some an-ageing clinics ave been idened b ASADA, te ACC and oter partner

    agencies as a major source of pepdes, ormones and oter PIEDs, due to teir capacit

    to suppl parmaceucal qualit WADA proibited PIEDs directl to atletes, in some

    cases witout a prescripon.

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    An-ageing clinics are selling a wide range of PIEDs including testosterone, anabolic

    steroids, Gh, pepdes, IGF-1, MGF and SARMs. Some of tese clinics ave been

    idened as aving links to organised criminal idenes.

    Atletes and bod builders ave previousl been idened b ASADA as using

    an-ageing clinics to acquire testosterone, Gh and anabolic steroids. As man of

    tese substancessuc as testosterone and Ghrequire a prescripon from a

    medical praconer, complicit doctors ave been idened providing prescripons

    to clients of an-ageing clinics, even if tere is no medical reason for te prescribing

    of tese substances and te ave ad no contact wit te paent or access to teir

    medical records.

    In man cases, an-ageing clinics are markeng teir services directl to atletes b

    oering services suc as ormone proling and ormone based training regimes to

    enance atlec performance.

    Te an-ageing industr bot overseas and in Australia as expanded signicantl in

    recent ears, in line wit te increasing range of an-ageing products being released

    onto te market.

    Some medical praconers ave been idened as one of te ke conduits troug

    wic individuals are obtaining PIEDs, in parcular testosterone, Gh, CJC-1295, GhRP-6

    and SARMs.

    Some medical praconers wo advocate te benets of pepdes and ormones for

    an-ageing treatment and/or are working from an-ageing clinics, appear to be te

    primar prescribers of te various pepdes and ormones used b elite and sub-elite

    atletes and bod builders for teir performance and image enancing eects.

    Te ACC idened doctors wo ave dispensed Gh directl to paents witout a

    prescripon, wic is illegal, or troug a parmac owned b tese doctors. In tese

    instances, no prescripon or record of te dispensed Gh was recorded.

    Te ACC also idened lax and fraudulent prescribing pracces b some doctors wit

    links to sporng clubs and an-ageing clinics. Tese pracces include wring scripts

    in false names, providing prescripons witout consulng te paent and prescribing

    ormones witout conducng te necessar blood tests normall carried out prior

    to te prescripon of tese substances. Some of tese doctors are also implicated

    in experimenng on plaers, b providing tem wit dierent substances in order to

    determine te eects on teir performance.

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    Te ACC as idened tat an-ageing clinics, supplement suppliers and

    online stores in Australia are sourcing pepdes and ormones troug domesc

    compounding parmacies.

    As opposed to standard parmacies, wic dispense prescripon medicines and

    terapeuc agents, compounding parmacies provide a range of services in relaon to

    parmaceucals suc as:

    altering or liming te dose of a medicine

    canging te psical form of a medicine (for example modifing a pill into a

    srup or gel)

    suppling compound drugs tat ave been disconnued or are no

    longer available.

    Compounding parmacies are a principal domesc source of pepdes and ormones

    given teir capacit to produce medicines and parmaceucal compounds tat are not

    readil available or commerciall produced. Given teir abilit to manufacture various

    an-ageing medicines, compounding parmacies pla a ke role in te dispensing of

    substances prescribed b or distributed troug an-ageing clinics.

    Based on available informaon, compounding parmacies producing pepdes are

    predominantl sourcing teir raw materials from wolesalers based in Cina.

    Te standard of compeon at te elite level of sport as reaced a point were

    winning margins are now measured in undredts of a second. Tere is an ever-

    increasing focus on te science of sport in order to ensure tat atletes perform at

    te igest possible standard and gain an possible compeve advantage. Remaining

    compeve at te elite level is now dependent on access to te best sports sciensts

    and use of te latest tecnolog.

    Informaon provided to te ACC suggests tat in Australian football codes, sports

    sciensts ave gained increasing inuence over decision making witin te clubs. Someof tese sciensts are plaing a crical role in pusing legal and regulator boundaries in

    relaon to sport supplementaon programs and medical treatments given to plaers.

    Wile it appears tat te majorit of ig performance sta, sports sciensts, coaces

    and medical advisors adere to an-doping codes, it is also clearinternaonall and

    domescalltat some of tese individuals are plaing a crical role in pusing beond

    te boundar of wat is permied b WADA. Tis was parcularl evident in te use of

    PIEDs b Lance Armstrong and is ccling teammates, were parcular doctors plaed a

    crical role in te development and implementaon of te doping program.

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    Te ACC as idened specic ig-performance sta, sports sciensts and

    coaces witin some codes wo ave condoned and/or orcestrated te administraon

    of proibited substances, and substances not et approved for uman consumpon,

    to plaers.

    In some cases, pepdes and oter substances were administered to plaers witout

    tem understanding te nature of te substances, and witout te knowledge of te

    team doctor or club medical sta.

    CASE STUDY 3

    Te United States An-Doping Agenc (USADA) invesgaon into doping

    b te American United States Postal Service and Discover Cannel

    Ccling teams found overwelming evidence tat Dr Micele Ferrari

    facilitated and orcestrated te sopiscated doping program for tese

    teams.

    Dr Ferrari provided tecnical advice to professional cclists on te use

    of PIEDs and blood doping and designed doping programs tat riders

    would follow in order to acieve te largest possible performance

    enancement witout returning a posive an-doping result.

    Dr Ferrari ad a long istor of working wit an Italian researcer,

    Franceso Conconi, wo, wile being funded to develop a test for

    Ertropoien (EPO),23 ad also been involved in doping professional

    cclists. Ferraris expert knowledge of EPO and te tests used to detect

    EPO use b professional cclists ad plaed a major role in is abilit

    to provide EPO to cclists and enable te sstemic doping to remain

    undiscovered.

    According to te USADA invesgaon report, Lance Armstrong paid

    Dr Ferrari just over US$1 million between 1996 and 2006 for is services.

    23 EPO is a parmaceucal product wic as been widel used b atletes due to its abilit to

    increase te amount of oxgen carried b te blood, resulng in improved endurance.

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    Te ACC as idened a range of substances tat ave limited to no istor of use

    in umans, are not approved for uman use, or teir use is considered o-label.

    Substances being administered to plaers include:

    afamelanode and melanocte smulang ormone (Melanotan I and II)

    AOD-9604an an-obesit drug currentl going troug uman clinic trials

    Cerebrolsina pepde extract from pig brain wic is used to treat

    alzeimers and stroke vicms

    a form of Interleukin not proibited b WADAused in te treatment of burns

    and inammaon associated wit trauma (some oter forms of Interleukin are

    proibited b WADA)

    TA-65a drug wic acts on a secon of te DNA and is purported to reduce

    ageing at te cellular level

    Actovegincalf blood extract (used b a route of administraon wic is not

    proibited b WADA).

    Wile tese substances are not proibited b WADA, due to a lack of long-term clinical

    studies on te use of tese substances or teir o-label use, teir potenal impact on

    te ealt of plaersbot sort and long-termis unknown.

    Te apparent willingness of some ig-performance coaces, trainers and sports

    sciensts to administer WADA-proibited and experimental drugs and teir advocac

    of o-label substance use, raises concerns over te welfare of plaers wo are being

    administered tese substances and broader issues for sports administrators in Australia.

    It was also idened tat some ig-performance coacing sta ulised medical sta

    from outside teir respecve clubs to administer substances to plaers. In some cases,

    te medical sta administering tese substances were not communicang wit te

    appointed team doctors nor advising team doctors of te treatments or substances

    being administered to plaers. No part appeared to be maintaining compreensive

    medical records in relaon to treatments being given to plaers.

    Witin te Australian sports supplement market, tere is an extensive range of products

    targeted at improving atlec endurance, fat loss, muscle development, draon and

    recover from strenuous training sessions. In man cases, te eecveness of tese

    products is et to be clinicall proven.

    Professional atletes use a wide range of sport supplements to assist wit muscle

    development, fat loss, draon, recover and to support immunit during strenuous

    training periods. In professional sporng teams, supplement programs are developed b

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    sports sciensts, strengt and condioning coaces, team doctors and nutrionists.

    Wile tere are a large number of sports supplement companies tat sell onl legimate

    (non-proibited) sports supplements, a large number of retail and online sports

    supplement stores also sell substances wic are proibited b WADA, prescripon onl

    medicines and proibited imports.

    Some supplement suppliers at te manufacturing, wolesale and retail level are also

    involved in te sale of proibited substances. In some cases, professional atletes ave

    inadvertentl consumed proibited substances due to supplements being contaminated

    at te factor wic was processing bot WADA-proibited and non-proibited

    supplements. In oter cases atletes ave inadvertentl used proibited substances due

    to sports supplements containing undeclared ingredients.

    Te ACC as idened supplement suppliers as a parcular treat to te integrit of

    sport given teir read access to professional atletes and PIEDs.

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    According to te Director General of

    WADA, te inuence of organised crime

    on sport is increasing, wit criminal

    groups involved in te tracking of

    PIEDs also engaged in mone laundering,

    corrupon, matc xing and fraud.24

    Te internaonal presence of organised

    criminal groups in te tracking of

    PIEDs is furter supported b a 2005

    assessment25 wic found tat te PIEDs

    market is extensive and igl organised,

    wit te Italian maa and Russian organised criminal groups just two of te criminal

    groups eavil involved in tracking of PIEDs across Europe.

    Te ACCs Organised Crime in Australia 201126 report idened te widespread use

    of PIEDs b persons from a broad cross secon of te communit and noted tat tedistribuon of PIEDs can be igl protable.

    Troug te ACC and ASADAs analsis of te pepde and ormone market, it is assessed

    tat te Australian PIEDs market is larger and more complex tan previousl assessed.

    Organised criminal groups and individuals are involved in te domesc tracking of

    PIEDs, wit some of tese criminal idenes and groups also engaged in te tracking

    of oter illicit drugs.

    Te ACC considers tat organised criminal idenes and groups will expand teir

    presence in te Australian pepde and ormone market. Tis is based on te ig

    demand for pepdes and ormones, te igl protable nature of te market wit te

    mark-up on pepdes and ormones reportedl up to 140 per cent, and te establised

    presence of organised criminal idenes and groups in te steroid market bot as

    distributors and users of tese substances.27

    24 Alvad, S 2011, WADAs Director General strikes alarm bells against organized crime in sports, Play the Game, 23

    Febraur, viewed 21 November 2011, .

    25 Dona, A 2007, World tracking in doping substances, World An-Doping Associaon, viewed 12 November 2011,

    .

    26 Australian Crime Commission (ACC) 2011, Organised Crime in Australia, ACC, Canberra.

    27 ibid.

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    Te presence of organised criminal idenes and groups in te PIEDs market presents

    a treat to te integrit of Australian professional sport as a direct consequence of

    te increased likeliood of criminal idenes and groups interacng wit professional

    atletes and te potenal exploitaon of tese relaonsips for criminal purposes.

    Relaonsips between atletes and organised crime idenes can be exploited b

    criminals to corrupt te atlete and give a form of social status to te criminal, in te

    same wa tat te steroid market as been used b organised crime to corrupt law

    enforcement ocers.

    Te use of PIEDs b sub-elite atletes as also been idened as an issue of concern b

    te ACC. Overseas experience as demonstrated tat organised criminal groups involved

    in matc xing are increasingl targeng sub-elite atletes due to te ease wit wic

    tese individuals can be bougt, te lower levels of scrun from integrit autories

    at sub-elite compeons, and te potenal long-term value of tese atletes to te

    criminal group. Overseas experience as also demonstrated tat criminal idenes and

    groups will invest ears developing suc relaonsips, wit te ulmate aim of aving

    te atlete parcipate in acvies suc as matc xing.

    Te ACC as idened an increasing number of associaons of concern between

    professional atletes and organised criminal idenes in Australia. Te ACCs 2011

    assessment ofThreats to the Integrity of Professional Sport in Australia, noted tat as

    te amount of mone wagered on sports increases, associaons wit atletes or oter

    individuals wit te abilit to inuence a sporng contest, or provide inside informaon,

    will be increasingl sougt aer.

    Te ACC as idened a number of issues tat pose a current treat to te integrit of

    professional sport in Australia. Tese treats relate to:

    organised criminal inltraon of unregulated markets28

    inltraon troug legimate businesses, contractors and consultants

    illicit drug use and criminal associaons

    diering levels of integrit oversigt in professional sport in Australia.

    28 Unregulated markets are were tere is no specic legislaon or exisng legislaon wic is open to legal interpretaon.

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    In recent ears, te ACC as idened tat criminal groups and entrepreneurial

    individuals are increasingl exploing new and emerging unregulated drug markets.

    Entrepreneurial individuals and criminal groups are exploing tese markets b

    capitalising on te meframe between wen a substance is idened b regulator

    autories as being armful, and te subsequent regulaon of tat substance, wic

    in some cases is considerable. Tis is most clearl demonstrated in te drug analogue

    market, were manufacturers and vendors connue to release pscoacve substances

    tat are not et regulated.

    Tese same vulnerabilies are being exploited in relaon to pepdes and ormones,

    wic in some cases are not et approved for uman use et are widel available.

    Strategies ulised b individuals idened b te ACC as being involved in te

    distribuon of pepdes and ormones include:

    te establisment of a researc bod to obtain pepdes and ormones from a

    compounding parmac

    te use of an-ageing clinics to distribute tese substances

    te recruitment of complicit doctors to write prescripons for controlled

    parmaceucals, suc as Gh

    te role of a sports scienst wo beneted nanciall from te sale of pepdes

    and ormones; advocated teir use and directed teir applicaon at a number

    of sporng clubs, even toug e was not medicall qualied.

    It is clear tat deliberate strategies ave been emploed b te PIEDs suppliers and

    distributors to facilitate te acquision and suppl of tese substances and circumvent

    exisng regulaons around te suppl of substances wic are not et approved for

    uman use.

    An assessment of mone laundering troug te football sector in Europe b te

    Financial Acon Taskforce (FATF) found tat, unlike oter businesses, criminals were

    aracted to sport for reasons oter tan protabilit.

    FATF found tat connecons tat criminals seek to make troug sport are

    movated b social presge and tat sport provides a powerful route for criminals to

    become celebries b associang wit famous people and moving upwards in powerful

    circles witin establised societ.29 Tis is parcularl relevant in Australia,

    29 Financial Acon Taskforce, Mone Laundering troug te football sector, Paris, 2009.

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    wit man professional sporng club boards including some of Australias business and

    polical leaders.

    Te ACC as found tat sporng clubs, and professional sports in general, are vulnerable

    to inltraon troug sponsorsip and business relaonsips. Tis is due to te

    ig level of compeon for sponsorsip dollars between and witin te codes, te

    signicant nancial pressure man professional sporng clubs are under, and limited or

    no due diligence conducted on potenal investors and business partners. In essence,

    sporng clubs and codes appear rarel to queson te source of mone being invested

    into teir clubs.

    Te ACC as idened individuals wit

    extensive criminal associaons as being

    in business partnersips wit major

    Australian sporng codes. Te existence

    of suc business relaonsips raises

    concerns over te potenal for tese

    relaonsips to be exploited for criminal

    purposes and demonstrates ow open

    Australian professional sports currentl

    are to inltraon b organised criminal

    idenes and groups troug legimate

    businesses.

    Informaon obtained b te ACC suggests tat illicit drug use b professional atletes

    remains an ongoing issue, wit ocial stascs for illicit drug use witin professional

    sports likel to signicantl understate te extent of actual use. Illicit drug use b

    atletes leaves tem parcularl vulnerable to exploitaon for oter criminal purposes,

    including matc xing and fraud arising out of te provision of inside informaon. Tere

    is also evidence to suggest tat some atletes are suppling oters wit illicit drugs.

    Te use of illicit substances b atletes is likel to be correlated in some cases wit

    te use of WADA proibited substances b tose atletes. Some plaers are allegedl

    using bot PIEDs and illicit drugs, and te risk-taking insncts wic are integral to

    some elite atletes likel explain tis decision. Tere are, owever, some atletes wo

    draw disncons between taking PIEDs and illicit drugs, based on personal opinions

    and biases and in man cases on an evaluaon of te likeliood of te acvit being

    detected.

    A number of sports conduct tesng on plaers for illicit drugs and maintain policies to

    deal wit posive illicit drug tests, owever evidence suggests tat loopoles exist and

    are being exploited b plaers seeking to avoid tesng and detecon.

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    Sporng codes emplo a wide range of individuals wo ave te capacit to inuence

    te outcome of a game, or ave access to inside informaon wic can be used to gain

    an unfair advantage in beng markets. For example, a mid-er Australian Football

    League (AFL) club as 99 sta to support te rst grade plaers. Apart from full-me

    posions at clubs, individuals wit specic skills sets or knowledge, suc as sports

    sciensts, are used on a contract basis.

    Codes of conduct are used b te sports governing bodies to ensure plaers conform to

    relevant rules and expected beaviours. More recentl, codes of conduct are being used

    to proibit plaers and oter individuals involved wit atletes, suc as coaces and

    support sta, from wagering and to reduce te risk of contrived results and te use of

    inside informaon in beng markets.

    In deciding wo is required to adere to a code of conduct, it is generall recognised tat

    te net sould be cast wide to capture all individuals wo ave access to plaers and

    knowledge of team acvies. however, te status of contractors and consultants, and if

    te are captured under a code of conduct, remains unclear to sports governing bodies.

    Te AFL, wic as a progressive integrit management framework, as

    aempted to address tis risk b requiring contractors and consultants to provide

    teir personal details to te sports integrit unit, as all oter club ocials and plaers

    are required to do.

    however, tis informaon is onl obtained if te integrit unit becomes aware tat an

    individual is working at a club on a contract basis, or te club provides tis informaon.

    Te ACC as found tat if a club neglects to formall disclose tis informaon, it would

    be igl unlikel tat a specic contractor would come to te noce of te sports

    governing bod.

    Due to te igl sopiscated nature of doping, specic skills and knowledge are

    required to ensure atletes obtain te greatest possible benet witout returning

    a posive an-doping sample. Overseas experience as illustrated te fundamental

    role contracted sports sciensts and medical professionals pla in sopiscated

    doping programs, as was most clearl demonstrated in te case of Dr Ferrari and is

    involvement wit Lance Armstrong.

    As stated previousl, sports sciensts can pla a crical role in taking training programs

    and te preparaon of atletes to te edge of, and somemes beond, wat is

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    permied b WADA. As professional sports become increasingl complex and reliant on

    sports sciensts and oter individuals wit specialist skill sets, tese individuals will pose

    a treat to te integrit of professional sport in Australia due to:

    te specialist skills of tese individuals, in parcular medical doctors and

    individuals wit knowledge of PIEDs

    te access to and increasing

    inuence contractors suc as

    sports sciensts ave on internal

    mecanisms and decisions

    related to te training and

    preparaon of professional

    atletes

    te idened involvement of

    consultants and contractors in

    sopiscated doping programs

    overseas and now Australia

    te limited visibilit of tese

    individuals to integrit ocers and units.

    Te extent of integrit measures varies signicantl between te sporng codes inAustralia, including between codes wic form te basis of substanal wagering

    markets. Integrit management in professional sport in Australia is onl as strong as

    te weakest link across te broader sports industr. Te lack of eecve integrit

    management in some sporng codes creates a ig level of vulnerabilit for te broader

    industr. It is assessed tat individuals wo pose a treat to te integrit of sport in

    Australia are capable of targeng tose codes wit minimal integrit management

    sstems in order to inltrate te broader industr.

    Caracteriscs of te sports industr wic exacerbate tis treat are te propensit

    for sporng codes to recruit from witin te broader sporng industr, te ig level ofinterconnectedness witin and across professional sports, and te connual movement

    of individuals witin and between sporng codes.

    Tis is parcularl te case in te football codes, were plaers and coaces move to

    new teams on a regular basis.

    Te treat of unetical individuals moving between codes is greatest in relaon to

    individuals wo ave transferrable skills/knowledge, parcularl administrators, coaces,

    ig performance coaces and sports sciensts.

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    Te ACC as found, on te basis of a limited and focused examinaon of one componentof te PIEDs market, tat te market as evolved signicantl in recent ears to include

    pepdes and ormones. Tese substances, wic are WADA-proibited, are being

    used b professional atletes in a number of sports in Australia, wit widespread use

    idened or suspected in a number of professional sporng codes. Organised crime

    as been found to ave a tangible and expanding footprint in tis market, and teir

    acvit is being facilitated b some coaces and support sta of elite atletes, wo ave

    orcestrated and/or condoned te use of proibited substances and/or metods of

    administraon.

    Te PIEDs market does not rival te establised markets for metlampetamine,cocaine or eroin in terms of te risk and arms te pose to te Australian communit,

    but it does currentl, and as te potenal to increasingl pose arm to te sector and

    te broader communit out of all proporon to te relave size of te market. Tis is

    because of te special status of sport for Australia and Australians, and te enduring

    signicance of concepts suc as fairness and integrit in Australian sport. Moreover,

    unlike te more establised illicit drug markets, tis parcular treat as been idened

    at a me wen it is sll possible for a coordinated response to get aead of te game,

    to disrupt te expanding organised crime presence in professional sports and to arden

    te sports sector to make it less vulnerable to inltraon b organised crime.

    Tere are clear parallels between wat as been discovered in Australia and te USADA

    invesgaon into Lance Armstrong, wic underlines te transnaonal treat posed

    b doping to professional sport, bot from a fair pla perspecve and as a broader

    integrit issue.

    It is also clear from te ndings of tis project, te USADA invesgaon and previous

    ig prole doping cases in Europe and te United States,30 tat it is not onl atletes

    wo are involved in doping, but atlec support sta, organised criminal groups and

    complicit doctors.

    In te European Unions most recent Wite Paper on Sport in 2007,31 it was

    recommended tat te gt against doping sould not onl target atletes, but also

    tose involved in tracking tese substances, as is te case wit illicit drugs.

    30 BALCO and Operaon Puerto.

    31 European Commission (EC) 2007, White Paper on Sport, Brussels, viewed Januar 29 2013, .

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    It is clear tat te global tracking and use of PIEDs is a complex, large and igl

    protable market. Wile some elite atletes, ig performance coaces, doctors and

    sports industr insiders are involved in sopiscated doping programs driven b te

    need to enance performance wile defeang an-doping controls, it is also clear tat acomplex suppl and distribuon network exists to sasf te ig demand for anabolic

    steroids, pepdes and ormones b sub-elite and recreaonal atletes, bod builders

    and increasingl, ageing Australians.

    Te ACC as demonstrated troug tis project tat te treat posed b te PIEDs

    market and related criminal acvies to te integrit of sport in Australia, and organised

    crime aempts to inltrate te professional sports sector in tis countr, exibits man

    of te caracteriscs idened in te USADA invesgaon of Armstrongs acvies

    in te mid-1990s to mid-2000s. Te dierence is tat te Australian treat is current,

    crosses sporng codes and is evolving.

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    Pepdes is a generic name given to an group of amino acids tat are linked togeter to

    form a cain. Essenall, te are similar to proteins, toug in muc sorter lengts (less

    tan 50 units long). In te world of sport, pepdes generall refer to one of two tings:

    eiter broken protein fragments from drolsed proteins; or pepde ormones and

    related compounds.

    Protein pepdes are wole proteins tat are broken down into smaller pepde fragments

    b a process of drolsis. hdrolsed proteins are absorbed muc faster tan oter forms

    of protein and are commonl found in supplements tat contain drolsed we protein.

    A pepde ormone is a protein wic is released in te blood stream. Usuall, te pepde

    ormone is secreted b te pituitar gland. Pepde ormones include growt ormone

    and insulin. Te substances involved in tis case smulate te producon of pepde

    ormones, wic is dierent to substances tat mimic te eects of pepde ormones

    suc as somatropin (a sntec uman growt ormone).

    Te substances idened as being used in Australia are GhRP-2, GhRP-6, CJC-1295,

    AOD-9604 and exarelin. An overview summar of tese substances is provided below:

    GhRP-2 and GhRP-6 are growt ormone-releasing factors and are terefore proibited

    S2 hormones and Related Substances according to te WADA Proibited List. Te are

    part of te growt ormone-releasing pepde (GhRP) famil, wic includes GhRP-1,

    GhRP-2, GhRP-4, GhRP-6, alexamorelin, ipamorelin and exarelin. GhRPs are used to

    smulate te release of Growt hormone (Gh) b te pituitar gland. Te also promote

    food intake b smulang unger and aid in energ metabolism.

    Purported benets of using GhRPs include bone mineral densit, increased lean muscle

    mass, improved strengt, rejuvenaon and strengtening of joints and improved

    recover from injur suc as bone fractures. Side eects from te use of GhRP ma

    include ot uses, loud stomac rumbling, wite blood cell count increase, sweang

    and increased appete.

    GhRP-2 and 6 are administered b subcutaneous injecon. GhRP-2 and GhRP-6 are

    detectable in urine.

    CJC-1295 is considered a growt ormone-releasing factor and is terefore considered

    to be proibited according to te WADA Proibited List in te S2 categor (Pepde

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    ormones, growt factors and related substances). CJC-1295 is a sntec pepde

    ormone, similar in structure to GhRh, wic smulates te release of growt ormone,

    and subsequentl IGF-1, from te pituitar gland. CJC-1295 was iniall developed to

    treat tose suering from growt disorders, muscle wasng diseases or burns vicms.however, CJC-1295 is not approved for uman use.

    CJC-1295s purported anabolic eects ma increase lean muscle mass, reduce fat

    and improve performance. In addion, CJC-1295 as an-inammator properes if

    administered directl to te related area soon aer injur, can reduce pain and swelling

    and also assist in te repair of injured ssue. It is also purported to promote slow wave

    sleep (SWS) wic is responsible for te igest level of muscle growt and memor

    retenon. Furter benets include reduced bod fat, increased energ and vitalit,

    increased endurance, accelerated ealing, and strengtening of te eart.

    CJC-1295 is administered b subcutaneous injecon, usuall in te abdomen. It is also

    available as a cream.

    AOD9604 is not currentl proibited under categor S2 of te WADA Proibited List.

    AOD9604 works b mimicking te wa natural Gh regulates te metabolism of fat b

    smulang lipolsis (te breakdown or destrucon of fat) and inibits lipogenesis (te

    transformaon of non-fat food materials into bod fat). Reports b Caldaza Ltd ave

    sown tat AOD9604 ad posive (anabolic) eects on carlage ssue formaon as well

    as enancements in te dierenal of muscle progenitor cells (cells tat create muscle

    cells) to muscle cells. Oter purported benets of AOD9604 include increasing muscle

    mass and IGF-1 levels. AOD-9604 is not approved for uman use.

    hexarelin is considered a growt ormone releasing factor and is terefore proibited

    under categor S2, hormones and Related Substances, according to te WADA

    Proibited List. As wit GhRP-6, exarelin smulates te release of Gh, wit eects

    similar to tose experienced wen using a sntec growt ormone.

    Purported benecial eects of exarelin use include increased strengt, growt of new

    muscle bres and increases in te size of exisng muscle bres, joint rejuvenaon and

    assistance in ealing. hexarelin ma also be benecial in fat reducon. Unlike

    GhRP-6, tere is no eect on appete as it does not increase grelin levels responsible

    for increased unger and gastric empting.

    hexarelin can be administered orall in tablet form or via subcutaneous injecon.

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    Su

    bstance

    SportStatus

    Detectable

    SchedulingStatus(SUSM

    P)

    BorderStatus

    Pe

    pdes

    GhRP-2

    GhRP-6

    Proibited-S2

    WADAProibitedList

    yes-Complex

    Unsceduled

    Scedule7ACustoms

    (ProibitedImports)Reg

    ulaons

    CJC-1295

    Proibited-S2

    WADAProibitedList

    yes-Complex

    Unsceduled

    Scedule7ACustoms

    (ProibitedImports)Reg

    ulaons

    hexarelin

    Proibited-S2

    WADAProibitedList

    yes-Complex

    Unsceduled

    Scedule7ACustoms

    (ProibitedImports)Reg

    ulaons

    AOD-9604

    Notcurrentlproibited

    N/A

    Unsceduled

    Scedule7ACustoms

    (ProibitedImports)Reg

    ulaons

    SA

    RMs

    ProibitedS1WADAProibitedList

    yes-Complex

    TobeScedule4intePoisons

    StandardMa2013

    Scedule8Custom

    (ProibitedImports)Reg

    ulaons

    IG

    F-1

    Proibited-S2

    WADAProibitedList

    yes-Complex

    Scedule4intePoisonsS

    tandard.

    Addionall,possessionwitout

    autoritisillegal

    Scedule7ACustoms

    (ProibitedImports)Reg

    ulaons

    M

    GF

    Proibited-S2

    WADAProibitedList

    yes-Complex

    Scedule4intePoisonsS

    tandard.

    Addionall,possessionwitout

    autoritisillegal

    Scedule7ACustoms

    (ProibitedImports)Reg

    ulaons

    G

    h

    Proibited-S2

    WADAProibitedList

    yes-Complex

    Scedule4intePoisonsS

    tandard.

    Addionall,possessionwitout

    autoritisillegal

    Scedule7ACustoms

    (ProibitedImports)Reg

    ulaons

    T

    mosin

    Subjecttote

    formused

    N/A

    Unsceduled

    Currentlunregulated

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    humn gowt rlin Ppd

    human growt releasing pepdes suc as CJC-1295 and GhRP-6 smulate

    an increased level of uman growt ormone (Gh). Te main pepdes

    idened as being used troug Project Aperio were CJC-1295 and GhRP-6

    Liquid (injected)

    Cream (applied to skin)

    Powder (mixed wit saline and injected)

    Not approved for uman use, currentl unsceduled

    Scedule 7A Customs (Proibited Imports) Regulaons

    Proibited bot in and out of compeon

    Detectable in urine but complex

    Growth Hormone Variants

    AOD-9604 (stands for An Obesit Drug number 9604) was idened in

    Project Aperio as being used b professional atletes. AOD-9604 is an

    experimental drug tat is in a growt ormone variants tat as fat burning

    properes and ma be used b atletes to increase power to weigt raos

    b beer ulisaon of fat stores. Atletes ma also use it to reabilitate so

    ssue injuries.

    Liquid (injected)

    Cream (applied to skin)

    Not et approved for uman use, about to enter te nal pase of clinical

    uman trials

    not a border controlled drug

    not currentl proibited

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    Insulin Like Growth Factor (IGF-1) and Mechano Growth Factor (MGF)

    IGF-1 is a ormone secreted b te liver and is one of te primar ormones

    necessar for cell growt in te bod. IGF-1 is used b bodbuilders and

    atletes due to its anabolic eect.

    MGF is derived from IGF-1 and assist ssue repair and adaptaon. MGF is

    used due to its reported abilit to facilitate muscle repair following exercise.

    Liquid (injected)

    Scedule 4 on te Poisons Scedule prescripon onl

    Possession witout legal autorit (a prescripon) is illegal.

    Scedule 7A Customs (Proibited Imports) Regulaons

    Proibited bot in and out of compeon

    Is detectable but complex

    slcv andon rcpto Modulto (sarM)

    Also known as Ostarine, Enobosarm

    SARMs are used to treat a range of medical condions or assist in te

    management of illnesses suc as cancer b reducing muscle wasng. SARMs

    enance te bods abilit to ulise testosterone.

    It is suspected tat SARMs are being used b professional atletes due to

    teir anabolic eect.

    Liquid (injected)

    Cream (applied to skin)

    To be a Scedule 4 on te Poisons Scedule prescripon onl medicine in

    Ma 2013

    Possession witout legal autorit (a prescripon) is illegal from Ma 2013

    Scedule 8 Customs (Proibited Imports) Regulaons

    Proibited bot in and out of compeon

    Some SARMs are currentl detectable

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    ACC Australian Crime Commission

    AFL Australian Football League

    ASADA Australian Sports An-Doping Autorit

    ASC Australian Sports Commission

    Customs and Border Protecon Australian Customs and Border Protecon Service

    FATF Financial Acon Taskforce

    Gh Growt hormone

    GhRP Growt hormone Releasing Pepde

    Gh human Growt hormone

    IGF-1 Insulin Growt Factor 1

    MGF Mecano Growt Factor

    NSP Needle Sringe Program

    PIEDs Performance and Image Enancing Drugs

    Poisons Standard Standard for te Uniform Sceduling of Medicines and Poisons

    S1 Scedule 1 (to te WADA Proibited List)

    S2 Scedule 2 (to te WADA Proibited List)

    S4 Scedule 4 (to te Standard for te Uniform Sceduling of Medicines and Poisons)

    SARMs Selecve Androgen Receptor Modulators

    TGA Terapeuc Goods Administraon

    USADA United States An-Doping Agenc

    WADA World An-Doping Agenc

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