The Rodchenkov Act: U.S. Criminal Law Reaches Into Global Doping

Timeline

1. Oct 22, 2019The House of Representatives passes the Rodchenkov Anti-Doping Act.
2. Nov 16, 2020The Senate passes the Act.
3. Nov 17, 2020WADA says the Act's extraterritorial reach will undermine the global fight against doping and questions the exclusion of U.S. pro and college sports.
4. Dec 4, 2020President Trump signs the Act into law.
5. Mar 1, 2021China's new criminal penalties for organizing doping take effect, targeting non-athletes.
6. Summer 2021The Tokyo Olympics are held; two athletes supplied by a Texas man test positive.
7. May 2023A Texas supplier pleads guilty, becoming the first person convicted under the Act.
8. Feb 21, 2024The supplier is sentenced to three months in prison and ordered to forfeit $16,410.
9. Jul 2024NPR reports a Justice Department criminal investigation into the Chinese swimmers case; WADA calls it a validation of concerns about the Act.
10. Dec 2024–Jan 2025The U.S. withholds its 2024 WADA dues; S. 233 is introduced to make the withholding authority permanent.
11. Jun 25, 2025The Senate Commerce Committee approves S. 233 by voice vote.

The ethical issues

• Extraterritoriality: whether one country may criminalize doping conduct that occurs abroad.
• Consistency: the Act protects events governed by the WADA Code but does not reach U.S. leagues that do not follow it.
• Who is punished: athletes are excluded, so the law targets coaches, doctors, suppliers and officials.
• Whistleblowers and cooperation: criminal exposure could deter cooperation with anti-doping investigators.
• Harmonization vs. sovereignty: overlapping national laws could fracture a single global rulebook.

Stakeholders

Stakeholder	Interests & obligations
Clean athletes, including U.S. athletes	Protection from rivals' doping schemes and potential restitution.
Athlete entourage (coaches, doctors, suppliers)	Clarity about criminal exposure.
WADA	A harmonized global system and its own investigative role.
USADA and U.S. law enforcement	Tools to investigate and deter doping networks.
Foreign governments	Sovereignty and protection of their citizens from foreign prosecution.
U.S. professional leagues and the NCAA	Remaining outside the WADA Code and the Act's scope.
Whistleblowers	Protection when exposing doping schemes.

The case

Grigory Rodchenkov ran Russia’s only WADA-accredited laboratory and later helped expose the country’s state-sponsored doping program. He moved to the United States, where, as of 2021, he remained under witness protection. In December 2020, the U.S. enacted a law in his name that gave American prosecutors power to pursue doping conspiracies around the world. It was welcomed by U.S. anti-doping leaders and sharply criticized by the global anti-doping regulator.^[1][2][3]

Background

Rodchenkov directed Moscow’s Anti-Doping Center from 2006 to 2015. A WADA-commissioned Independent Commission concluded in 2015 that he had colluded to conceal positive tests. After moving to the U.S., he described the Russian scheme to 60 Minutes and The New York Times in May 2016, and WADA’s McLaren investigation confirmed many of his allegations, including a state-run scheme to hide positive tests at the 2014 Sochi Olympics.^[3]

U.S. lawmakers concluded that sports sanctions, which bind only those who accept the World Anti-Doping Code, could not reach the officials, doctors and suppliers who orchestrate doping. At a 2018 Helsinki Commission briefing, Rodchenkov’s lawyer urged Congress to pass a “long-arm statute” modeled on the Foreign Corrupt Practices Act. The House report said the new law would “fill an important gap with regard to U.S. law enforcement” and serve as a deterrent.^[3]

The rules and governance

The Act makes it unlawful for “any person, other than an athlete, to knowingly carry into effect, attempt to carry into effect, or conspire with any other person to carry into effect a scheme in commerce to influence by use of a prohibited substance or prohibited method any major international sports competition.” It states plainly: “There is extraterritorial Federal jurisdiction over an offense under this section.”^[1]

A “major international sport competition” is one in which at least one U.S. athlete and three or more athletes from other countries compete, that is governed by the World Anti-Doping Code, and whose organizer receives sponsorship from an organization doing business in the U.S. or compensation for U.S. broadcast rights. Violations carry up to 10 years in prison and fines of $250,000 for individuals or $1 million for organizations, plus forfeiture. The statute of limitations is 10 years. The Act makes restitution to victims mandatory and requires federal agencies to share relevant information with the U.S. Anti-Doping Agency (USADA).^[1]

Because of the Code requirement, U.S. professional leagues and NCAA competitions, which have not signed on to the Code, fall outside the Act, as do U.S. national championships without foreign athletes.^[3]

Passage and the global response

The House passed the bill on October 22, 2019; the Senate followed on November 16, 2020; and President Trump signed it on December 4, 2020.^[1]

WADA said it “maintains its concern.” “No nation has ever before asserted criminal jurisdiction over doping offences that occurred outside its national borders – and for good reason,” it said, warning of “overlapping laws in different jurisdictions that will compromise having a single set of anti-doping rules.” It argued the Act could “impede the capacity to benefit from whistleblowers by exposing them to possible prosecution” and might lead other nations to adopt similar laws, “many of which may be political in nature or imposed to discriminate against specific nationalities.”^[2]

WADA president Witold Bańka focused on the exemption: “We join other stakeholders around the globe in asking why this U.S. legislation, which purports to protect athletes and claims jurisdiction overseas, specifically excludes the hugely popular and influential professional and college leagues. Nearly half a million athletes compete in U.S. college sports, and thousands more in the professional leagues. These leagues were originally included in the Act but were subsequently removed without explanation… If it is not good enough for American sports, why is it being imposed on the rest of the world?”^[2]

The IOC supported the Act’s focus on athletes’ entourages but also criticized the omission of U.S. pro and college sports. USADA and the U.S. Olympic and Paralympic Committee issued brief statements thanking Congress. Weeks after the Act passed, China strengthened its own criminal law to target those who supply athletes with banned substances or organize doping, while excluding athletes, a similar approach to the Rodchenkov Act.^[3]

Experts disagreed about whether the law would work. A Washington and Lee law professor said such laws’ “bark is often way worse than their bite,” because cases need evidence and cooperation from abroad. A Helsinki Commission adviser predicted “real teeth” and “real enforcement.” The U.S. had already charged seven Russian military intelligence officers in 2018 with hacking anti-doping organizations; none had been extradited, illustrating the enforcement challenge.^[3]

The first prosecution

The first case came out of the Tokyo Olympics, held in 2021. According to federal prosecutors in Manhattan, a man who claimed to be a “kinesiologist and naturopathic” doctor in El Paso, Texas, obtained unapproved versions of drugs including human growth hormone and erythropoietin from Central and South America and supplied them to athletes, including two Olympic athletes competing for Nigeria and Switzerland. He discussed the drugs’ “testability” over encrypted messages. Both athletes tested positive, and the supplier advised that they blame contaminated meat.^[4]

He pleaded guilty in May 2023, becoming the first person charged and convicted under the Act. On February 21, 2024, he was sentenced to three months in prison, one year of supervised release and forfeiture of $16,410. “Today’s sentence sends a clear message: violating the Rodchenkov Anti-Doping Act comes with serious consequences up to and including incarceration,” said U.S. Attorney Damian Williams, noting the upcoming Paris Olympics. Prosecutors credited the FBI’s Integrity in Sports and Gaming Initiative and thanked USADA.^[4]

Aftermath

The Act’s reach abroad was soon tested in a far larger dispute. In April 2024, reports revealed that 23 Chinese swimmers had tested positive for the banned heart drug trimetazidine in January 2021 and that WADA had accepted the Chinese explanation of accidental contamination without appeal, so they competed at the Tokyo Olympics.^[6][8] In July 2024, NPR reported that the Justice Department had opened a criminal investigation. The FBI would neither confirm nor deny it, but two international sports organizations confirmed it, and World Aquatics said its executive director had been subpoenaed “by the United States government.”^[6]

WADA said it was “disappointed” and had received no contact from U.S. law enforcement. It said the reports “validate the concerns expressed broadly by the international community” about the Rodchenkov Act, “under which the United States purports to exercise extraterritorial criminal jurisdiction over participants in the global anti-doping system,” and stood by its decision not to appeal.^[5] USADA’s chief executive, Travis Tygart, told a House committee that Russia and China had been “too big to fail” in WADA’s eyes.^[6]

The dispute moved to money. The White House drug policy office withheld the 2024 U.S. dues to WADA, about $3.6 million by USADA’s count; a later Senate committee report put it at $3.7 million. USADA backed the decision, linking it to the same post-Russia reforms that produced the Rodchenkov Act, and said non-payment would not affect U.S. athletes’ eligibility.^[7][8] In January 2025, senators introduced the Restoring Confidence in the World Anti-Doping Agency Act (S. 233), which would require the office to review WADA’s governance every year and give it permanent authority to withhold dues. The Senate Commerce Committee approved it by voice vote on June 25, 2025, and its report was printed in February 2026.^[8]

The El Paso case showed the Act could be used against an entourage member operating from U.S. soil. Whether it can reach foreign officials and doctors abroad, its most ambitious claim, depends on evidence and cooperation that other countries and sports bodies may or may not provide.^[3][4]

The core dilemma

Doping schemes are often run by people beyond the reach of sports sanctions. Criminal law can reach them, and the U.S. has the resources and motive to use it. But when one country asserts jurisdiction over the world’s sport while exempting its own biggest leagues, it invites accusations of hypocrisy and retaliation. Is the Rodchenkov Act a necessary tool for clean sport or a unilateral move that weakens a shared system?

Competing values

• Effective deterrence vs. harmonization: criminal penalties reach the entourage, but overlapping national laws may fracture one rulebook.
• National interest vs. global legitimacy: the U.S. protects its athletes but asserts power over others.
• Consistency vs. political reality: applying the law to U.S. leagues would have faced resistance at home.
• Prosecution vs. cooperation: criminal exposure may pressure suppliers to talk, or deter whistleblowers.

Strongest arguments

For the Act: sports sanctions cannot jail a doctor or a state official. The Russian scandal showed that entire systems can corrupt competitions in which U.S. athletes are cheated. Criminal law, like the Foreign Corrupt Practices Act, can change behavior globally, and the first prosecution exposed a supplier advising athletes on how to evade tests.

Against the Act: unilateral extraterritorial jurisdiction undermines the cooperative system the U.S. helped build and may prompt retaliatory laws. Excluding U.S. pro and college sports, which do not follow the Code, applies a standard to others that the U.S. does not apply to itself.

A middle position: the Act’s core idea of criminalizing doping conspiracies by non-athletes is sound and mirrors laws elsewhere; its legitimacy would be strengthened by bringing more U.S. sport under the Code and by agreed protocols with WADA.

Applying the frameworks

Justice & fairness

A justice lens asks whether rules apply equally. Behind a veil of ignorance, not knowing whether you were an American or foreign athlete, or a U.S. league player, would you accept a law that criminalizes doping schemes abroad but not in the most popular domestic leagues? The exemption is the strongest fairness objection to the Act.

Utilitarian

A utilitarian would ask whether the Act reduces doping overall. If it deters suppliers and organizers, it benefits clean athletes everywhere. If it damages cooperation with WADA and foreign authorities or discourages whistleblowers, it may make doping harder to detect. Early evidence, a single short sentence, is too limited to settle the question.

Rights-based

A rights lens weighs clean athletes’ right to fair competition against the rights of foreign nationals not to be prosecuted by a country whose laws they never agreed to. It also asks about whistleblowers’ rights: those who expose schemes need protection, not new legal jeopardy.

Walk it through: the Simple Decision Model

1. Spot the issue. You are a federal prosecutor in 2022 weighing a Rodchenkov Act case against a foreign coach accused of doping athletes at a world championship in which U.S. athletes competed. Stakeholders include clean athletes, the accused, the coach’s home country, WADA, USADA and potential witnesses. The codes in play are the Act, the World Anti-Doping Code and international law on cooperation.
2. Gather facts. What evidence exists, and where? Is the event covered under the Act’s definition? Can you obtain cooperation and witnesses from abroad? Avoid assuming that jurisdiction on paper means a viable case.
3. Test options. Options: (a) indict; (b) share evidence with sports authorities for disciplinary action; (c) pursue both in coordination with WADA. Weigh deterrence, diplomatic effects and impact on whistleblowers.
4. Check codes and law. Confirm the elements of the offense, the 10-year limitations period and the requirement to share information with USADA.
5. Decide and document. Record the jurisdictional basis and how the case protects, rather than exposes, cooperating witnesses.
6. Communicate and follow up. Explain the case publicly in terms of protecting all clean athletes, and coordinate with international partners.

What’s settled and what’s contested

• Settled: the Act’s text, including its extraterritorial jurisdiction and athlete exemption; its December 4, 2020 enactment; and the El Paso supplier’s guilty plea and three-month sentence.
• Contested: whether unilateral extraterritorial jurisdiction helps or harms global anti-doping; whether excluding U.S. pro and college sports is defensible; and how enforceable the Act is against people abroad.

Why this case matters

The Rodchenkov Act moved doping from a sports offense toward a transnational crime. It raises lasting questions about who governs global sport, how national power and international institutions interact, and whether a country can credibly police the world’s competitions without holding its own leagues to the same standard.

Key terms

Sanction certainty

The principle that the likelihood of being caught and punished deters misconduct more than the severity of the punishment.

Institutional accountability

Structures that make a sport organization explain its decisions and face consequences: clear authority, transparency, appeals, independent oversight and enforcement.

Whistleblowing

Disclosure of wrongdoing in the public interest by someone inside or close to an organization: a moral safety valve.

Codes and guardrails

Written rules of conduct, backed by real consequences, that turn values into expected behavior. Without enforcement they are decoration.

Multiple points of view

Analyzing a dilemma from each stakeholder’s position in turn (athlete, parent, coach, administrator, official, bystander) before reaching your own reasoned view.

Corruption

The misuse of entrusted power for private gain, whether financial, sporting, administrative or cultural.

Definitions from the Ethics Cases glossary.

Discussion questions

1. Is it legitimate for one country to criminalize doping schemes that take place entirely abroad if its athletes compete in the event?
2. WADA's president asked, 'If it is not good enough for American sports, why is it being imposed on the rest of the world?' How would you answer?
3. Should athletes themselves be excluded from criminal liability, as the Act and China's 2021 law provide?
4. Could the threat of criminal prosecution discourage whistleblowers and cooperation? How should the law address that?
5. Does the Act's first case, a three-month sentence for a supplier, suggest the law has 'real teeth' or that its bark is worse than its bite?

Sources

1. Public Law 116-206: Rodchenkov Anti-Doping Act of 2019 — U.S. Government Publishing Office
2. WADA statement on U.S. Senate's passing of the Rodchenkov Anti-Doping Act — World Anti-Doping Agency
3. The Rodchenkov Anti-Doping Act: The United States' Response to the Russian Doping Scandal — Marquette Sports Law Review
4. First Defendant Ever Charged With Violating Anti-Doping Act Sentenced To Prison — U.S. Attorney's Office, Southern District of New York
5. WADA statement regarding U.S. Department of Justice investigation into Chinese swimming case — World Anti-Doping Agency
6. Justice Department opens a criminal probe of the Chinese Olympic doping scandal — NPR
7. Statement from USADA CEO Travis T. Tygart on the U.S. government withholding payment to WADA — U.S. Anti-Doping Agency
8. Senate Report 119-111: Restoring Confidence in the World Anti-Doping Agency Act of 2025 — U.S. Senate Committee on Commerce, Science, and Transportation (GovInfo)