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New Generation Performance and Image Enhancing Drugs and Organised 
Criminal Involvement in their use in Professional Sport

Correspondence should be addressed to: 
Chief Executive Officer 
Australian Crime Commission 
PO Box 1936 Canberra City 
ACT 2601
02 6243 6666 (from within Australia) 
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61 2 6243 6687 (international)
Published February 2013
The information contained in this report is produced by the Australian Crime Commission (ACC).
© Commonwealth of Australia 2013.
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be reproduced by any process without written permission from the Chief Executive Officer, Australian  
Crime Commission.

New Generation Performance and Image Enhancing Drugs and Organised 
Criminal Involvement in their use in Professional Sport

AIM AND SCOPE        5 
Nature of the threat 
The PIEDs market        7 
The role of organised crime 
Use by professional athletes 
The role of sports scientists, coaches and other facilitators     9 
Growth hormone releasing peptides 
Growth hormone variants 
Selective androgen receptor modulators 
Insulin-like growth factors (IGF-1)      15 
Mechano growth factor (MGF) 
Other substances        16 
Elite athletes 
Sub-elite athletes        18 
Anti-ageing clinic clients 
Use on animals 
Monitoring future demand 
Online suppliers        22 
Anti-ageing clinics 
Medical practitioners 
Compounding pharmacies 
Sports scientists and high performance staff 
Administration of untested substances to athletes    28 
Supplement suppliers 

Organised criminal links 
Organised criminal infiltration of unregulated markets 
Infiltration through legitimate business 
Illicit drug use and criminal associations 
Contractors and consultants 
Inconsistent integrity oversight in professional sport 

In 2011, the Australian Crime Commission (ACC) highlighted threats to the integrity 
of professional sport and concluded that there was potential for organised crime to 
infiltrate sport in Australia, as has occurred overseas.
Data from the ACC’s 2010–11 Illicit Drug Data Report indicated that the market for 
Performance and Image Enhancing Drugs (PIEDs) has expanded, with record numbers 
of seizures, detections and arrests and increasing reports by users that they were 
injecting them. The ACC also received information from the Australian Sports Anti-
Doping Authority (ASADA), as part of the ACC’s routine monitoring of all illicit drug 
markets, which suggested a potential threat to a number of sports from the use of new 
generation PIEDs. 
In early 2012, the ACC, with the assistance of ASADA1, began a project to consider the 
extent of use of PIEDs by professional athletes, the size of this market and the extent of 
organised criminal involvement. This project focused particularly on a new form of PIEDs, 
known collectively as peptides and hormones. These substances may provide effects 
similar to anabolic steroids and are considered by users to be next generation PIEDs. 
Some of these substances are perceived by athletes to be undetectable, making them 
attractive to those seeking to gain an unfair advantage.
This report provides a summary of findings from this project. In particular, the ACC has 
now identified use of these substances, which are prohibited by the World Anti-Doping 
Agency (WADA), by professional athletes in a number of sports in Australia. Widespread 
use has been identified or is suspected in a number of professional sporting codes.
In detailing the nature and extent of this threat to the professional sporting industry 
and the Australian Community, this report provides an important opportunity for 
Government, regulatory bodies and the sporting industry to address these issues head on. 
1  The ACC has collaborated with ASADA throughout this project and references to the ACC in this report should be 
understood to imply and reflect the outcomes of this collaboration. As the appropriate regulatory agency, ASADA will 
conduct its own investigation of matters raised by this project.

The project, code named Project Aperio, was a 12-month ACC investigation, supported 
by ASADA and the Therapeutic Goods Administration (TGA), which examined the 
following four key issues:
new generation PIEDs, that were previously considered to be only used by elite 
athletes and are now widely available
the involvement of organised criminal identities and groups in the distribution of new 
generation PIEDs
the use of WADA prohibited substances by professional athletes in Australia
current threats to the integrity of professional sport in Australia.  
Based on intelligence provided to the ACC, Project Aperio primarily considered two 
major sporting codes in Australia and collected incidental intelligence relating to other 
sporting codes. 
This report does not provide a comprehensive summary of all relevant activity of 
concern in all sports, or all sporting clubs and franchises in Australia. Rather it represents 
a snapshot of the activity, derived from the intelligence which formed the original basis 
of the inquiries and the need for the ACC to focus on the role of organised crime in the 
PIEDs market. It is likely, given the level of demand for PIEDs and the diverse sources of 
supply, that the use of WADA prohibited substances is more widespread than identified 
in this report.

Legal provisions prevent the ACC from publicly disclosing detailed information about the 
nature of the matters contained in this report. This includes the disclosure of information 
specifically referencing players, clubs and any information that could identify other 
individuals involved. Particular sporting bodies have received classified briefings on 
matters relevant to them.  
As such, the report focuses on describing the broad nature of the activities, threats and 
vulnerabilities and includes intelligence judgements about the likely future trajectory of 
these issues.

Despite being prohibited substances in professional sport, peptides and hormones are 
being used by professional athletes in Australia, facilitated by sports scientists, high-
performance coaches and sports staff. Widespread use of these substances has been 
identified, or is suspected by the ACC, in a number of professional sporting codes in 
Australia. In addition, the level of use of illicit drugs within some sporting codes is 
considered to be significantly higher than is recorded in official statistics.
The ACC has also identified that organised crime identities and groups are involved in the 
domestic distribution of PIEDs, which includes peptides and hormones. If left unchecked, 
it is likely that organised criminals will increase their presence in the distribution of 
peptides and hormones in Australia.
The ACC has identified significant integrity concerns within professional sports in 
Australia related to the use of prohibited substances by athletes and increasing 
associations of concern between professional athletes and criminal identities.
Further key findings, summarised into relevant topics are outlined below.
The PIEDs market in Australia is large and diverse, with a wide range of substances being 
used by a broad cross-section of the community.  
PIEDs previously considered to only be available to elite athletes and used in 
sophisticated sports doping programs due to the expense and complexity of their 
administration, are now widely available. A highly profitable and organised market has 
been established around the sourcing and supply of new generation PIEDs.  
The growth hormone releasing peptide (herein referred to as ‘peptides’), hormone 
and anabolic steroid markets are assessed by the ACC to be one and the same, with 
individuals trafficking anabolic steroids also distributing peptides and hormones.
Organised criminal identities and groups are active in the trafficking of PIEDs that are 
being used by elite athletes in Australia. Organised crime groups are taking advantage 
of the current legislative and regulatory situation whereby persons and entities who 
supply certain substances to athletes which are prohibited under the WADA Code do not 
commit a crime in Australian jurisdictions. however, athletes who use the substances 
face substantial sporting bans. This is a significant legislative and regulatory vulnerability.

Professional sport in Australia is highly vulnerable to organised criminal infiltration 
through legitimate business relationships with sports franchises and other associations. 
This is facilitated by a lack of appropriate levels of due diligence by sporting clubs and 
sports governing bodies when entering into business arrangements.
There is also increasing evidence of personal relationships of concern between 
professional athletes and organised criminal identities and groups.
The ACC has identified widespread use of 
peptides and hormones by professional 
athletes in Australia. Given that many of 
these substances are prohibited for use by 
athletes by WADA, athletes who use these 
substances have potentially committed 
anti-doping rule violations.
While intelligence confirms the use of 
peptides in major sporting codes, it further 
suggests that individuals in a range of other 
codes may also be using peptides. 
Multiple players across some sporting codes and specific clubs within those codes 
are suspected of currently using or having previously used peptides, which could 
constitute an anti-doping rule violation. The level of suspected use of peptides varies 
between some sporting codes, however officials from a club have been identified as 
administering, via injections and intravenous drips, a variety of substances, possibly 
including peptides. Moreover, the substances were administered at levels which were 
possibly in breach of WADA anti-doping rules.
The use of peptides and hormones is linked to a culture in some professional sports in 
Australia of administering untested and experimental substances to athletes in the hope 
they will provide an advantage in the highly competitive world of professional sport. In 
some instances, the substances are not yet approved for human use.  
In addition to elite athletes using peptides and hormones, these substances are also 
being used by sub-elite athletes competing at various levels of competition, for example 
at the state and club level. 
Illicit drug use by professional athletes is more prevalent than is reflected in official 
sports drug testing program statistics, and there is evidence that some professional 
athletes are exploiting loopholes in illicit drug testing programs.

Some coaches, sports scientists and support staff of elite athletes have orchestrated and/
or condoned the use of prohibited substances and/or methods of administration. 
Sports scientists are now influential in professional sport in Australia, with some of these 
individuals prepared to administer substances to elite athletes which are untested or not 
yet approved for human use. 
In many Australian sporting codes, sports scientists have gained increasing influence over 
decision making within the clubs. Some sports scientists and doctors are experimenting 
on professional sportspersons in an effort to determine if particular substances can 
improve performance without being detected.
Complicit medical practitioners are a key conduit through which peptides and hormones 
are being supplied to athletes and other individuals on prescription. In some cases, 
medical practitioners who are prescribing peptides, hormones and other PIEDs are 
engaging in lax, fraudulent and unethical prescribing practices, such as prescribing 
controlled drugs in false names.
Some anti-ageing clinics have been identified as a key source of supply of pharmaceutical 
grade WADA prohibited PIEDs to athletes, in some cases without prescription. 

Internationally and domestically, sport has become a highly profitable global enterprise. 
Based on the latest available Australian Bureau of Statistics data,2 in 2006 the total 
annual income generated by the sport and recreation industry in Australia was estimated 
at A$8.82 billion, a figure which will have 
grown substantially since then. Apart from 
the direct contribution of sport to the 
Australian economy, there is intangible 
value from the success of Australian 
teams and athletes on the international 
stage and the ability to showcase Australia 
on the international stage when it hosts 
major events. 
The concept of fair play is a key 
foundation for amateur and professional 
sport in Australia. The Essence of 
Australian Sport,3 a document produced last year by the Australian Sports Commission 
(ASC) in consultation with the sports industry, provides a statement on what sport in 
Australia stands for—its core principles and values. 
This document notes: “Australians are proud of their sporting ability and reputation as 
a nation of good sports, and our society expects high standards of behaviour from all 
people involved in sport.”4 
The ACC and ASADA have identified significant issues in professional and sub-elite sport 
in Australia which undermine the principles of fair play as a direct consequence of the 
use of PIEDs. 
The importance of fairness is identified as one of the key principles in The Essence of 
Australian Sport
. The document states that players of sport at all levels should strive to 
uphold the principles of fairness and operate in the spirit of the rules, never taking an 
unfair advantage, and making informed and honourable decisions at all times.  
It goes on to state: “ is vital that the integrity of sport is maintained. The main 
responsibility for this lies with decision makers at every level of sport, who should ensure 
2  Australian Bureau of Statistics (ABS) 2006, Sport and physical recreation services, Australia-2004–05, ABS, Canberra.
3  The Australian Sports Commission (ASC) 2012, The essence of Australian sport, Canberra, n.d., viewed 20 November 
2012, <>.
4  ibid., p.2.

that all policies, programs and services are based on the principles of fairness, respect, 
responsibility and safety.”5
Apart from the potential impact on spectators and their loss of faith in sport arising from 
integrity issues around the use of prohibited substances, the increasing link between 
sports and wagering markets means the issues identified by the ACC and ASADA also 
have major implications for the integrity of sports betting markets. Individuals and teams 
engaged in the use of prohibited substances have an unfair advantage, which can be 
exploited by persons with inside information.
While there is a long history of betting on sports, the market has expanded 
significantly in recent years with growth of up to 13 per cent annually. Betting on 
racing6 remains the largest betting market in Australia, increasing 69 per cent between 
2000–01 and 2010–11. Wagering on other sports increased by 278 per cent over the 
same period.7  
5  ibid., p.2.
6  Racing includes thoroughbred horse racing, and harness and greyhound racing.
7  In 2000–01, of the estimated A$12.8 billion wagered on racing and other sports in Australia, A$880 million was 
wagered on sports other than racing. In 2010–11, A$23.5 billion was wagered on racing and sports in Australia, with 
A$3.3 billion being wagered on sports other than racing; Australian Racing Board Limited 2011, Australian Racing Fact 
Book; A guide to the Racing Industry in Australia, Australian Racing Board, Sydney.

The principal substances identified through Project Aperio as being used were: 
growth hormone releasing peptides (CJC-1295, GhRP-2, GhRP-6 and hexarelin)
growth hormone variants (AOD-9604)
selective androgen receptor modulators (SARMs)
insulin like growth factor (IGF-1) and mechano growth factor (MGF).
For the purposes of this report, these substances will be collectively referred to as 
peptides and hormones. A summary of the legal status and status of these substances in 
professional sport is detailed in Appendix Two.
The Australian PIEDs market has expanded rapidly in recent years. This is evidenced by:
increased border seizures, with the number of PIEDs detected at the Australian 
border rising from 2695 in 2009–10 to 5561 in 2010–11, a 106 per cent 
increase, and the highest recorded number of PIEDs detections at the border in 
the last decade8
an increase of 255 per cent between 2009–10 and 2010–11 in the number of 
hormones detected at the Australian border by the Australian Customs and 
Border Protection Service
the highest number on record of national steroid seizures and arrests in  
2010–11 by Australian law enforcement agencies9
an increasing number of individuals reporting the injection of PIEDs
more than half of the males who were new to injecting in 2011 were reportedly 
injecting PIEDs.10
While anabolic steroids remain the most widely recognised PIEDs, an array of drugs 
that were originally developed for the treatment of medical and hormonal disorders by 
manipulating the body’s hormonal system are now also being used as PIEDs.
8  Australian Crime Commission (ACC) 2012, Australian Illicit Drug Report 2010–11, ACC, Canberra.
9  ibid.
10  University of New South Wales (UNSW) 2012, Australian NSP Survey: National Data Report 2007–2011, UNSW, Sydney.

In recent years, peptides have become increasingly popular among professional 
and amateur athletes, bodybuilders, and as a ‘fountain of youth’ within the 
anti-ageing fraternity.  
Growth hormone releasing peptides stimulate release of an increased level of human 
growth hormone (hGh), which has a history of misuse by athletes and may play an 
important role in muscle and bone growth.  
While peptides can be used on their own to promote muscle growth, these substances 
are also used in combination with anabolic steroids to maintain muscle gains.  
Peptides have become popular with elite athletes given the ability of these substances 
to stimulate hGh production, resulting in possible anabolic effects. Anecdotal reports 
suggest peptides assist in rehabilitating soft tissue injuries. however, both the 
rehabilitative properties and broader benefits of peptides to athletes (who typically have 
higher levels of hGh) are yet to be scientifically proven.  
Peptides are also marketed as an anti-ageing medicine given their ability to increase hGh 
levels and compensate for the natural decline in hGh associated with ageing.11  
From an anti-doping perspective, the ability to detect peptide use is complex, as these 
substances are rapidly metabolised. 
Peptides are classified as a Schedule 2 (S2) prohibited substance on the WADA Prohibited 
List and are therefore prohibited for use by professional athletes both in and out of 
competition. Peptides have been a WADA prohibited substance since at least 2008. 
As noted previously, the principal peptides identified by the ACC and ASADA as being 
misused in both professional sports and the broader population are:
Peptides are sold either as a transdermal cream or in a solution for injection as per the 
examples in Figure 1. As shown in Figure 1, the solution for injection clearly states on the 
label that these substances are ‘For Research Purposes Only’. A comprehensive overview 
of the various peptides currently being used in Australia is provided in Appendix Two and 
Appendix Three.
11  hGh levels peak during childhood and adolescence and then consistently decrease through adulthood.

FIGURE 1: GhRP-6 transdermal cream (on left) and GhRP-6 solution for injection (on right)
Most peptides are listed under Schedule 7A Item 3 of the Customs (Prohibited Imports) 
Regulations 1956. Further, under Regulation 5 of these Regulations, Schedule 7A 
substances are classified as prohibited imports unless the importer has a permit to 
import issued by the TGA. 
AOD-9604 is a variant of growth hormone which has fat burning properties and may be 
used by athletes to increase power to weight ratios by better utilisation of fat stores.
AOD-9604 is about to enter phase three clinical trials.12 During phase two clinical trials it 
was also found to have an anabolic effect on cartilage tissue and may promote cartilage 
creation and repair and have a capacity to enhance muscle formation.13
AOD-9604 is not currently a WADA prohibited substance.
Unlike testosterone which has anabolic and androgenic14 effects, Selective Androgen 
Receptor Modulators (SARMs) appear to only act on anabolic receptors that cause tissue 
(bone and muscle) growth. This causes a low tendency for undesirable androgenic side 
effects which include the development of male characteristics in females and baldness 
and breast tissue development in males (gynecomastia).
12  Phase III clinical trials involve greater numbers of patients and are undertaken for the purpose of determining 
whether the medicine confers clinical benefit in the disease/s for which effectiveness was demonstrated in Phase II 
clinical trials. They also determine the nature and likelihood of any side effects. Phase III clinical trials are undertaken 
if the Phase II clinical trials indicate the medicine has potential benefit that outweighs the hazards.
13  Calzada ASX announcement (Calzada) 2012, AOD9604 Shows Positive Results in Cartilage and Muscle Repair Models
viewed 24 January 2013, <>.
14  Androgenic side effects of steroid use include acne, musculoskeletal injuries, cardiovascular disease, impaired liver 
function and gynecomastia.

The use of SARMs by elite athletes is well documented, with these substances believed 
to have been widely used since at least 2008. With the availability of suitable standards, 
some SARMs can be detected. SARMs are reported to be used in combination with other 
PIEDs, including hGh. SARMs are classified as a Schedule 1 (S1)-anabolic agent on the 
WADA Prohibited List and are a prohibited substance for elite athletes both in and out of 
The scheduling of SARMs was recently considered by the TGA’s Advisory Committee on 
Medicines and Scheduling, which determined that SARMs will be classified as a Schedule 
4 medicine and included in Appendix D in 
the Standard for the Uniform Scheduling 
of Medicines and Poisons (SUSMP) (The 
Poisons Standard). This will make it illegal 
to possess SARMs without legal authority 
(through prescription). This change in 
scheduling will take effect on 1 May 2013.
IGF-1 is a hormone secreted by the liver 
and is one of the primary hormones 
necessary for cell growth in the body.  
Athletes use IGF-1 for its anabolic effect in muscle and to facilitate the development 
of cartilage and bone. In many cases, athletes will use hGh and IGF-1 in small doses to 
reduce the chances of returning a positive anti-doping sample.  
MGF is derived from IGF-1 and assists tissue repair and adaptation. It is expressed as 
a pulse following muscle damage (such as after weight training) and is believed to be 
essential for repair and growth of new cells. MGF is used by bodybuilders due to its role 
in muscle repair following exercise.  
Under the Poisons Standard, IGF-1 possesses the same status as anabolic steroids and is 
a Schedule 4 medicine, with the additional control that possession without authority is 
illegal (for example possession other than in accordance with a legal prescription). IGF-1 
and MGF are S2 prohibited substances on the WADA Prohibited List and are therefore 
prohibited for use by professional athletes both in and out of competition.

The ACC has identified the use of a range of other substances by elite athletes, 
bodybuilders and other users, some of which are prescription only medicines. A 
summary of these substances is provided below:  
Regulatory Status
A peptide that provides a 
Customs Prohibited Import
possible anabolic effect
S2 of WADA prohibited substances
A peptide that provides a 
Customs Prohibited Import
possible anabolic effect
S2 of WADA prohibited substances
Tanning agent and aphrodisiac
Schedule 4 in the Poisons Standard 
Tanning agent and aphrodisiac
Schedule 4 in the Poisons Standard 
Promotes muscle growth
Schedule 4 in the Poisons 
Standard. Additionally, possession 
without legal authority is illegal
S4 (hormone and metabolic 
modulators) of WADA prohibited 
Thymosin (TB-500)
Injury recovery
Not regulated
S2 of WADA prohibited substances

A diverse group of individuals has been identified as users of peptides and hormones. 
however, users can be categorised into three main groups:
elite and sub-elite athletes
anti-ageing clinic clients.
The ACC has also identified the administration of peptides and hormones to 
thoroughbred racehorses, which is a breach of the Rules of Racing.
Widespread use of peptides has been identified, or is suspected by the ACC, in a number 
of professional sporting codes in Australia. Although the use of peptides appears to be 
more widespread in some major codes, individuals from a number of other sports are also 
suspected of using peptides. 
Multiple players (in one code) from a number of clubs are suspected of currently using or 
having previously used peptides, which could constitute an anti-doping rule violation.16 
Some players have also been identified as sourcing peptides for personal use. An instance 
of team-based doping, orchestrated by some club officials and coaching staff, has also been 
Apart from the peptide’s anabolic effects, it has been found that injured elite athletes, 
particularly players from one sporting code, have been using peptides to assist in 
rehabilitating soft tissue injuries. 
While the level of suspected use of peptides varies between sporting codes, officials 
from one club have been identified as administering, via injections and intravenous drips, 
a variety of substances, possibly including peptides. Moreover, the substances were 
administered at levels which were possibly in breach of WADA anti-doping rules. This 
activity was orchestrated by some club officials and the club’s high performance unit.
While intelligence confirms the use of peptides in major sporting codes, it further suggests 
that individuals in a range of other codes may also be using peptides.
15  For the purposes of this report, elite athletes are deemed to be those athletes who are competing in a recognised 
major competition in Australia or who are representing Australia or who are receiving payment and are considered to 
be professional athletes.
16  The issue of whether particular athletes have committed an anti-doping rule violation will be determined by the 
formal process which governs ASADA investigations of this type.

Apart from the use of peptides by elite athletes, sub-elite athletes have also been 
identified as using peptides and hormones. Sub-elite athletes are considered a high-risk 
group for doping due to:
the highly competitive environment in attaining a position in elite sport
the ability to make significant gains in strength and power through the 
use of PIEDs.
Peptides and hormones have been identified as being used at the sub-elite level in a 
number of sporting codes. Given the ease with which the various peptides and hormones 
can be obtained, any motivated sub-elite athlete is capable of acquiring and using these 
substances as illustrated in Case Study 1. 
On 14 October 2010, Customs and Border Protection intercepted a 
package from Canada which contained ten, five milligram vials of white 
powder labelled GhRP-6. Subsequent inquiries by ASADA identified the 
addressee as a rugby union player in a state club rugby competition.
On 28 November 2010, Customs and Border Protection intercepted a 
package from Canada addressed to another individual from the same team. 
This package contained five vials of what was believed to be GhRP-6.
Although it was not able to be established in the investigation, ASADA 
assessed it ‘as possible’ that the two individuals who had imported these 
substances were complicit in the importation of GhRP-6 from Canada, and 
that other team members of these individuals were using GhRP-6. 
After an extensive investigation by ASADA, the matter was referred to 
the Australian Rugby Union as a potential anti-doping rule violation. The 
ARU subsequently imposed a four-year ban on one individual for the 
possession and attempted trafficking of GhRP-6, and the other individual 
received a two-year ban for possession of GhRP-6.  
As demonstrated by this example, a rigorous and lengthy investigation is 
undertaken in the administration of an anti-doping rule violation.   
The fact that PIEDs use is occurring at the sub-elite level—and it is from these ranks 
that elite athletes are selected—means there is a threat to the integrity of professional 
sport in Australia. 

While the use of anabolic steroids by bodybuilders is well established, peptides and 
hormones have become increasingly popular amongst bodybuilders. Given the historical 
and widespread use of prohibited substances in bodybuilding, bodybuilders are often at 
the cutting edge of doping trends. 
The peptides, IGF-1, MGF and SARMs have gained a reputation amongst the bodybuilding 
community as being highly effective anabolic agents and are deemed by bodybuilders 
to have a number of advantages over steroids. This is because users do not experience 
the adverse and well recognised effects of prolonged anabolic steroid use, such as liver 
damage and disruption of hormonal production. 
Similar to online illicit drug forums, the use of peptides and hormones is the subject of 
extensive discussion in online bodybuilding forums. Users of peptides and hormones use 
these online forums to share information on the effects, dosage and administration of 
these substances. Individuals are also discussing how to combine peptides and hormones 
with anabolic steroids in ‘stacks’17 and cycles in order to increase the development of lean 
muscle, while minimising the side effects associated with use of these substances. 
Case Study 2 describes the perceived benefits of combining use of peptides and 
anabolic steroids.
A major side effect of using anabolic steroids in males is the disruption 
of normal testosterone production, which has typically required 
individuals to cease using steroids in order to allow the body to 
recommence the production of testosterone. however, on cessation 
of steroid use, individuals typically experience a significant loss of the 
muscle gains that were achieved through the use of steroids.  
To maintain their gains, steroid users typically cycle off steroids and 
commence what is known as a post-cycle therapy (PCT). This is done 
through the administration of a range of drugs such as Nolvadex, an 
anti-estrogen drug, and human chorionic gonadotropin (hCG).  
Peptides have been identified by bodybuilders as highly effective 
substances for use in a PCT, thereby allowing individuals to maintain 
muscular gains while cycling off steroids.  
17  Steroids are typically used in cycles to reduce the side effects associated with the disruption of hormone production 
due to steroid use. Users of PIEDs also combine multiple substances in order to heighten the effects of steroids and 
these combinations are known as stacks. 

Individuals involved in bodybuilding, particularly well known bodybuilders, are playing a 
key role in promoting peptides, increasing interest and demand for these substances in 
the bodybuilding community and by gymnasium users.
Growth hormone-releasing peptides have become increasingly popular as an anti-
ageing product given the ability of these substances to naturally stimulate hGh 
production and address the normally low levels of hGh in older individuals. It is also 
reported that these peptides are proving to be more effective than hGh as they 
promote the natural release of hGh as opposed to traditional hGh supplementation 
therapies. Dehydroepiandrosterone18 (DhEA) and testosterone have also become 
increasingly popular as hormonal treatments to ‘reverse’ the effects of ageing.19  
The use of hGh for anti-ageing purposes is considered by the TGA to be ‘off-label’, 
meaning that the drug is used outside the recognised therapeutic uses of the drug. 
While hGh and testosterone require a prescription from a medical practitioner, 
no such requirement currently exists for the supply of growth hormone releasing 
peptides. Consequently, anti-ageing clinics have become major distributors of peptides 
around Australia. 
Recently, the American Association of Clinical Endocrinologists20 updated their clinical 
guidelines for the use of hGh in clinical practice following concerns about what the 
Association called the ‘unethical aspects of hGh therapy for athletes and ageing 
individuals’. These guidelines strongly recommend that under no circumstances should 
hGh be prescribed unless the patient has a clearly defined medical condition (such as 
stunted growth), and that hGh should not be administered other than in accordance 
with the approved uses of hGh.
The anti-ageing industry both overseas and in Australia has expanded significantly in 
recent years, in line with the increasing range of anti-ageing products being released 
onto the market.
18  DhEA is a steroid hormone produced in the body. It functions as an endogenous precursor to more potent androgens 
such as testosterone.
19  Bross, R, Storer, T, Bhasin, S 1999, ‘Ageing and Muscle Loss’, Trends in Endocrinology and Metabolism, vol.10 (5), 
20  Specialising in endocrinology, diabetes, and metabolism, the American Association of Clinical Endocrinologists is a 
professional community of physicians committed to enhancing the ability of its members to provide high quality 
patient care.

The ACC has identified increasing interest in the administration of peptides to 
thoroughbred racehorses for the same reasons that these substances are used on 
humans—injury rehabilitation and to promote recovery. These substances are prohibited 
for use on racehorses, and although it is suspected that peptides are being administered to 
racehorses the extent of use across the industry is the subject of ongoing inquiries.
Available data, including border seizures of PIEDs, national arrests for steroids and drug 
injecting data, all suggest that the PIEDs market is expanding considerably in Australia. 
however, in contrast to the amount of research and knowledge that exists on illicit drug 
use, formal academic research into the use of PIEDs and the PIEDs market in Australia is 
extremely limited. This makes it difficult to quantify the size of and identify changes in 
the PIEDs market.  
Further research and consideration of the establishment of key indicators to identify 
changes in the Australian PIEDs market would assist in addressing this current gap.
Any increase in the use of PIEDs is likely to result in the increased prevalence of injection, 
as this is the principal route of administration of anabolic steroids and hormones. 
Increased levels of injection have already been identified in the latest Needle Syringe 
Program (NSP) Survey, which reported that while relatively small proportions of 
respondents reported last injecting PIEDs, a significant increase in prevalence occurred 
over the period 2007 to 2011. Among males who were new to injecting,21 more than half 
(53 per cent) reported last injecting PIEDs.22 
21  New to injecting is defined by the NSP study as individuals who have been injecting for less than 3 years.
22  University of New South Wales (UNSW) 2012, Australian NSP Survey: National Data Report 2007–2011
UNSW, Sydney.

As illustrated in Figure 2, a highly organised network of individuals and companies are 
involved in the acquisition and distribution of peptides and hormones. These include:
on-line suppliers
anti-ageing clinics
medical practitioners
compounding pharmacies
sports scientists and high performance staff
sports supplement suppliers.  
FIGURE 2: Supply chain from primary suppliers of peptides and hormones through 
to consumers
high performance 
coaches/sports scientists
On-line suppliers 
Elite Athletes
(Domestic and International)
Chinese Bio-Chemical 
Supplement Suppliers
Medical Practitioners
Anti-Ageing clinics 
(onsite Drs and 
Ageing clients
offsite Drs)
Primary Sources
The supply base to satisfy increasing domestic demand for PIEDs is broad. PIEDs can be 
easily acquired from a multitude of online stores based in Australia and overseas. Online 
stores offer a comprehensive range of PIEDs, including anabolic steroids, DhEA, hGh, 
SARMs, IGF-1 and peptides. however, as is the case with anabolic steroids sold online, 
the quality is potentially unreliable as the source of the products cannot be verified.  

An example of the range of peptides, hormones and other substances available 
online is provided below (substances which are currently scheduled by the TGA are 
shown in italics): 
Follistatin 344
HGH Frag 176-191 
IGF DES (1-3)
Melanotan II
Modified GRF 1-29
Thymosin Beta 4 (TB-500).
Products are advertised in a manner to attract a number of user markets, including:
strength enhancement/muscle enhancement
fat loss
injury rehabilitation
libido enhancement
growth hormone deficiency. 
A number of websites selling peptides also offer other prescription only drugs which 
target the PIED user market, such as aromatase inhibitors. These inhibitors are used in 
the treatment of breast cancer, but are also used to counter gynecomastia, which is a 
side effect of anabolic steroid use.  
The popularity of online stores as a source for peptides and hormones is reflected in 
the significant increase in border detections of hormones, which increased 255 per cent 
between 2009–10 and 2010–2011.  

Figure 3 illustrates the number of users and potential users of peptides and hormones 
using the internet to search for information on these substances. It also illustrates the 
high level of interest in these substances by Australians.
FIGURE 3: Searches on Google using the term ‘GhRP’ between January 2007 and January 
2013 showing volume of searches, countries from which searches emanate and related 
searches conducted. 
Notwithstanding the diverse sources of supply for peptides, the number of permits 
issued by TGA to allow lawful importation is very low. In particular, data obtained from 
the TGA indicates that nationally no permits for the importation of CJC-1295 or GhRP-6 
were issued in 2012 and that in total only six permits currently exist for the importation 
of CJC-1295, eleven permits for GhRP-2 and three permits for GhRP-6.
Some anti-ageing clinics have been identified by ASADA, the ACC and other partner 
agencies as a major source of peptides, hormones and other PIEDs, due to their capacity 
to supply pharmaceutical quality WADA prohibited PIEDs directly to athletes, in some 
cases without a prescription. 

Anti-ageing clinics are selling a wide range of PIEDs including testosterone, anabolic 
steroids, hGh, peptides, IGF-1, MGF and SARMs. Some of these clinics have been 
identified as having links to organised criminal identities.  
Athletes and body builders have previously been identified by ASADA as using 
anti-ageing clinics to acquire testosterone, hGh and anabolic steroids. As many of 
these substances—such as testosterone and hGh—require a prescription from a 
medical practitioner, complicit doctors have been identified providing prescriptions 
to clients of anti-ageing clinics, even if there is no medical reason for the prescribing 
of these substances and they have had no contact with the patient or access to their 
medical records.  
In many cases, anti-ageing clinics are marketing their services directly to athletes by 
offering services such as hormone profiling and hormone based training regimes to 
enhance athletic performance.
The anti-ageing industry both overseas and in Australia has expanded significantly in 
recent years, in line with the increasing range of anti-ageing products being released 
onto the market. 
Some medical practitioners have been identified as one of the key conduits through 
which individuals are obtaining PIEDs, in particular testosterone, hGh, CJC-1295, GhRP-6 
and SARMs.  
Some medical practitioners who advocate the benefits of peptides and hormones for 
anti-ageing treatment and/or are working from anti-ageing clinics, appear to be the 
primary prescribers of the various peptides and hormones used by elite and sub-elite 
athletes and body builders for their performance and image enhancing effects.  
The ACC identified doctors who have dispensed hGh directly to patients without a 
prescription, which is illegal, or through a pharmacy owned by these doctors. In these 
instances, no prescription or record of the dispensed hGh was recorded.  
The ACC also identified lax and fraudulent prescribing practices by some doctors with 
links to sporting clubs and anti-ageing clinics. These practices include writing scripts 
in false names, providing prescriptions without consulting the patient and prescribing 
hormones without conducting the necessary blood tests normally carried out prior 
to the prescription of these substances. Some of these doctors are also implicated 
in experimenting on players, by providing them with different substances in order to 
determine the effects on their performance.

The ACC has identified that anti-ageing clinics, supplement suppliers and 
online stores in Australia are sourcing peptides and hormones through domestic 
compounding pharmacies.  
As opposed to standard pharmacies, which dispense prescription medicines and 
therapeutic agents, compounding pharmacies provide a range of services in relation to 
pharmaceuticals such as:
altering or limiting the dose of a medicine
changing the physical form of a medicine (for example modifying a pill into a 
syrup or gel) 
supplying compound drugs that have been discontinued or are no 
longer available.
Compounding pharmacies are a principal domestic source of peptides and hormones 
given their capacity to produce medicines and pharmaceutical compounds that are not 
readily available or commercially produced. Given their ability to manufacture various 
anti-ageing medicines, compounding pharmacies play a key role in the dispensing of 
substances prescribed by or distributed through anti-ageing clinics.  
Based on available information, compounding pharmacies producing peptides are 
predominantly sourcing their raw materials from wholesalers based in China.
The standard of competition at the elite level of sport has reached a point where 
winning margins are now measured in hundredths of a second. There is an ever-
increasing focus on the science of sport in order to ensure that athletes perform at 
the highest possible standard and gain any possible competitive advantage. Remaining 
competitive at the elite level is now dependent on access to the best sports scientists 
and use of the latest technology.  
Information provided to the ACC suggests that in Australian football codes, sports 
scientists have gained increasing influence over decision making within the clubs. Some 
of these scientists are playing a critical role in pushing legal and regulatory boundaries in 
relation to sport supplementation programs and medical treatments given to players.  
While it appears that the majority of high performance staff, sports scientists, coaches 
and medical advisors adhere to anti-doping codes, it is also clear—internationally and 
domestically—that some of these individuals are playing a critical role in pushing beyond 
the boundary of what is permitted by WADA. This was particularly evident in the use of 
PIEDs by Lance Armstrong and his cycling teammates, where particular doctors played a 
critical role in the development and implementation of the doping program.

The United States Anti-Doping Agency (USADA) investigation into doping 
by the American United States Postal Service and Discovery Channel 
Cycling teams found overwhelming evidence that Dr Michele Ferrari 
facilitated and orchestrated the sophisticated doping program for these 
Dr Ferrari provided technical advice to professional cyclists on the use 
of PIEDs and blood doping and designed doping programs that riders 
would follow in order to achieve the largest possible performance 
enhancement without returning a positive anti-doping result.  
Dr Ferrari had a long history of working with an Italian researcher, 
Franceso Conconi, who, while being funded to develop a test for 
Erythropoietin (EPO),23 had also been involved in doping professional 
cyclists. Ferrari’s expert knowledge of EPO and the tests used to detect 
EPO use by professional cyclists had played a major role in his ability 
to provide EPO to cyclists and enable the systemic doping to remain 
According to the USADA investigation report, Lance Armstrong paid 
Dr Ferrari just over US$1 million between 1996 and 2006 for his services.  
23  EPO is a pharmaceutical product which has been widely used by athletes due to its ability to 
increase the amount of oxygen carried by the blood, resulting in improved endurance. 
The ACC has identified specific high-performance staff, sports scientists and 
coaches within some codes who have condoned and/or orchestrated the administration 
of prohibited substances, and substances not yet approved for human consumption,  
to players.  
In some cases, peptides and other substances were administered to players without 
them understanding the nature of the substances, and without the knowledge of the 
team doctor or club medical staff.

The ACC has identified a range of substances that have limited to no history of use 
in humans, are not approved for human use, or their use is considered ‘off-label’. 
Substances being administered to players include:
afamelanotide and melanocyte stimulating hormone (Melanotan™ I and II)
AOD-9604—an anti-obesity drug currently going through human clinic trials 
Cerebrolysin™—a peptide extract from pig brain which is used to treat 
alzheimer’s and stroke victims
a form of Interleukin not prohibited by WADA—used in the treatment of burns 
and inflammation associated with trauma (some other forms of Interleukin are 
prohibited by WADA)
TA-65™—a drug which acts on a section of the DNA and is purported to reduce 
ageing at the cellular level
Actovegin™—calf blood extract (used by a route of administration which is not 
prohibited by WADA).
While these substances are not prohibited by WADA, due to a lack of long-term clinical 
studies on the use of these substances or their ‘off-label’ use, their potential impact on 
the health of players—both short and long-term—is unknown. 
The apparent willingness of some high-performance coaches, trainers and sports 
scientists to administer WADA-prohibited and experimental drugs and their advocacy 
of ‘off-label’ substance use, raises concerns over the welfare of players who are being 
administered these substances and broader issues for sports administrators in Australia.  
It was also identified that some high-performance coaching staff utilised medical staff 
from outside their respective clubs to administer substances to players. In some cases, 
the medical staff administering these substances were not communicating with the 
appointed team doctors nor advising team doctors of the treatments or substances 
being administered to players. No party appeared to be maintaining comprehensive 
medical records in relation to treatments being given to players.
Within the Australian sports supplement market, there is an extensive range of products 
targeted at improving athletic endurance, fat loss, muscle development, hydration and 
recovery from strenuous training sessions. In many cases, the effectiveness of these 
products is yet to be clinically proven.  
Professional athletes use a wide range of sport supplements to assist with muscle 
development, fat loss, hydration, recovery and to support immunity during strenuous 
training periods. In professional sporting teams, supplement programs are developed by 

sports scientists, strength and conditioning coaches, team doctors and nutritionists.  
While there are a large number of sports supplement companies that sell only legitimate 
(non-prohibited) sports supplements, a large number of retail and online sports 
supplement stores also sell substances which are prohibited by WADA, prescription only 
medicines and prohibited imports.  
Some supplement suppliers at the manufacturing, wholesale and retail level are also 
involved in the sale of prohibited substances. In some cases, professional athletes have 
inadvertently consumed prohibited substances due to supplements being contaminated 
at the factory which was processing both WADA-prohibited and non-prohibited 
supplements. In other cases athletes have inadvertently used prohibited substances due 
to sports supplements containing undeclared ingredients.  
The ACC has identified supplement suppliers as a particular threat to the integrity of 
sport given their ready access to professional athletes and PIEDs.

According to the Director General of 
WADA, the influence of organised crime 
on sport is increasing, with criminal 
groups involved in the trafficking of 
PIEDs also engaged in money laundering, 
corruption, match fixing and fraud.24
The international presence of organised 
criminal groups in the trafficking of 
PIEDs is further supported by a 2005 
assessment25 which found that the PIEDs 
market is extensive and highly organised, 
with the Italian mafia and Russian organised criminal groups just two of the criminal 
groups heavily involved in trafficking of PIEDs across Europe.  
The ACC’s Organised Crime in Australia 201126 report identified the widespread use 
of PIEDs by persons from a broad cross section of the community and noted that the 
distribution of PIEDs can be highly profitable. 
Through the ACC and ASADA’s analysis of the peptide and hormone market, it is assessed 
that the Australian PIEDs market is larger and more complex than previously assessed. 
Organised criminal groups and individuals are involved in the domestic trafficking of 
PIEDs, with some of these criminal identities and groups also engaged in the trafficking 
of other illicit drugs.
The ACC considers that organised criminal identities and groups will expand their 
presence in the Australian peptide and hormone market. This is based on the high 
demand for peptides and hormones, the highly profitable nature of the market with the 
mark-up on peptides and hormones reportedly up to 140 per cent, and the established 
presence of organised criminal identities and groups in the steroid market both as 
distributors and users of these substances.27
24  Alvad, S 2011, ‘WADA’s Director General strikes alarm bells against organized crime in sports’, Play the Game, 23 
Febraury, viewed 21 November 2011, <
25  Donati, A 2007, World trafficking in doping substances, World Anti-Doping Association, viewed 12 November 2011, 
26  Australian Crime Commission (ACC) 2011, Organised Crime in Australia, ACC, Canberra.
27  ibid.

The presence of organised criminal identities and groups in the PIEDs market presents 
a threat to the integrity of Australian professional sport as a direct consequence of 
the increased likelihood of criminal identities and groups interacting with professional 
athletes and the potential exploitation of these relationships for criminal purposes. 
Relationships between athletes and organised crime identities can be exploited by 
criminals to corrupt the athlete and give a form of social status to the criminal, in the 
same way that the steroid market has been used by organised crime to corrupt law 
enforcement officers.
The use of PIEDs by sub-elite athletes has also been identified as an issue of concern by 
the ACC. Overseas experience has demonstrated that organised criminal groups involved 
in match fixing are increasingly targeting sub-elite athletes due to the ease with which 
these individuals can be ‘bought’, the lower levels of scrutiny from integrity authorities 
at sub-elite competitions, and the potential long-term value of these athletes to the 
criminal group. Overseas experience has also demonstrated that criminal identities and 
groups will invest years developing such relationships, with the ultimate aim of having 
the athlete participate in activities such as match fixing.  
The ACC has identified an increasing number of associations of concern between 
professional athletes and organised criminal identities in Australia. The ACC’s 2011 
assessment of Threats to the Integrity of Professional Sport in Australia, noted that as 
the amount of money wagered on sports increases, associations with athletes or other 
individuals with the ability to influence a sporting contest, or provide inside information, 
will be increasingly sought after.
The ACC has identified a number of issues that pose a current threat to the integrity of 
professional sport in Australia. These threats relate to:
organised criminal infiltration of unregulated markets28
infiltration through legitimate businesses, contractors and consultants
illicit drug use and criminal associations
differing levels of integrity oversight in professional sport in Australia.
28  Unregulated markets are where there is no specific legislation or existing legislation which is open to legal interpretation.

In recent years, the ACC has identified that criminal groups and entrepreneurial 
individuals are increasingly exploiting new and emerging unregulated drug markets.  
Entrepreneurial individuals and criminal groups are exploiting these markets by 
capitalising on the timeframe between when a substance is identified by regulatory 
authorities as being harmful, and the subsequent regulation of that substance, which 
in some cases is considerable. This is most clearly demonstrated in the drug analogue 
market, where manufacturers and vendors continue to release psychoactive substances 
that are not yet regulated.
These same vulnerabilities are being exploited in relation to peptides and hormones, 
which in some cases are not yet approved for human use yet are widely available. 
Strategies utilised by individuals identified by the ACC as being involved in the 
distribution of peptides and hormones include:
the establishment of a ‘research‘ body to obtain peptides and hormones from a 
compounding pharmacy
the use of anti-ageing clinics to distribute these substances
the recruitment of complicit doctors to write prescriptions for controlled 
pharmaceuticals, such as hGh
the role of a sports scientist who benefited financially from the sale of peptides 
and hormones; advocated their use and directed their application at a number 
of sporting clubs, even though he was not medically qualified.
It is clear that deliberate strategies have been employed by the PIEDs suppliers and 
distributors to facilitate the acquisition and supply of these substances and circumvent 
existing regulations around the supply of substances which are not yet approved for 
human use.
An assessment of money laundering through the football sector in Europe by the 
Financial Action Taskforce (FATF) found that, unlike other businesses, criminals were 
attracted to sport for reasons other than profitability.  
FATF found that “connections that criminals seek to make through sport are 
motivated by social prestige and that sport provides a powerful route for criminals to 
become ‘celebrities’ by associating with famous people and moving upwards in powerful 
circles within established society.”29 This is particularly relevant in Australia,
29  Financial Action Taskforce, Money Laundering through the football sector, Paris, 2009.

with many professional sporting club boards including some of Australia’s business and 
political leaders.  
The ACC has found that sporting clubs, and professional sports in general, are vulnerable 
to infiltration through sponsorship and business relationships. This is due to the 
high level of competition for sponsorship dollars between and within the codes, the 
significant financial pressure many professional sporting clubs are under, and limited or 
no due diligence conducted on potential investors and business partners. In essence, 
sporting clubs and codes appear rarely to question the source of money being invested 
into their clubs.  
The ACC has identified individuals with 
extensive criminal associations as being 
in business partnerships with major 
Australian sporting codes. The existence 
of such business relationships raises 
concerns over the potential for these 
relationships to be exploited for criminal 
purposes and demonstrates how open 
Australian professional sports currently 
are to infiltration by organised criminal 
identities and groups through legitimate 
Information obtained by the ACC suggests that illicit drug use by professional athletes 
remains an ongoing issue, with official statistics for illicit drug use within professional 
sports likely to significantly understate the extent of actual use. Illicit drug use by 
athletes leaves them particularly vulnerable to exploitation for other criminal purposes, 
including match fixing and fraud arising out of the provision of ‘inside information’. There 
is also evidence to suggest that some athletes are supplying others with illicit drugs. 
The use of illicit substances by athletes is likely to be correlated in some cases with 
the use of WADA prohibited substances by those athletes. Some players are allegedly 
using both PIEDs and illicit drugs, and the risk-taking instincts which are integral to 
some elite athletes likely explain this decision. There are, however, some athletes who 
draw distinctions between taking PIEDs and illicit drugs, based on personal opinions 
and biases and in many cases on an evaluation of the likelihood of the activity being 
A number of sports conduct testing on players for illicit drugs and maintain policies to 
deal with positive illicit drug tests, however evidence suggests that loopholes exist and 
are being exploited by players seeking to avoid testing and detection.

Sporting codes employ a wide range of individuals who have the capacity to influence 
the outcome of a game, or have access to inside information which can be used to gain 
an unfair advantage in betting markets. For example, a mid-tier Australian Football 
League (AFL) club has 99 staff to support the first grade players. Apart from full-time 
positions at clubs, individuals with specific skills sets or knowledge, such as sports 
scientists, are used on a contract basis.  
Codes of conduct are used by the sports governing bodies to ensure players conform to 
relevant rules and expected behaviours. More recently, codes of conduct are being used 
to prohibit players and other individuals involved with athletes, such as coaches and 
support staff, from wagering and to reduce the risk of contrived results and the use of 
inside information in betting markets.  
In deciding who is required to adhere to a code of conduct, it is generally recognised that 
the net should be cast wide to capture all individuals who have access to players and 
knowledge of team activities. however, the status of contractors and consultants, and if 
they are captured under a code of conduct, remains unclear to sports governing bodies.  
The AFL, which has a progressive integrity management framework, has 
attempted to address this risk by requiring contractors and consultants to provide 
their personal details to the sport’s integrity unit, as all other club officials and players 
are required to do.  
however, this information is only obtained if the integrity unit becomes aware that an 
individual is working at a club on a contract basis, or the club provides this information. 
The ACC has found that if a club neglects to formally disclose this information, it would 
be highly unlikely that a specific contractor would come to the notice of the sports 
governing body.  
Due to the highly sophisticated nature of doping, specific skills and knowledge are 
required to ensure athletes obtain the greatest possible benefit without returning 
a positive anti-doping sample. Overseas experience has illustrated the fundamental 
role contracted sports scientists and medical professionals play in sophisticated 
doping programs, as was most clearly demonstrated in the case of Dr Ferrari and his 
involvement with Lance Armstrong.  
As stated previously, sports scientists can play a critical role in taking training programs 
and the preparation of athletes to the edge of, and sometimes beyond, what is 

permitted by WADA. As professional sports become increasingly complex and reliant on 
sports scientists and other individuals with specialist skill sets, these individuals will pose 
a threat to the integrity of professional sport in Australia due to:
the specialist skills of these individuals, in particular medical doctors and 
individuals with knowledge of PIEDs
the access to and increasing 
influence contractors such as 
sports scientists have on internal 
mechanisms and decisions 
related to the training and 
preparation of professional 
the identified involvement of 
consultants and contractors in 
sophisticated doping programs 
overseas and now Australia
the limited visibility of these 
individuals to integrity officers and units.
The extent of integrity measures varies significantly between the sporting codes in 
Australia, including between codes which form the basis of substantial wagering 
markets. Integrity management in professional sport in Australia is only as strong as 
the weakest link across the broader sports industry. The lack of effective integrity 
management in some sporting codes creates a high level of vulnerability for the broader 
industry. It is assessed that individuals who pose a threat to the integrity of sport in 
Australia are capable of targeting those codes with minimal integrity management 
systems in order to infiltrate the broader industry.  
Characteristics of the sports industry which exacerbate this threat are the propensity 
for sporting codes to recruit from within the broader sporting industry, the high level of 
interconnectedness within and across professional sports, and the continual movement 
of individuals within and between sporting codes. 
This is particularly the case in the football codes, where players and coaches move to 
new teams on a regular basis.  
The threat of unethical individuals moving between codes is greatest in relation to 
individuals who have transferrable skills/knowledge, particularly administrators, coaches, 
high performance coaches and sports scientists.

The ACC has found, on the basis of a limited and focused examination of one component 
of the PIEDs market, that the market has evolved significantly in recent years to include 
peptides and hormones. These substances, which are WADA-prohibited, are being 
used by professional athletes in a number of sports in Australia, with widespread use 
identified or suspected in a number of professional sporting codes. Organised crime 
has been found to have a tangible and expanding footprint in this market, and their 
activity is being facilitated by some coaches and support staff of elite athletes, who have 
orchestrated and/or condoned the use of prohibited substances and/or methods of 
The PIEDs market does not rival the established markets for methylamphetamine, 
cocaine or heroin in terms of the risk and harms they pose to the Australian community, 
but it does currently, and has the potential to increasingly pose harm to the sector and 
the broader community out of all proportion to the relative size of the market. This is 
because of the special status of sport for Australia and Australians, and the enduring 
significance of concepts such as fairness and integrity in Australian sport. Moreover, 
unlike the more established illicit drug markets, this particular threat has been identified 
at a time when it is still possible for a coordinated response to get ‘ahead of the game’, 
to disrupt the expanding organised crime presence in professional sports and to harden 
the sports sector to make it less vulnerable to infiltration by organised crime.
There are clear parallels between what has been discovered in Australia and the USADA 
investigation into Lance Armstrong, which underlines the transnational threat posed 
by doping to professional sport, both from a ‘fair play’ perspective and as a broader 
integrity issue.  
It is also clear from the findings of this project, the USADA investigation and previous 
high profile doping cases in Europe and the United States,30 that it is not only athletes 
who are involved in doping, but athletic support staff, organised criminal groups and 
complicit doctors.  
In the European Union’s most recent White Paper on Sport in 2007,31 it was 
recommended that the fight against doping should not only target athletes, but also 
those involved in trafficking these substances, as is the case with illicit drugs.  
30  BALCO and Operation Puerto.
31  European Commission (EC) 2007, White Paper on Sport, Brussels, viewed January 29 2013, <

It is clear that the global trafficking and use of PIEDs is a complex, large and highly 
profitable market. While some elite athletes, high performance coaches, doctors and 
sports industry insiders are involved in sophisticated doping programs driven by the 
need to enhance performance while defeating anti-doping controls, it is also clear that a 
complex supply and distribution network exists to satisfy the high demand for anabolic 
steroids, peptides and hormones by sub-elite and recreational athletes, body builders 
and increasingly, ageing Australians. 
The ACC has demonstrated through this project that the threat posed by the PIEDs 
market and related criminal activities to the integrity of sport in Australia, and organised 
crime attempts to infiltrate the professional sports sector in this country, exhibits many 
of the characteristics identified in the USADA investigation of Armstrong’s activities 
in the mid-1990s to mid-2000s. The difference is that the Australian threat is current, 
crosses sporting codes and is evolving.

Peptides is a generic name given to any group of amino acids that are linked together to 
form a chain. Essentially, they are similar to proteins, though in much shorter lengths (less 
than 50 units long). In the world of sport, peptides generally refer to one of two things: 
either broken protein fragments from hydrolysed proteins; or peptide hormones and 
related compounds. 
Protein peptides are whole proteins that are broken down into smaller peptide fragments 
by a process of hydrolysis. hydrolysed proteins are absorbed much faster than other forms 
of protein and are commonly found in supplements that contain hydrolysed whey protein. 
A peptide hormone is a protein which is released in the blood stream. Usually, the peptide 
hormone is secreted by the pituitary gland. Peptide hormones include growth hormone 
and insulin. The substances involved in this case stimulate the production of peptide 
hormones, which is different to substances that mimic the effects of peptide hormones 
such as somatropin (a synthetic human growth hormone). 
The substances identified as being used in Australia are GhRP-2, GhRP-6, CJC-1295, 
AOD-9604 and hexarelin. An overview summary of these substances is provided below: 
GhRP-2 and GhRP-6 are growth hormone-releasing factors and are therefore prohibited 
S2 hormones and Related Substances according to the WADA Prohibited List. They are 
part of the growth hormone-releasing peptide (GhRP) family, which includes GhRP-1, 
GhRP-2, GhRP-4, GhRP-6, alexamorelin, ipamorelin and hexarelin. GhRPs are used to 
stimulate the release of Growth hormone (Gh) by the pituitary gland. They also promote 
food intake by stimulating hunger and aid in energy metabolism. 
Purported benefits of using GhRPs include bone mineral density, increased lean muscle 
mass, improved strength, rejuvenation and strengthening of joints and improved 
recovery from injury such as bone fractures. Side effects from the use of GhRP may 
include hot flushes, loud stomach rumbling, white blood cell count increase, sweating 
and increased appetite. 
GhRP-2 and 6 are administered by subcutaneous injection. GhRP-2 and GhRP-6 are 
detectable in urine.
CJC-1295 is considered a growth hormone-releasing factor and is therefore considered 
to be prohibited according to the WADA Prohibited List in the S2 category (Peptide 

hormones, growth factors and related substances). CJC-1295 is a synthetic peptide 
hormone, similar in structure to GhRh, which stimulates the release of growth hormone, 
and subsequently IGF-1, from the pituitary gland. CJC-1295 was initially developed to 
treat those suffering from growth disorders, muscle wasting diseases or burns victims. 
however, CJC-1295 is not approved for human use. 
CJC-1295’s purported anabolic effects may increase lean muscle mass, reduce fat 
and improve performance. In addition, CJC-1295 has anti-inflammatory properties if 
administered directly to the related area soon after injury, can reduce pain and swelling 
and also assist in the repair of injured tissue. It is also purported to promote slow wave 
sleep (SWS) which is responsible for the highest level of muscle growth and memory 
retention. Further benefits include reduced body fat, increased energy and vitality, 
increased endurance, accelerated healing, and strengthening of the heart. 
CJC-1295 is administered by subcutaneous injection, usually in the abdomen. It is also 
available as a cream.
AOD9604 is not currently prohibited under category S2 of the WADA Prohibited List.
AOD9604 works by mimicking the way natural Gh regulates the metabolism of fat by 
stimulating lipolysis (the breakdown or destruction of fat) and inhibits lipogenesis (the 
transformation of non-fat food materials into body fat). Reports by Caldaza Ltd have 
shown that AOD9604 had positive (anabolic) effects on cartilage tissue formation as well 
as enhancements in the ‘differential of muscle progenitor cells (cells that create muscle 
cells) to muscle cells’. Other purported benefits of AOD9604 include increasing muscle 
mass and IGF-1 levels. AOD-9604 is not approved for human use. 
hexarelin is considered a growth hormone releasing factor and is therefore prohibited 
under category S2, hormones and Related Substances, according to the WADA 
Prohibited List. As with GhRP-6, hexarelin stimulates the release of Gh, with effects 
similar to those experienced when using a synthetic growth hormone.  
Purported beneficial effects of hexarelin use include increased strength, growth of new 
muscle fibres and increases in the size of existing muscle fibres,  joint rejuvenation and 
assistance in healing. hexarelin may also be beneficial in fat reduction. Unlike 
GhRP-6, there is no effect on appetite as it does not increase ghrelin levels responsible 
for increased hunger and gastric emptying. 
hexarelin can be administered orally in tablet form or via subcutaneous injection.

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A Pr
A Pr
A Pr
A Pr
A Pr
A Pr
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orm used
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ed - S2 W
ed - S2 W
ed - S2 W
ed – S1 W
ed - S2 W
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o the f
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human growth releasing Peptides 
human growth releasing peptides such as CJC-1295 and GhRP-6 stimulate 
an increased level of human growth hormone (hGh). The main peptides 
identified as being used through Project Aperio were CJC-1295 and GhRP-6
•  Liquid (injected)
•  Cream (applied to skin)
•  Powder (mixed with saline and injected)
Not approved for human use, currently unscheduled
Schedule 7A Customs (Prohibited Imports) Regulations
Prohibited both in and out of competition 
Detectable in urine but complex
Growth Hormone Variants
AOD-9604 (stands for Anti Obesity Drug number 9604) was identified in 
Project Aperio as being used by professional athletes. AOD-9604 is an 
experimental drug that is in a growth hormone variants that has fat burning 
properties and may be used by athletes to increase power to weight ratios 
by better utilisation of fat stores. Athletes may also use it to rehabilitate soft 
tissue injuries.
•  Liquid (injected)
•  Cream (applied to skin)
Not yet approved for human use, about to enter the final phase of clinical 
human trials
not a border controlled drug
not currently prohibited

Insulin Like Growth Factor (IGF-1) and Mechano Growth Factor (MGF)
IGF-1 is a hormone secreted by the liver and is one of the primary hormones 
necessary for cell growth in the body. IGF-1 is used by bodybuilders and 
athletes due to its anabolic effect.
MGF is derived from IGF-1 and assist tissue repair and adaptation. MGF is 
used due to its reported ability to facilitate muscle repair following exercise.
•  Liquid (injected)
Schedule 4 on the Poisons Schedule – prescription only 
Possession without legal authority (a prescription) is illegal.
Schedule 7A Customs (Prohibited Imports) Regulations
Prohibited both in and out of competition 
Is detectable  but complex
selective androgen receptor Modulators (sarMs)
Also known as Ostarine, Enobosarm
SARMs are used to treat a range of medical conditions or assist in the 
management of illnesses such as cancer by reducing muscle wasting. SARMs 
enhance the body’s ability to utilise testosterone.
It is suspected that SARMs are being used  by professional athletes due to 
their anabolic effect. 
•  Liquid (injected)
•  Cream (applied to skin)
To be a Schedule 4 on the Poisons Schedule – prescription only medicine in 
May 2013 
Possession without legal authority (a prescription) is illegal from May 2013
Schedule 8 Customs (Prohibited Imports) Regulations
Prohibited both in and out of competition 
Some SARMs are currently detectable

ACC – Australian Crime Commission 
AFL – Australian Football League
ASADA – Australian Sports Anti-Doping Authority
ASC – Australian Sports Commission
Customs and Border Protection – Australian Customs and Border Protection Service
FATF – Financial Action Taskforce
Gh – Growth hormone
GhRP – Growth hormone Releasing Peptide
hGh – human Growth hormone
IGF-1 – Insulin Growth Factor 1
MGF – Mechano Growth Factor
NSP – Needle Syringe Program
PIEDs – Performance and Image Enhancing Drugs
Poisons Standard – Standard for the Uniform Scheduling of Medicines and Poisons
S1 – Schedule 1 (to the WADA Prohibited List)
S2 – Schedule 2 (to the WADA Prohibited List)
S4 – Schedule 4 (to the Standard for the Uniform Scheduling of Medicines and Poisons)
SARMs – Selective Androgen Receptor Modulators
TGA – Therapeutic Goods Administration
USADA – United States Anti-Doping Agency
WADA – World Anti-Doping Agency

© Commonwealth of Australia 2013.