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CAS 2013A3383 - 3385 Volga Nizhniy Novgorod v Levan Silagadze (CAS)

Why it matters

This case clarifies that FIFA's Players' Agents Regulations do not require registration for contract validity, and that Swiss law fills lacunae regarding nullity and unjust enrichment. It also confirms that high agency fees (46.24% of players' salaries) are not automatically disproportionate if consistent with market practice, reinforcing pacta sunt servanda in football agency contracts.

Summary

Volga Nizhniy Novgorod appealed a FIFA decision ordering it to pay EUR 1,200,000 to agent Levan Silagadze for mediating employment contracts with three Georgian players. The Club argued the agency contracts were invalid because they were not registered with the national association, the dates were wrong, and the former president who signed them lacked authority. The CAS Panel held that FIFA regulations do not require registration for validity, and the contracts were validly concluded. The Club also claimed unjust enrichment, but the Panel found no evidence that the agent received fees without cause, as the players signed contracts and the Club issued Acts of Acceptance. Finally, the Club sought to reduce the fees to 3-5% of players' salaries, but the Panel noted that fees of 30-40% were common in Russia at the time, and the players were free agents, justifying higher fees. The Panel dismissed the appeal and confirmed the FIFA decision.

The detail

Parties: CAS 2013A3383 - 3385 Volga Nizhniy Novgorod v Levan Silagadze

Outcome: The appeal by Volga Nizhniy Novgorod is dismissed; the FIFA Single Judge's decision ordering the Club to pay EUR 1,200,000 in agency fees is confirmed.

Quantum: EUR 1,200,000

Applicable law: FIFA Regulations on Players' Agents; Swiss Code of Obligations (SCO) articles 20, 62, 417; Russian Civil Code (CCR) articles 1102, 1103

Issues in play: The validity of agency contracts under Swiss law (SCO art. 20) and the principle of unjust enrichment (SCO art. 62; CCR arts. 1102-1103) were considered. The Panel also addressed mitigation of agent fees under SCO art. 417.

Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗

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