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CAS 2019 A 6263 (CAS)

Why it matters

This case illustrates the CAS approach to disciplinary sanctions under Article 12bis FIFA RSTP for overdue payables, confirming that financial difficulties do not excuse non-payment and that fines are proportionate even when a settlement is reached. It also shows how CAS can ratify a settlement agreement and issue a consent award, while still ruling on the disciplinary aspects.

Summary

Sport Club Internacional (Brazil) appealed a FIFA decision ordering it to pay EUR 1,500,000 plus interest to Udinese Calcio (Italy) for the permanent transfer of player Edenilson Andrade dos Santos, and imposing a warning and CHF 15,000 fine for overdue payables under Article 12bis FIFA RSTP. Internacional had exercised an option to buy the player but failed to pay the first instalment, triggering an acceleration clause. Before the CAS hearing, Internacional and Udinese reached a settlement covering this and a related dispute (CAS 2019/A/6264). At the hearing, the parties agreed to focus only on the disciplinary sanctions. The Panel ratified the settlement, issuing a consent award on the contractual dispute. On the disciplinary issue, the Panel confirmed the FIFA Single Judge's decision: Internacional violated Article 12bis by failing to pay on time, and the fine of CHF 15,000 (about 1% of the debt) was proportionate, considering no prior offence and the club's cooperation. The appeal was dismissed, and the sanctions upheld.

The detail

Parties: Sport Club Internacional v. Udinese Calcio S.p.A. & FIFA

Case number: CAS 2019 A 6263

Outcome: The Panel ratified a settlement agreement between Internacional and Udinese regarding the contractual dispute, and confirmed the disciplinary sanctions (warning and fine of CHF 15,000) imposed by FIFA on Internacional for overdue payables.

Quantum: CHF 15,000 fine

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Article 12bis; Swiss law subsidiarily; CAS Code of Sports-related Arbitration

Issues in play: The case involved the application of Article 12bis FIFA RSTP on overdue payables, balancing the principle of pacta sunt servanda against the proportionality of sanctions for financial non-compliance.

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

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