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CAS 2019 A 6264 (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 of around 1% of the overdue amount are proportionate. It also shows how CAS handles partial settlements by issuing a consent award on the contractual part while deciding the disciplinary part separately.

Summary

Sport Club Internacional (Brazil) appealed a FIFA Single Judge decision ordering it to pay Udinese Calcio S.p.A. (Italy) USD 1,500,000 plus interest for overdue transfer fee instalments, and imposing a warning and a CHF 15,000 fine under Article 12bis FIFA RSTP. The dispute arose from a 2016 transfer of player Nicolas Lopez. After late payments, the parties signed a settlement agreement with an acceleration clause. Internacional failed to pay the fifth and sixth instalments, leading Udinese to file a claim. The Single Judge accepted the claim and imposed sanctions. At CAS, the parties reached a second settlement agreement during the hearing. The Panel issued a Partial Consent Award incorporating the settlement, resolving the contractual dispute. The disciplinary part proceeded separately: the Panel confirmed the Single Judge's decision, finding that Internacional had committed an offence under Article 12bis(2) and that the warning and fine were proportionate. The Panel rejected Internacional's arguments that financial difficulties excused non-payment and that the fine was excessive. The award highlights the strict liability for overdue payables in football and the wide discretion of FIFA bodies in imposing sanctions.

The detail

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

Case number: CAS 2019 A 6264

Outcome: The parties settled the contractual dispute; the Panel issued a Partial Consent Award incorporating the settlement. The disciplinary sanctions (warning and fine) imposed by FIFA were upheld in a separate final award.

Quantum: USD 1,500,000 (settled amount)

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Article 12bis; Swiss law subsidiarily.

Issues in play: The case involved the application of Article 12bis FIFA RSTP on overdue payables and the proportionality of sanctions (warning and fine) for non-payment. The settlement agreement's acceleration clause and interest rate were also at issue.

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

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