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CAS 2019/A/6315 (CAS)

Why it matters

This case reaffirms CAS's deference to FIFA disciplinary sanctions unless arbitrary or grossly disproportionate. It clarifies that a club with seven violations of Article 12bis RSTP in three years is a 'repeated offender' and can predict escalating sanctions. The award also confirms that a suspended registration ban with probation is proportionate and that financial hardship is not a valid defense for non-payment.

Summary

Clube Atlético Mineiro (CAM) appealed a FIFA decision ordering it to pay USD 1,125,000 to FC Spartak Moscow under a transfer agreement addendum, plus a suspended one-year registration ban with a one-year probationary period. CAM did not dispute the debt but argued the sanction was disproportionate and that its qualification as a 'repeated offender' violated the principle of predictability. The CAS sole arbitrator dismissed the appeal. He found that CAM had been found in violation of Article 12bis RSTP seven times in three years, making it clearly a repeated offender. The sanction was predictable given the clear wording of Article 12bis para. 6. The decision was adequately reasoned. The sanction was not disproportionate because it was not the harshest available and CAM could avoid it by paying its debts. CAS applied its established deferential standard of review for FIFA disciplinary decisions, only intervening if arbitrary or grossly disproportionate. The award confirms that financial difficulties do not excuse non-payment and that repeated violations justify escalating sanctions.

The detail

Parties: Clube Atlético Mineiro v. F.C. Spartak Moscow & FIFA

Case number: CAS 2019/A/6315

Outcome: Appeal dismissed; FIFA decision confirmed: CAM must pay USD 1,125,000 plus interest and costs, and is subject to a suspended one-year registration ban with a one-year probationary period.

Quantum: USD 1,125,000

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

Issues in play: The principle of predictability (whether a repeated offender could foresee a harsher sanction) and the proportionality of the sanction under Article 12bis RSTP.

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

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