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CAS 2021 A 7985 (CAS)

Why it matters

This case reaffirms the CAS's deference to FIFA Disciplinary Committee discretion in imposing fines for non-compliance with final and binding decisions. It clarifies that a fine within the prescribed range (CHF 100 to CHF 1,000,000) will not be reduced unless grossly disproportionate, and that the debtor's obligation to pay arises from the award itself, not from a separate payment request. The decision also confirms that a creditor's standing to be sued in such disciplinary appeals is limited.

Summary

Santos FC failed to pay EUR 2,900,000 plus interest to FC Barcelona as ordered by a CAS award dated 9 December 2020. Barcelona requested payment on 23 December 2020 via email to Santos's legal representative, who forwarded it internally. Santos claimed it never received the request and argued that the payment deadline should run from 29 January 2021 when Barcelona directly contacted Santos's legal department. The FIFA Disciplinary Committee found Santos guilty of non-compliance and imposed a CHF 30,000 fine, a transfer ban threat, and ordered payment. Santos appealed to CAS, arguing improper notification, that the fine was null because FIFA might benefit from fines, and that COVID-19 should reduce the fine. The CAS Panel held that Barcelona lacked standing to be sued in this vertical dispute between Santos and FIFA. On the merits, the Panel found that Santos was properly notified via its legal representative and that the 30-day payment period ran from the award's notification, not from a payment request. The Panel upheld the fine, noting that FIFA's discretion was not arbitrary and the fine was proportionate given similar cases. The appeal was dismissed, and Santos bore the arbitration costs.

The detail

Parties: Santos FC v. FC Barcelona & FIFA

Case number: CAS 2021 A 7985

Outcome: Santos FC's appeal dismissed; FIFA Disciplinary Committee decision confirmed; Santos FC ordered to pay arbitration costs; each party bears own legal fees.

Quantum: CHF 30,000 fine

Applicable law: FIFA Disciplinary Code (2019 edition), CAS Code of Sports-related Arbitration

Issues in play: The case involved the enforcement of a prior CAS award and the proportionality of disciplinary sanctions under the FIFA Disciplinary Code, specifically whether the fine of CHF 30,000 was grossly disproportionate.

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

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