Award

CAS 2021-A-8364 Marco Antonio Trovato Villalba v. FIFA

CAS · Football (FIFA / CAS) · Switzerland · 2 Sept 2025

Why it matters

This case is a landmark in sports arbitration for its strict application of FIFA's zero-tolerance policy against match manipulation. It confirms that conspiracy to fix matches, even without consummation, can warrant a lifetime ban for high-ranking officials. The award also clarifies the duty to cooperate under Article 20 CDF and the standard of proof in disciplinary proceedings, setting a precedent for future match-fixing cases involving football executives.

Summary

Marco Antonio Trovato Villalba, former president of Club Olimpia in Paraguay, was investigated by FIFA for allegedly conspiring to manipulate the results of multiple matches between 2018 and 2019. The investigation began after a notary forwarded a complaint from Edgar Troche, who claimed to have WhatsApp conversations with Trovato about fixing games. FIFA's Disciplinary Committee ordered Trovato to hand over his mobile phone for forensic analysis. Trovato initially cooperated but later failed to provide the correct PIN, leading to a finding that he violated his duty to cooperate under Article 20 of the FIFA Disciplinary Code (CDF). The Committee also found sufficient evidence of conspiracy to manipulate matches under Article 18 CDF, based on the WhatsApp messages and other circumstantial evidence. In September 2020, the Committee imposed a lifetime ban from all football-related activities and a CHF 100,000 fine. Trovato appealed to the FIFA Appeal Committee, which upheld the decision in July 2021. He then appealed to the Court of Arbitration for Sport (CAS). The CAS panel conducted a de novo review, hearing expert testimony on the authenticity of the WhatsApp messages and considering Trovato's arguments about procedural violations and lack of evidence. The panel found that the messages were authentic and that Trovato had conspired to influence matches, even if the fixes were not carried out. It also held that Trovato failed to cooperate fully by not providing the correct PIN. The panel confirmed the lifetime ban, emphasizing the severity of match-fixing, the number of matches involved, and Trovato's position as a club president. The award was issued on 21 August 2025, with each party bearing its own costs except for the expert fees, which were assigned to Trovato.

The detail

Parties: CAS 2021-A-8364 Marco Antonio Trovato Villalba v. FIFA

Outcome: Appeal dismissed; FIFA's decision to impose a lifetime ban from football and a CHF 100,000 fine for match-fixing conspiracy confirmed.

Quantum: CHF 100,000 fine

Applicable law: FIFA Disciplinary Code (CDF), particularly Articles 18 (match manipulation) and 20 (duty to cooperate); CAS Code of Sports-related Arbitration

Issues in play: The case involved the interpretation of Article 18 CDF on conspiracy to manipulate matches versus actual match-fixing, and the proportionality of a lifetime ban for a club president who conspired but did not complete the fix.

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

Locus Standi links to the source decision and publishes its own plain-language summary. It does not reproduce the text of the award.

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