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CAS 2022 A 8837 (CAS)

Why it matters

This case clarifies that a club which is not a direct party to a transfer agreement may have standing to sue for overdue payments if the agreement expressly grants it enforcement rights. It also confirms the strict application of FIFA RSTP Article 12bis on overdue payables, reinforcing that clubs must pay on time or face sanctions, even if they dispute the creditor's identity.

Summary

Al Nassr Saudi Club appealed a FIFA PSC decision ordering it to pay Atlanta United FC the second instalment of a transfer fee for player Gonzalo Martinez. Al Nassr argued Atlanta lacked standing because the Transfer Agreement was signed by MLS, not Atlanta. However, clause 8.5 of the agreement allowed the MLS team (Atlanta) to enforce its terms. The CAS Sole Arbitrator found that Atlanta had standing, as the MLS acted as agent for Atlanta. On the merits, Al Nassr admitted non-payment but claimed it owed only 95% of the instalment due to MLS internal rules. The CAS rejected this, holding that Al Nassr must pay the full amount to Atlanta (or MLS) and that internal distribution was irrelevant. The CAS also upheld the Article 12bis sanction (a warning) because Al Nassr delayed payment over 30 days without a prima facie contractual basis. The appeal was dismissed, and Al Nassr was ordered to pay the outstanding amount plus interest and CHF 5,000 towards Atlanta's legal costs.

The detail

Parties: Al Nassr Saudi v. Atlanta United FC & FIFA_redacted

Case number: CAS 2022 A 8837

Outcome: Al Nassr's appeal dismissed; FIFA PSC decision confirmed; Al Nassr ordered to pay outstanding transfer fee instalment plus interest and CHF 5,000 towards Atlanta's legal costs.

Quantum: USD [redacted] plus 5% interest p.a. from 2 October 2021

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), particularly Article 12bis; Transfer Agreement between MLS and Al Nassr dated 4 September 2020.

Issues in play: Standing to sue of a club not a signatory to the transfer agreement (Atlanta) vs. the debtor club's obligation to pay only to the MLS. The CAS held that clause 8.5 of the Transfer Agreement gave Atlanta the right to enforce payment.

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

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