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CAS 2023 A 9775 (CAS)

Why it matters

This case clarifies the strict requirements for a valid waiver of training compensation under FIFA regulations. It confirms that a waiver must clearly and unequivocally refer to 'training rewards' as defined in the FIFA RSTP, and that ambiguous terms like 'development rights' are insufficient. The decision also underscores that separate clubs are distinct entities for training compensation purposes, even if commonly owned.

Summary

C.D. Tenerife, a Spanish football club, signed Gambian player Ba Lamin Sowe in January 2023. Under FIFA rules, this triggered training compensation obligations to clubs that trained the player between ages 12 and 21. The FIFA Clearing House determined that Banjul FC and Banjul Football Academy were entitled to a total of EUR 269,972.60. C.D. Tenerife argued that Banjul FC had waived its rights via a letter stating no 'development rights' would be claimed, and that the two Gambian entities were effectively the same. The CAS Sole Arbitrator rejected both arguments. She found that the waiver was invalid because 'development rights' is not a term used in FIFA regulations and does not clearly refer to 'training compensation' or 'training rewards'. She also held that Banjul FC and Banjul Academy are separate legal entities, and the waiver did not cover the Academy. The appeal was dismissed, and the FIFA decision was confirmed.

The detail

Parties: 9776 C.D. Tenerife SAD v Waa Banjul FC & Banjul Football Academy & FIFA

Case number: CAS 2023 A 9775

Outcome: Appeal dismissed; FIFA's decision confirming training compensation of EUR 269,972.60 payable by C.D. Tenerife to Banjul FC and Banjul Academy upheld.

Quantum: EUR 269,972.60

Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP), FIFA Clearing House Regulations (FCHR), Swiss law

Issues in play: Validity of a waiver of training compensation under Swiss law and FIFA regulations; whether a waiver referring to 'development rights' clearly waived 'training compensation'.

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

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