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CAS 2023 A 9876 (CAS)

Why it matters

This case clarifies that a post-decision settlement between a player and club does not nullify sporting sanctions (transfer bans) imposed by FIFA for abusive conduct and repeat offending. It reinforces the 'vertical' effect of FIFA's regulatory sanctions, which are independent of private settlements. The Panel also applied the 'comfortable satisfaction' standard of proof to determine the signing date of the settlement agreement.

Summary

The case involves an appeal by Turkish club Samsunspor against a FIFA Dispute Resolution Chamber (DRC) decision. The DRC had found that the club acted abusively towards player Arvydas Novikovas, giving him just cause to terminate his contract. The DRC ordered the club to pay EUR 70,601 in outstanding remuneration and EUR 512,419.84 as compensation for breach of contract, plus interest. Additionally, because the club was a repeat offender (three prior instances), it imposed a ban on registering new players for two consecutive registration periods. The club appealed to CAS, arguing that the parties had signed a settlement agreement on 4 July 2023 (before the DRC decision) and that the Player had been paid EUR 620,000, so the DRC decision should be annulled. The majority of the CAS Panel found that the club failed to prove the settlement was signed before the DRC decision. The evidence (witness testimony, WhatsApp messages, medical reports) was insufficient to meet the 'comfortable satisfaction' standard. The Panel concluded the settlement was signed after the DRC decision and thus did not affect the sporting sanctions. The appeal was dismissed, and the DRC decision was confirmed.

The detail

Parties: Club Samsunspor v. FIFA & Arvydas Novikovas

Case number: CAS 2023 A 9876

Outcome: The appeal was dismissed; the FIFA DRC decision was confirmed, including the two-window transfer ban and compensation award.

Quantum: EUR 620,000 (settlement sum paid by Club to Player)

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

Issues in play: The key issue was whether a settlement agreement signed before or after the FIFA DRC decision could affect the sporting sanctions imposed under Article 17(4) RSTP. The Panel found the settlement was signed after the decision, so it did not affect the sanctions.

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

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