CAS 2024/A/10918 Jonathan Dominic Finbar Beckett v. FIFA
CAS · Football (FIFA / CAS) · Switzerland · 15 May 2025
Why it matters
This case clarifies the limits of FIFA's General Secretariat's authority to impose de facto definitive suspensions on football agents without proper disciplinary proceedings. It reinforces that provisional measures cannot substitute for a full disciplinary process, especially when the relevant disciplinary provisions are suspended. The decision protects agents' procedural rights and ensures that eligibility decisions are made by the competent body.
Summary
Jonathan Beckett, a British football agent and co-owner of Arete Management Ltd, represented a player in contract extension negotiations with Aston Villa FC in January 2024. At that time, Beckett had not yet obtained a FIFA licence under the new FFAR, which came into force on 1 January 2024. He argued that he was merely assisting Simon Bayliff, a licensed agent, and that his role was administrative. However, FIFA's General Secretariat found that Beckett had personally provided Football Agent Services without a licence, based on emails showing he was the main contact with the club, attended meetings, and negotiated terms. On 16 September 2024, FIFA provisionally suspended Beckett's licence and barred him from reapplying until 17 January 2026, citing Article 5(1)(b) FFAR (eligibility requirement not to have provided services without a licence in the previous 24 months). Beckett appealed to CAS. The CAS Panel held that the FIFA General Secretariat lacked competence to decide whether Beckett had provided services without a licence and to impose a de facto definitive suspension. Under the FFAR, only the FIFA Disciplinary Committee could make such findings and impose final sanctions, but Article 21 (disciplinary provisions) was temporarily suspended. The Panel found that the General Secretariat had usurped the Disciplinary Committee's authority. Therefore, the appealed decision was set aside, and Beckett's licence remained in force. FIFA was ordered to bear the arbitration costs and pay CHF 5,000 towards Beckett's legal fees.
The detail
Parties: CAS 2024/A/10918 Jonathan Dominic Finbar Beckett v. FIFA
Outcome: Appeal upheld; FIFA's decision to provisionally suspend Beckett's licence and prevent him from reapplying until 17 January 2026 is set aside.
Applicable law: FIFA Football Agent Regulations (FFAR), specifically Articles 5 and 17; CAS Code of Sports-related Arbitration (R64).
Issues in play: The case involved a conflict between the FIFA General Secretariat's provisional suspension powers under FFAR Article 17 and the exclusive jurisdiction of the FIFA Disciplinary Committee to impose definitive sanctions under Article 21 FFAR, which was temporarily suspended.
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.