TAS 2020 A 7003 Rayo Vallecano de Madrid S.A.D. c. FIFA
CAS · Football (FIFA / CAS) · Switzerland · 1 Jun 2021
Why it matters
This case clarifies the scope of third-party influence under FIFA's RSTP, confirming that agreements giving a sponsor the ability to influence player transfers, even if not exercised, violate art. 18bis. It also addresses proportionality of sanctions, reducing a fine where one of two violations was overturned, and underscores that clubs must declare any third-party influence in the Transfer Matching System.
Summary
Rayo Vallecano, a Spanish football club, entered into a sponsorship agreement with a Chinese company that required the club to sign a Chinese player and play friendlies in China. A later collaboration agreement provided the club €1.2 million to acquire a specific Chinese player, Zhang Chengdong, on loan. Rayo Vallecano signed the player but terminated his contract early. FIFA's Disciplinary Committee found the club violated art. 18bis RSTP (prohibition of third-party influence) and art. 4(2) Annex 3 (failure to declare third-party influence in TMS), imposing a CHF 55,000 fine. The FIFA Appeal Committee upheld the violation but removed a separate art. 18ter charge. Rayo Vallecano appealed to CAS, arguing the sponsor had no effective influence and that the agreements were legitimate. The CAS panel held that the agreements gave the sponsor the ability to influence player transfers, violating art. 18bis, regardless of whether influence was actually exercised. It also found the club failed to declare the third-party influence in TMS. However, the panel reduced the fine from CHF 55,000 to CHF 53,000 because the CHF 5,000 portion for the TMS violation was disproportionate after one violation was dropped. The panel confirmed the rest of the sanction, including a warning. The award is significant for its interpretation of third-party influence and proportionality in disciplinary sanctions.
The detail
Parties: TAS 2020 A 7003 Rayo Vallecano de Madrid S.A.D. c. FIFA
Outcome: Appeal partially upheld; fine reduced from CHF 55,000 to CHF 53,000; other sanctions confirmed.
Quantum: CHF 53,000
Applicable law: FIFA Regulations on the Status and Transfer of Players (RSTP) arts. 18bis, 18ter, Annex 3 art. 4(2); FIFA Disciplinary Code; CAS Code of Sports-related Arbitration
Issues in play: Whether sponsorship and collaboration agreements allowing a third party to influence player transfers violate art. 18bis RSTP (prohibition of third-party influence) and art. 4(2) Annex 3 (duty to declare third-party influence in TMS).
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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