TAS 2023 A 9362 Laureano González v. FIFA ES
CAS · Football (FIFA / CAS) · Switzerland · 2 May 2025
Why it matters
This case clarifies that 'misuse' of funds is encompassed within 'misappropriation' under the FIFA Code of Ethics, even before the 2020 edition expressly added the term. It also reaffirms CAS's deferential standard of review over internal disciplinary sanctions of sports associations, only intervening if the sanction is illegal, arbitrary, or disproportionate.
Summary
Laureano González, former president of the Venezuelan Football Federation (FVF) and CONMEBOL vice-president, was sanctioned by the FIFA Ethics Committee in October 2022 for authorizing payments totaling USD 410,363 to companies in Doral, Miami, and for purchasing 800 football kits from Textiles Flix, S.A. with FIFA funds, without proper documentation or evidence that the goods/services were delivered. The Committee found him responsible for breaching articles 13 (general duties), 15 (duty of loyalty), and 28 (misappropriation and misuse of funds) of the FIFA Code of Ethics, imposing a 5-year ban from all football-related activities and a fine of USD 410,363. González appealed to the Court of Arbitration for Sport (CAS), arguing that he had no operational role in daily finances, that the payments were for legitimate needs, and that the 2020 edition of the Code (which explicitly mentions 'misuse') should not apply retroactively. The CAS Panel, after a hearing in September 2024, dismissed the appeal. It held that the term 'misappropriation' in earlier editions of the Code already covered misuse of funds, as confirmed by FIFA Circular 1757. The Panel found that González had approved transactions to companies of dubious existence and failed to ensure funds were used for their intended purpose, violating his duties of loyalty and general care. The Panel also reviewed the sanction and found it proportionate, noting that the 5-year ban was the minimum possible and the fine reflected the amount misused. The award was issued on 2 May 2025, confirming the original decision.
The detail
Parties: TAS 2023 A 9362 Laureano González v. FIFA ES
Outcome: Appeal dismissed; CAS confirmed FIFA Ethics Committee's 5-year ban and USD 410,363 fine against González for misappropriation of funds and breach of duties.
Quantum: USD 410,363
Applicable law: FIFA Code of Ethics (2012, 2018, 2019, 2020 editions); Swiss law; CAS Code of Sports-related Arbitration
Issues in play: Whether the term 'misuse' of funds was covered under earlier editions of the FIFA Code of Ethics (which only mentioned 'misappropriation'), and whether the sanction was proportionate.
Read the full decision at Court of Arbitration for Sport (football, via FIFA) ↗
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