Labour Disputes
Texto da decisão
REF FPSD-2563
Decision of the
Dispute Resolution Chamber
passed on 8 October 2021
regarding an employment-related dispute concerning the player Robert de
Souza Ribeiro
BY:
Clifford J. Hendel (USA & France), Deputy Chairperson
Tomislav Kasalo (Croatia), member
Daan de Jong (The Netherlands), member
CLAIMANT / COUNTER-RESPONDENT:
Robert de Souza Ribeiro, Brazil
Represented by Mr. Breno Costa Ramos Tannuri
RESPONDENT / COUNTER-CLAIMANT:
Olympique Club de Safi, Morocco
Represented by Mr. Mohamed Ghazi
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I.
Facts of the case
1.
On 27 November 2020, the Brazilian player, Robert de Souza Ribeiro (hereinafter: the
Claimant/Counter -Respondent), and the Moroccan club, Olympique de Safi (hereinafter: the
Respondent) signed an employment contract valid as from 24 November 2020 until 30 June
2022.
2.
In accordance with the employment contract, the Respondent/Counter-Claimant undertook
to pay to the Claimant/Counter-Respondent inter alia a monthly salary of USD 3,000 at the
end of each month.
3.
Additionally, article 5.1 provided that the Claimant/Counter-Respondent would be entitled to
a sign on fee in the amount of USD 30,000, payable as soon as the contract is approved.
4.
Article 6 of the contract states that “(…) In case of failure, the dispute shall be submitted, by
either party, to the Dispute Resolution Chamber of the Royal Moroccan Football Federation.
The decisions of the FRMF Dispute Resolution Chamber are subject to appeal in accordance
with the provisions of the statutes and regulations of the FRMF”.
5.
By correspondence dated 2 February 2021, the Claimant/Counter-Respondent put the
Respondent/Counter-Claimant in default of payment of USD 36,000, consisting of the
outstanding salaries for the months of December 2020 to January 2021, as well as the sign
on fee (USD 30,000), setting a time limit of 15 days in order to remedy the default.
6.
On 18 February 2021, the Claimant/Counter-Respondent sent a second default notice to the
Respondent, confirming that the Respondent/Counter-Claimant had paid the outstanding
salaries, but failed to pay the outstanding sign-on fee in the amount of USD 30,000. As a
result, the Claimant/Counter-Respondent granted the Respondent/Counter-Claimant, 10
days to comply with its obligations.
7.
On 28 February 2021, the Respondent/Counter-Claimant replied to the default notice,
acknowledging the outstanding amount and proposing a payment plan as follows: 50% to
be paid by end of March 2021 and the balance to be paid by end of April 2021.
8.
On 1 March 2021, the Claimant/Counter-Respondent responded and agreed to the proposed
terms, but stated that if the Respondent/Counter-Claimant failed to timely comply with its
financial obligations, he would lodge a claim before FIFA.
9.
On 1 April 2021, the Claimant/Counter-Respondent sent another default notice to the
Respondent/Counter-Claimant stating that it had failed to make payment of the first
instalment (50%) of the sign-on fee as agreed and also failed to pay his salaries for February
and March 2021, granting the Respondent/Counter-Claimant 15 days to comply with its
obligations.
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10. On 19 April 2021, the Claimant/Counter-Respondent unilaterally terminated the contract
with the Respondent/Counter-Claimant for outstanding remuneration.
II. Proceedings before FIFA
11. On 18 May 2021, the Claimant/Counter-Respondent filed the claim at hand before FIFA. A
brief summary of the position of the parties is detailed in continuation.
a. Position of the Claimant/Counter-Respondent
12. According to the Claimant/Counter-Respondent, despite several
Respondent/Counter-Claimant failed to meet its financial obligations.
reminders,
the
13. The Claimant/Counter-Respondent further submits that the salaries for the months of
February, March 2021 and the first instalment of the sign-on fee, due at the end of March
2021, remained unpaid and that as a result, on 1 April 2021, he sent a final default notice to
the Respondent/Counter-Claimant requesting payment of the first instalment of the sign-on
fee in the amount of USD 15,000 and his salaries for February and March 2021 in the amount
of USD 6,000.
14. According to the Claimant/Counter-Respondent, the Respondent/Counter-Claimant did not
comply as requested and as a result, he unilaterally terminated the contract on 19 April 2021,
in his opinion, with just cause.
15. As a result of the above termination, the Claimant/Counter-Respondent submits that he had
to pay the cost of his flight to return to Brazil in the amount of Brazilian Reais (BRL) 6,000
(equivalent to USD 1,085), which he requests to be reimbursed by the Respondent/CounterClaimant.
16. Therefore, the Claimant/Counter-Respondent submits that he is entitled to the amount of
USD 37,085 plus 5% interest p.a. as outstanding remuneration as follows:
- USD 6,000 as salaries for February and March 2021;
- USD 30,000 as the sign on fee;
- USD 1,085 as the reimbursement of his flight costs.
17. In addition to outstanding remuneration, the Claimant/Counter-Respondent submits that
he is also entitled to compensation for breach of contract in the amount of USD 45,000
(USD 3,000 x 15 months residual duration of the contract for the period between April
2021 and June 2022), plus 5% interest p.a. as of 20 April 2021.
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b. Position of the Respondent/Counter-Claimant
18. The Respondent/Counter-Claimant in its reply contests FIFA’s competence to deal with the
current claim and states that in accordance with article 16 of the contract, the Dispute
Resolution Chamber (NDRC) of the Royal Moroccan Football Federation (FRMF) is competent
to hear the current claim.
19. According to the Respondent/Counter-Claimant , article 16 of the contract provides that in
case of disputes, either party, may submit the dispute to the NDRC) of the FRMF.
20. The Respondent/Counter-Claimant adds that the NDRC of the FRMF is competent,
independent and respects the principle of parity.
21. Therefore, the Respondent/Counter-Claimant submits that the international dimension of the
dispute should be disregarded, as the contract gives clear recognition to the NDRC of the
FRMF to handle the current dispute and that FIFA is incompetent to hear the current dispute.
22. In continuation, the Respondent/Counter-Claimant also submits that the Claimant/CounterRespondent had no just cause to terminate the contract.
23. In support of the above, the Respondent/Counter-Claimant states that further to the agreed
payment plan between the parties for the sign-on fee, all previous default notices have no
legal effect.
24. The Respondent/Counter-Claimant adds that further to the agreed payment plan, the
Claimant/Counter-Respondent sent another default notice, in which no deadline was
provided for making the payment, therefore it does not respect the requirements of article
14bis of the RSTP.
25. Moreover, the Respondent/Counter-Claimant submits that the default could only be evoked
if there was a significant debt and a few days' delay, i.e. 10 days according to FIFA regulations.
However, neither of these two conditions were met as on 1 April 2021, certain amounts
requested, in particular the 50% of the sign-on bonus and the salary for March 2021, were
not yet due and cannot even be considered, as being in arrears within the meaning of article
12bis of the RSTP, and consequently they cannot, in any case, be the basis for the termination
of the contract for just cause in application of article 14bis of the FIFA RSTP.
26. The Respondent/Counter-Claimant adds that the amount demanded (prematurely) by the
Claimant/Counter-respondent before the end of April 2021 does not fall within the scope of
the aforementioned article, since on that date it could not be considered in default of
payment. Consequently, and considering the constant practice of the FIFA, the matter at hand
cannot constitute a situation of just cause, for failure to observe the deadline and for the
absence of default in payment on the date of the formal notice.
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27. According to the Respondent/Counter-Claimant, the Claimant/Counter-respondent rushed
his departure by not giving it any chance to resolve the issue.
28. As a result, the Respondent/Counter-Claimant reiterates that the formal notice for nonpayment issued on 1 April 2021 does not grant it any time limit. Consequently, the
termination of the contract on 19 April 2021 on the basis of the notice of 1 April 2021 is
unfounded and could not, in any event, constitute just cause as the Claimant failed in his
obligation to grant it 15 days to comply.
29. For its part, the Respondent/Counter-Claimant submits that it was justified in disregarding
this notice, which remains, in many respects, pathological and it was entitled to not consider
it.
30. With respect to compensation requested by the Claimant/Counter-respondent, the
Respondent/Counter-Claimant submits that the situation of just cause does not arise insofar
as the Claimant/Counter-respondent failed to meet the requirements of article 14bis RSTP.
Consequently, according to the Respondent, the Claimant /Counter-respondent could not be
put in the position he would have been in had he not prematurely terminated the contract,
nor could he be entitled to receive additional compensation and that the sporting sanctions
to be imposed on it are therefore unfounded.
31. With the above in mind, the Respondent/Counter-Claimant submits that it owes the
Claimant/Counter-respondent USD 30,000 as the sign-on fee and USD 6,000 as salaries for
February and March 2021 and that FIFA should reject all other demands.
32. Additionally, the Respondent/Counter-Claimant lodged a counterclaim against the
Claimant/Counter-respondent, stating that the party who terminates the contract without
just cause (the Claimant) should pay compensation for breach of contract. As a result,
according to the Respondent/Counter-Claimant, the Claimant/Counter-Respondent should
pay the residual value of the contract in the amount of USD 42,000 as compensation for
breach of contract, subject to whether he signed a new contract with a new club and that
the Claimant/Counter-respondent should be ordered to submit any such contract so as to
establish the compensation due to the Respondent.
c. Claimant’s response to the counterclaim
33. In response to the counterclaim and the reply of the Respondent/Counter-Claimant, the
Claimant/Counter-Respondent first of all stated that the Respondent/Counter-Claimant
had failed to demonstrate the NDRC of the FRMF is an independent and duly constituted
tribunal.
34. Furthermore, in response to the counterclaim, the Claimant/Counter-Respondent stated that
it is clear that at the date of termination of the contract, i.e. 19 April 2021, more than 2
salaries were outstanding and that he had given the Respondent/Counter-Claimant multiple
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chances to comply by sending several default notices, granting a total of at least 15 days to
remedy the default.
35. Additionally, the Claimant/counter-Respondent submitted that he has remained unemployed
since the contract termination on 19 April 2021.
36. In conclusion, the Claimant/Counter-Respondent submitted that the counterclaim of the
Respondent/Counter-Claimant should be rejected.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
37. First of all, the Dispute Resolution Chamber (hereinafter also referred to as Chamber or DRC)
analysed whether it was competent to deal with the case at hand. In this respect, it took note
that the present matter was presented to FIFA on 18 May 2021 and submitted for decision
on 8 October 2021. Taking into account the wording of art. 34 of the October 2021 edition
of the Procedural Rules Governing the Football Tribunal (hereinafter: the Procedural Rules),
the aforementioned edition of the Procedural Rules is applicable to the matter at hand.
38. Subsequently, the members of the Chamber referred to art. 2 par. 1 of the Procedural Rules
and observed that in accordance with art. 23 par. 1 in combination with art. 22 lit. b) of the
Regulations on the Status and Transfer of Players (August 2021 edition), the Dispute
Resolution Chamber is in principle competent to deal with the matter at stake, which
concerns an employment-related dispute with an international dimension between a Brazilian
player and a Moroccan club.
39. However, the DRC acknowledged that the Respondent/Counter-Claimant contested the
competence of FIFA’s deciding bodies on the basis of art. 16 of the contract highlighting that
given the express choice of forum made by the parties in the contract, FIFA lacks jurisdiction
to adjudicate on this case and consequently, the claim lodged by the Claimant/counterRespondent shall be deemed inadmissible.
40. Taking into account the above, the Chamber emphasised that in accordance with art. 22 lit.
b) of the Regulations on the Status and Transfer of Players, it is competent to deal with a
matter such as the one at hand, unless an independent arbitration tribunal, guaranteeing fair
proceedings and respecting the principle of equal representation of players and clubs, has
been established at national level within the framework of the Association and/or a collective
bargaining agreement. With regard to the standards to be imposed on an independent
arbitration tribunal guaranteeing fair proceedings, the Chamber referred to FIFA Circular no.
1010 dated 20 December 2005. In this regard, the Chamber further referred to the principles
contained in the FIFA NDRC Standard Regulations, which came into force on 1 January 2008.
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41. In this regard, the Chamber noted that the Respondent/Counter-Claimant makes reference
to the Regulations of the FRMF and the procedural rules of the NDRC of the FRMF as proof
that the NDRC is independent and respects the principles of parity, however, the Chamber
deems that the evidence submitted is not sufficient to establish that the Moroccan NDRC is
impartial and meets the requirement of parity.
42. Additionally, the Chamber noted that the Claimant/Counter-Respondent submitted the entire
set of Regulations of the Moroccan NDRC, from which it can be noted that according to
article 3 (Jurisdiction of the NDRC), article 5 (Composition of the NDRC) and article 10
(Quorum) of the Regulations of the FRMF NDRC, it becomes undisputed that the parties do
not choose the arbitrators, but that this occurs through the Executive Committee of the FRMF.
As such, there appears to be a decisive influence from the FRMF over the appointment of
members of the Moroccan NDRC.
43. With the above in mind, the Chamber deemed that it could not reach the conclusion that the
FRMF NDRC meets the standards to be imposed on an independent arbitration tribunal
guaranteeing fair proceedings, established by the FIFA Circular 1010.
44. As a result, the Chamber concluded that FIFA is competent to hear the current claim and that
the argumentation of the Respondent/counter-Claimant, alleging the contrary, would need
to be rejected
45. Subsequently, the Chamber analysed which regulations should be applicable as to the
substance of the matter. In this respect, it confirmed that, in accordance with art. 26 par. 1
and 2 of the Regulations on the Status and Transfer of Players (August 2021 edition),and
considering that the present claim was lodged on 18 May 2021, the February 2021 edition
of said regulations (hereinafter: the Regulations) is applicable to the matter at hand as to the
substance.
b. Burden of proof
46. The Chamber recalled the basic principle of burden of proof, as stipulated in art. 13 par. 5 of
the Procedural Rules, according to which a party claiming a right on the basis of an alleged
fact, shall carry the respective burden of proof. Likewise, the Chamber stressed the wording
of art. 13 par. 4 of the Procedural Rules, pursuant to which it may consider evidence not filed
by the parties, including without limitation the evidence generated by or within the Transfer
Matching System (TMS).
c. Merits of the dispute
47. Its competence and the applicable regulations having been established, the Chamber entered
into the merits of the dispute. In this respect, the Chamber started by acknowledging all the
above-mentioned facts, as well as the arguments and the documentation on file. However,
the Chamber emphasised that in the following considerations it will refer only to the facts,
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arguments and documentary evidence, which it considered pertinent for the assessment of
the matter at hand.
i. Main legal discussion and considerations
48. The foregoing having been established, the Chamber moved to the substance of the matter,
and took note of the fact that the parties strongly dispute whether or not on 19 April 2021,
the Claimant/counter-Respondent had a just cause to terminate the contract.
49. The Chamber further noted that the Respondent/counter-Claimant did not contest that the
outstanding amounts requested by the Claimant/counter-Respondent, but submits that the
Claimant/counter-Respondent did not respect the requirements as per article 14bis of the
Regulations and that therefore, the Claimant/counter-Respondent terminated the contract
without just cause, filing a counterclaim for compensation payable to it by the
Claimant/counter-Respondent.
50. In this context, the Chamber acknowledged that its task was to determine whether or not on
19 April 2021, the Respondent/counter-Claimant was in arrears of its financial obligations
towards the Claimant/Counter-Respondent and whether this could lead the
Claimant/counter-Respondent to validly terminate the contract on said date.
51. With the above in mind, the Chamber noted that it remained uncontested between the
parties that on the date of termination, i.e. 19 April 2021, two monthly salaries linked to
months of February and March 2021 remained outstanding, as well as 50% of the sign-on
fee. The Chamber also noted that the Claimant/counter-Respondent put the
Respondent/counter-Claimant in default of payment and provided it with 15 days to remedy
its default, however to no avail.
52. At this point, the Chamber recalled the provisions set out in art. 14bis par. 1 of the
Regulations, according to which in the case of a club unlawfully failing to pay a player at least
two monthly salaries on their due dates, the player will be deemed to have a just cause to
terminate his contract, provided that he has put the debtor club in default in writing and has
granted a deadline of at least 15 days for the debtor club to fully comply with its financial
obligation(s).
53. Based on the foregoing, the Chamber concluded that on the date of termination of the
contract, 19 April 2021, the Respondent/Counter-Claimant was in serious violation of its
financial and contractual obligations towards the Claimant/counter-Respondent .
54. In view of the above, and taking into account the fact that the outstanding payments
remained uncontested, the Chamber concluded that the Claimant/counter-Respondent
terminated his contract with just cause on 19 April 2021 based on the contents of art. 14bis
of the Regulations and that the Respondent is to be held liable for the early termination of
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the contract with just cause by the Claimant/counter-Respondent. At this point, the members
of the Chamber decided reject the counterclaim of the Respondent/Counter-Claimant
ii. Consequences
55. Having stated the above, the members of the Chamber turned their attention to the question
of the consequences of such unjustified breach of contract committed by the
Respondent/Counter-Claimant.
56. As a consequence, and in accordance with the general legal principle of pacta sunt servanda,
the Chamber decided that the Respondent/counter-Claimant is liable to pay to the
Claimant/counter-Respondent, the amounts which were outstanding under the contract at
the moment of the termination, i.e. USD 22,085, consisting of the February and March 2021
salaries in the amount of USD 3,000 each, USD 15,000 as 50% of the sign-on fee and USD
1,085 as reimbursement for the flight ticket as substantiated by the Claimant/counterRespondent).
57. In addition, taking into consideration the Claimant/counter-Respondent’s request as well as
the constant practice of the Chamber in this regard, the latter decided to award the
Claimant/counter-Respondent interest at the rate of 5% p.a. on the outstanding amounts as
from the due dates until the date of effective payment as follows:
- on the amount of USD 3,000 as from 1 March 2021;
- on from the amount of USD 3,000 as from 1 April 2021;
- on the amount of USD 1,085 as 21 April 2021
- on the amount of USD 15,000 as from 1 May 2021.
58. Having stated the above, the Chamber turned to the calculation of the amount of
compensation payable to the Claimant/counter-Respondent by the Respondent/counterClaimant in the case at stake. In doing so, the Chamber firstly recapitulated that, in
accordance with art. 17 par. 1 of the Regulations, the amount of compensation shall be
calculated, in particular and unless otherwise provided for in the contract at the basis of the
dispute, with due consideration for the law of the country concerned, the specificity of sport
and further objective criteria, including in particular, the remuneration and other benefits due
to the player under the existing contract and/or the new contract, the time remaining on the
existing contract up to a maximum of five years, and depending on whether the contractual
breach falls within the protected period.
59. In application of the relevant provision, the Chamber held that it first of all had to clarify as
to whether the pertinent employment contract contained a provision by means of which the
parties had beforehand agreed upon an amount of compensation payable by the contractual
parties in the event of breach of contract. In this regard, the Chamber established that no
such compensation clause was included in the employment contract at the basis of the matter
at stake.
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60. As a consequence, the members of the Chamber determined that the amount of
compensation payable by the Respondent to the Claimant/counter-Respondent had to be
assessed in application of the other parameters set out in art. 17 par. 1 of the Regulations.
The Chamber recalled that said provision provides for a non-exhaustive enumeration of
criteria to be taken into consideration when calculating the amount of compensation payable.
61. Bearing in mind the foregoing as well as the claim of the Claimant/counter-Respondent, the
Chamber proceeded with the calculation of the monies payable to the Claimant/counterRespondent under the terms of the contract from the date of its unilateral termination until
its end date. Consequently, the Chamber concluded that the amount of USD 60,000 (USD
3,000 per month salary x 15 months + USD 15,000 as outstanding sign-on fee) shall serve as
the basis for the final determination of the amount of compensation for breach of contract.
62. In continuation, the Chamber verified as to whether the Claimant/counter-Respondent had
signed an employment contract with another club during the relevant period of time, by
means of which he would have been enabled to reduce his loss of income. According to the
constant practice of the DRC as well as art. 17 par. 1 lit. ii) of the Regulations, such
remuneration under a new employment contract shall be taken into account in the calculation
of the amount of compensation for breach of contract in connection with the player’s general
obligation to mitigate his damages.
63. In this regard, the Chamber noted that the Claimant/counter-Respondent had remained
unemployed and was therefore not able to mitigate his damages.
64. Consequently, on account of all of the above-mentioned considerations and the specificities
of the case at hand, the Chamber decided that the Respondent/counter-Claimant must pay
the amount of USD 60,000 to the Claimant/counter-Respondent which was to be considered
a reasonable and justified amount of compensation for breach of contract in the present
matter.
65. Lastly, taking into consideration the Claimant/counter-Respondent ’s request as well as the
constant practice of the Chamber in this regard, the latter decided to award the
Claimant/counter-Respondent interest on said compensation at the rate of 5% p.a. as of 18
May 2021, the date of claim, until the date of effective payment.
iii. Compliance with monetary decisions
66. Finally, taking into account the applicable Regulations, the Chamber referred to art. 24 par.
1 and 2 of the Regulations, which stipulate that, with its decision, the pertinent FIFA deciding
body shall also rule on the consequences deriving from the failure of the concerned party to
pay the relevant amounts of outstanding remuneration and/or compensation in due time.
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67. In this regard, the DRC highlighted that, against clubs, the consequence of the failure to pay
the relevant amounts in due time shall consist of a ban from registering any new players,
either nationally or internationally, up until the due amounts are paid. The overall maximum
duration of the registration ban shall be of up to three entire and consecutive registration
periods.
68. Therefore, bearing in mind the above, the DRC decided that the Respondent must pay the
full amount due (including all applicable interest) to the Claimant within 45 days of
notification of the decision, failing which, at the request of the Claimant, a ban from
registering any new players, either nationally or internationally, for the maximum duration of
three entire and consecutive registration periods shall become immediately effective on the
Respondent in accordance with art. 24 par. 2, 4, and 7 of the Regulations.
69. The Respondent shall make full payment (including all applicable interest) to the bank account
provided by the Claimant in the Bank Account Registration Form, which is attached to the
present decision.
70. The DRC recalled that the above-mentioned ban will be lifted immediately and prior to its
complete serving upon payment of the due amounts, in accordance with art. 24 par. 8 of the
Regulations.
d. Costs
71. The Chamber referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football
agent, or match agent”. Accordingly, the Chamber decided that no procedural costs were to
be imposed on the parties.
72. Likewise and for the sake of completeness, the Chamber recalled the contents of art. 25 par.
8 of the Procedural Rules, and decided that no procedural compensation shall be awarded in
these proceedings.
73. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made by
any of the parties.
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IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant/Counter-Respondent, Robert de Souza Ribeiro, is partially accepted.
2.
The Respondent/counter-Claimant, Olympique Club de Safi, has to pay to the
Claimant/counter-Respondent, USD 22,085 as outstanding remuneration plus 5% interest
p.a. as from the due dates until the date of effective payment as follows:
-
on the amount of USD 3,000 as from 1 March 2021;
on from the amount of USD 3,000 as from 1 April 2021;
on the amount of USD 15,000 as from 1 May 2021;
on the amount of USD 1,085 as of 21 April 2021.
3.
The Respondent/counter-Claimant has to pay to the Claimant/counter-Respondent,USD
60,000 as compensation for breach of contract plus 5% interest p.a as of 18 May 2021.
4.
Any further claims of the Claimant/counter-Respondent are rejected.
5.
The counterclaim of the Respondent/counter-Claimant is rejected.
6.
Full payment (including all applicable interest) shall be made to the bank account indicated in
the enclosed Bank Account Registration Form.
7.
Pursuant to art. 24 of the Regulations on the Status and Transfer of Players if full payment
(including all applicable interest) is not made within 45 days of notification of this decision,
the following consequences shall apply:
1. The Respondent/counter-Claimant shall be banned from registering any new players,
either nationally or internationally, up until the due amount is paid. The maximum
duration the ban shall be of three entire and consecutive registration periods.
2. The present matter shall be submitted, upon request, to the FIFA Disciplinary
Committee in the event that full payment (including all applicable interest) is still not
made by the end of the three entire and consecutive registration periods.
8. The consequences shall only be enforced at the request of the Claimant in accordance
with article 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.
9. This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
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Chief Legal & Compliance Officer
NOTE RELATED TO THE APPEAL PROCEDURE:
According to article 57 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
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FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request of a
party within five days of the notification of the motivated decision, to publish an anonymised or a
redacted version (cf. article 17 of the Procedural Rules).
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