Acórdão do FIFA
Processo FPSD-17964 OULAM BATAS_2025-11-13

REF. FPSD-17964

Decision of the
Dispute Resolution Chamber
passed on 13 November 2025
regarding an employment-related dispute concerning
the player Ayoub Abou Oulam Batas

COMPOSITION:
Frans DE WEGER (The Netherlands), Chairperson
Jorge GUTIÉRREZ (Costa Rica), Member
Michele COLUCCI (Italy), Member

CLAIMANT / FIRST COUNTER-RESPONDENT:
Ayoub Abou Oulam Batas, Spain
Represented by Pablo Sebastian Rodriguez

RESPONDENT / COUNTERCLAIMANT:
Urartu FC, Armenia

SECOND COUNTER-RESPONDENT:
Sutjeska, Montenegro

pg. 2

REF. FPSD-17964

I. Facts of the case
1.

The parties to this dispute are:
•

the Spanish player Ayoub Abou Oulam Batas (hereinafter: the Player or the Claimant /
Counter-Respondent);

•

the Armenian club Urartu FC (hereinafter: Urartu or the Respondent / Counterclaimant),
affiliated to the Football Federation of Armenia (FFA); and

•

the Montenegrin club Sutjeska (hereinafter: Sutjeska or the Second CounterRespondent), affiliated to the Football Association of Montenegro (FSCG).

2.

On unspecified dates in 2024, the Player and an individual named Erik Vardanyan - who,
according to the Player, is a directive of Urartu, and according to Urartu, is an intermediary
- (hereinafter: Mr. Vardanyan) exchanged several messages regarding the Player’s future. In
these messages, the Player and Mr. Vardanyan decided to initiate conversations with an
Armenian club, two Kazakh clubs, and Saudi Arabian and Russian clubs. Furthermore, Mr.
Vardanyan informed the Player that he would always have a place in “his” team, Urartu.
Lastly, Mr. Vardanyan invited the Player to sign a contract “with them, as they have a lot of
contacts” and the Player asked him which agency he represented.

3.

On 7 June 2024, Mr. Vardanyan forwarded the following offer to the Player:
“Dear Mr. AYOUB,
We are happy to notify you about the interest of FC Urartu (professional Football Club)
in your high-quality services of professional football player. We would be glad to see you
in our team. We present to you the conditions for joining our team:
1. Employment agreement for a period of 2 years (up to 30.05.2026).
2. Fixed monthly salary in amount of 7300 (seven thousand) US Dollars GROSS.
3. Payment of bonuses when winning Armenian Football Cup matches. The bonus
amount is determined by the decision of the Club President.
4. Accommodation on the territory of the Urartu Football Club Sport complex. Three
meals a day, a swimming pool, a recitation area, a gym and other necessary conditions
for living, Payment from the resident is 300$.

pg. 3

REF. FPSD-17964

5. Two round air ticket to home city and back per football season.”
4.

It must be noted that this offer contained Urartu’s letterhead and was addressed by an
individual named Dmitry Kudryashov to the Player.

5.

Between 7 June and 17 June 2024, the Player and Mr. Vardanyan exchanged several
WhatsApp messages related to the Player’s transfer to Urartu. In particular:
•

On 8 June 2024, the Player and Mr. Vardanyan had the following conversation
(quoted verbatim):
Mr. Vardanyan: “hermano no es asi que ellos lo que dicen tienes que aceptar llevo
mucho tiempo peleando i lo sabes tu hemos hecho trabajo hermano
yo trabajo en Urartu i no puedo ir en frente al club por eso hablo el
agentr de aqui aqui. mas de 5500 mil no hay salario i el te da 7 mil mas
sign of fee
si tu me dices que no tme quedo como tonto aquí
jugando en conference league veras que vas a tener oferta de buena
liga
ponemos clausula 300 mil euros como dices tu y 20%”
Player:

“Hermano!! Por 7 me quedo en Bulgaria y el equipo tmb juega
conference league Mi hermano me ha dicho esto”

Mr. Vardanyan: “hermano le digo la verda mas no puedo subir el salario tu me decías
primer año 7 segundo 9 ahora ha subido mas es imposible i nosostros
enpezamos hoy los entrenos
si quieres hacemos un conference call con el entrenador para que veas
que quiere que estes aquí”
Player:

“Hermano por el dinero que me dais me quedo en Bulgaria”

Mr. Vardanyan: “si pero te dan sign of fee hermano
el entrenador i el presidente saben que ya has aceptado me quedo
como tonto bro
si quieres hablo con tu hermano” (…)
Freely translated into English:
Mr. Vardanyan: “Brother, it's not that you have to accept what they say. I've been
fighting for a long time, and you know it. We've done the work, brother.
I work at Urartu, and I can't go to the club, so I'm talking to the agent
here. There's no salary over 5,500, and he's giving you 7,000 plus a

pg. 4

REF. FPSD-17964

signing fee
If you tell me no, I'll look like a fool here
playing in the Conference League. You'll see that you'll get offers from
good leagues.
We'll put in a clause for 300,000 euros, as you say, and 20%.”
Player:

“Brother! For 7, I'll stay in Bulgaria, and the team also plays in the
Conference League.
My brother told me this.”

Mr. Vardanyan: “Brother, I'm telling you the truth, but I can't raise the salary. You told
me 7 for the first year and 9 for the second, but now it's gone up even
more. It's impossible, and we're starting training today.
If you want, we can do a conference call with the coach so you can see
that he wants you here."
Player:

“Brother, for the money you're offering me, I'm staying in Bulgaria.”

Mr. Vardanyan: “Yes, but they're giving you a signing fee, brother.
The coach and the president know you've already accepted. I'll look like
a fool, bro.
If you want, I'll talk to your brother.” (...)
•

On 13 June 2024, the Player and Mr. Vardanyan had the following conversation
(quoted verbatim):
Player:

“Hermano y como que pagais en cash?
Los jugadores donde ponen el dinero”

Mr. Vardanyan: “hermano 500 dolares envían en la carta i lo demas cash es por
escapar unpoco de los taxes sabes pero tendras carta bancaria
también puedes poner allí tu dinero”
Freely translated into English:
Player:

“Brother, how do you pay in cash?
Where do the players put the money?”

Mr. Vardanyan: “Brother, they send $500 in the letter and the rest in cash to avoid some
of the taxes, you know, but you'll have a bank letter, so you can also
put your money there.”
•

On 16 June 2024, Mr. Vardanyan forwarded to the Player a document titled “Batas
Ayoub Agreement”. This document contained 17 pages and included a page

pg. 5

REF. FPSD-17964

establishing that the Player was entitled to USD 7,200 gross. The Player mentioned
that he would have the contract reviewed the following day.
On 17 June 2024, the Player and Mr. Vardanyan had the following conversation
(quoted verbatim):

•

Player:

“Hay muchas cosas que no están bn en el contrato”

Mr. Vardanyan: “que cosas?”
Player:

“7200 pone que no es neto”

Mr. Vardanyan: “7200 gross 7000 neto”
Player:

“Solo el dinero 200 000 amd pone que es neto
La cláusula de 300 mil euros, solo pone que el jugador pone que coge
el 20 por ciento
Esto es lo que me mando
Hoy lo revisará bn”

Freely translated into English:
Player:

“There are many things that are not right in the contract”

Mr. Vardanyan: “What things?”
Player:

“7200 says it's not net"

Mr. Vardanyan: “7200 gross, 7000 net”
Player:

•

6.

“Only the 200,000 AMD says it's net.
The 300,000 euro clause only says that the player gets 20 per cent.
This is what he sent me.
He'll review it today."

Additionally, on the same day, Mr. Vardanyan sent a voice message to the Player,
explaining that AMD 200,000 was equivalent to USD 500 and that “they” would pay
taxes on that amount. In this regard, Mr. Vardanyan stated that the Player would
receive AMD 200,000 on his bank account and the remaining amount in cash.

On an unspecified date, the Luxembourger club Swift Hesperange offered the Player a twoyear contract valid as from 1 July 2024 until 30 May 2026. The Player would receive EUR
44,000 net for the first season and EUR 49,500 net for the second season.

pg. 6

REF. FPSD-17964

7.

According to the Player, on 17 June 2024, he concluded an employment contract with
Urartu valid as from that date until 1 June 2026. Also according to the Player, this contract
included the following annex (hereinafter: the Alleged Annex):
“1. The Football Player shall be entitled to:
1.1. The amount of fixed monthly salary, without consideration of incentive bonuses
and compensations: in Armenian dram (AMD) equivalent to 7200 (seven thousand
two hundred) USD GROSS per month and shall be payable by the exchange rate
of the Central Bank of the Republic of Armenia on the last calendar day of the
month, which is previous to the month of the payment;
1.2. Payment in the amount of 20% (GROSS) of any amount of a paid transfer to a
third Club;
1.3. Accommodation on the territory of the Urartu Football Club Sport complex. Three
meals a day, a swimming pool, a recitation area, a gym and other necessary
conditions for living;
1.4. Two round air ticket per football season.
2. The annex shall enter into force from the date of signing and can only be changed by
mutual consent of parties through making up one document.”

8.

It must be noted that there is no signed copy of the Alleged Annex on file.

9.

On 19 June 2024, the Player and Mr. Vardanyan had the following conversation (quoted
verbatim):
Mr. Vardanyan: “hermano es por eso que nosotros damos los taxes de esos 500
dolares si ponemos 7000 es mucho dinero en armenia el porcentaje de
los taxes es alto
por eso te dan 500 dolares en la carta que se ve i 6600 dolares en la
mano”
Player:

“muchas gracias hermano”
(…)”

Mr. Vardanyan: “hermano tu vas a cobrar 7 mil netos
lo del 30 mil no te preocupes por nada
cuando este el presidente el te va a dar
sobre la clausula esta puesto en moneda armenia”

pg. 7

REF. FPSD-17964

Freely translated into English:
Mr. Vardanyan: “Brother, that's why we pay taxes on those 500 dollars. If we put in
7,000, that's a lot of money in Armenia. The tax rate is high,
that's why they give you 500 dollars in the letter, and 6,600 dollars in
your hand.”
Player:

“Thank you very much, brother”
(…)”

Mr. Vardanyan: “Brother, you're going to get 7,000 net.
Don't worry about the 30,000.
When the president is here, he'll give it to you.
The clause is in Armenian currency.”
10. On 21 June 2024, the Player and Urartu entered into another employment contract
(hereinafter: the Contract) valid as from the date of signature until 1 June 2026.
11. Clause 2.1.37 of the Contract established as follows:
“2.1.37. The Football Player agrees that according to the decision of the Club, he can be
transferred to the reserve team or another team (lower division) of the Club for the
participation in the football matches of a lower sporting level or to another team of the
Club, without changing of the main terms of this Contract.”
12. Clause 6 of the Contract stipulated:
“6. SALARY AND OTHER REWARDS
1. The Football Player shall be entitled to the amount of monthly salary, stipulated in
Annex to this Contract, which is an integral part of the Contract.
2. The salary should be paid each month during the period from 1 to 15 of the next
month by transferring by wire transfer to the bank account or cash. The Club shall be
entitled to choose the type and method of salary payment.
3. Acknowledging the economic situation, the salary and the system of its payment can
be indexed and (or) overviewed in the scope of exchange conversion.”
13. Clause 7 of the Contract provided the following:
“7. TERMINATION OF THE CONTRACT

pg. 8

REF. FPSD-17964

(…)
7.2. With a subject to payment of compensation, determined in article 2. of this Contract,
the Football Player has a right to prematurely and unilaterally (at its own initiative)
terminate this Contract (at his own will), notifying the Club not less than one month
before the termination in accordance with requirements of the part 1 of article 112 of
the Labour Code of the Republic of Armenia and relevant terms of Regulations for the
Status and Transfer of players FIFA and FFA, fully paying the Club the compensation,
stipulated in article 8.1.2 of the present Contract.
(…)”
14. Clause 8 of the Contract set forth:
“8. SECURING STABILITY OF THE CONTRACT
8.1. According to the requirements of the FIFA Players Status and Transfer Regulations,
if the Football Player violates terms and conditions of this Contract without any
reasonable excuse, the Club may impose on the Football Player disciplinary sanctions in
accordance with FIFA, UEFA, FFA statutes and regulations, active legislation of Republic
of Armenia, insofar as it does not contradict to statutes and regulations of FIFA, UEFA
and FFA and (or) Swiss Law, and this Contract, including, but not limited to deprivation
of the Football Player in full or in part of his right to receive monthly bonuses and
compensations for the corresponding month. Such deprivation (penalties) and the
procedure of disciplinary procedures and/or investigations are set out in article 12 of the
Contract.
8.1.1.In order to maintain the stability of the Contract, being governed by the article 17
and other applicable provisions of FIFA regulation : “on the Status and Transfer of
Players”, the Club and the Football Player have agreed, that in accordance with article
112 of the Labour Code of the Republic of Armenia in case of termination of this Contract
by the initiative of the football Player (at his own will) or in case of termination of this
Contract upon the initiative of the Club on disciplinary grounds, which can be qualified
as disciplinary sanction in accordance with part 2 of article 223 of the Labour Code of
the Republic of Armenia the Football Player should pay to the Club a monetary
compensation.
8.1.2. In accordance with the article 8.1.1 of the present Contract, if the Contract is
prematurely and unilaterally terminated by the Football Player (at his own will) or in case
of termination of this Contract upon the initiative of the Club on disciplinary grounds,
the Football Player shall be obliged to pay a fine in 140,000,000 (one hundred and four
million) in Armenian dram (AMD) as a liquidated damage.”
15. Clause 13.1 established:

pg. 9

REF. FPSD-17964

“Hereby I, the Football Player, verify, the following:
13.1.1 have received an original signed version of the Contract and the Annex to it, and
also I have read the Club Rules and all other rules and regulations of the Club affecting
me.
(…)”
16. Also on 21 June 2024, the Player and Urartu concluded a document titled “Annex to the
Contract” (hereinafter: the Annex), which established:
“To fulfill items 3.1.1., 6.1, of the Agreement in order to establish the amount of salary
and order of its payment the Club and Football Player agrees to settle the following
binding conditions.
1. The Football Player shall be entitled to receive an amount of 200,000 AMD NET fixed
monthly salary, which doesn't include taxes and other obligatory payments, set forth by
the legislation of R.A.
2. Annex is executed in three bilingual originals, of equal legal force, in Armenian and
English languages. In case of discrepancies the English text shall prevail.
3. The annex shall enter into force from the date of signing and can only be changed by
mutual consent of parties through making up one document.”
17. It must be noted that, according to the Player, the Alleged Annex was not combined with
these documents.
18. On 1 August 2024, Mr. Vardanyan was appointed as Urartu’s sporting director.
19. On 13 August 2024, an unidentified person sent a message in a WhatsApp group called “FC
Urartu” (hereinafter: the WhatsApp Group) stating that on 14 August 2024, between 13:00
and 15:00 hours, the activity “salary” would be held. This individual also stated that those
who were unable to attend and receive their salary would only be able to do so the
following week.
20. On 15 August 2024, the Player and Mr. Vardanyan had the following WhatsApp
conversation:
Mr. Vardanyan: “me dijo el abogado que querías el
contrato ?
te envie
que ha pasado ? “

pg. 10

REF. FPSD-17964

Player:

“Hermano
Todo bn y tu
Perdona que estaba en video
Faltan dos hojas
Contrato incompleto
(attaches picture of the Alleged Annex)
Faltan estas dos”

Mr. Vardanyan: “pero te han dado menos ?
salario.”
Player:

“Si pero lo va a revisar la chica me dijo
Le puedes pedir porfa el contrato completo al abogado para subirlo
mañana a la página de la asociación”

Mr. Vardanyan: “Necessitas el anexo?
Esto (quoting picture of the Alleged Annex)”
Player:

“si”

Mr. Vardanyan: “vale mañana hablamos i te la doy
Pero no la damos a nadie”
Player:

“ok
A quien se la voy a dar
Es para la asociación y para mi nadie más”

Mr. Vardanyan: “es por otra cosa mañana te cuento”
Freely translated into English:
Mr. Vardanyan: “The lawyer told me you wanted the contract?
I sent it to you.
What happened?”
Player:

“Brother,
everything's fine. How are you?
Sorry, I was on video.
Two pages are missing.
The contract is incomplete
(attaches picture of the alleged annex).
These two are missing.”

pg. 11

REF. FPSD-17964

Mr. Vardanyan: “But have they given you less?
Salary.”
Player:

“Yes, but the girl is going to review it, she told me
Can you please ask the solicitor for the complete contract to upload it
tomorrow to the association's website?”

Mr. Vardanyan: “Do you need the annex?
This (quoting picture of the Alleged Annex)”
Player:

“Yes.”

Mr. Vardanyan: “Okay, we'll talk tomorrow and I'll give it to you.
But we're not giving it to anyone else.”
Player:

“Okay.
Who am I going to give it to?
It's for the association and for me, no one else.”

Mr. Vardanyan: “It's for something else. I'll tell you tomorrow."
21. On 19 August 2024, the Player and Mr. Vardanyan had the following WhatsApp
conversation (quoted verbatim):
Player:

“Ya te paso el documento la chica? O voy yo a hablar con ella ahora ?”

Mr. Vardanyan: “estoy con ella dice que tiene que hablar con el presidente”
Player:

“Vale!! Va a hablar con él hoy?”

Mr. Vardanyan: “yo creo que va a decor que no hermano
no puedes entender como trabaja el club”
Freely translated into English:
Player:

“Did the girl give you the document? Or shall I go and talk to her now?”

Mr. Vardanyan: “I'm with her. She says she has to talk to the chairman.”
Player:

“OK! Is she going to talk to him today?”

Mr. Vardanyan: “I think he's going to say no, mate.

pg. 12

REF. FPSD-17964

You don't understand how the club works.”
22. On 11 September 2024, a contact saved by the Player as “David Team Manager Urartu”
(hereinafter: Mr. David) sent a message in the WhatsApp Group stating that, on that day at
19:15 hours, the activity “salary” would be held.
23. On 14 October 2024, an unidentified person informed in the WhatsApp Group that, on that
day at 17:00 hours, the activity “salary” would be held.
24. On 12 November 2024, a contact saved by the Player as “Areg Traductor Urartu”
(hereinafter: Mr. Areg) informed in the WhatsApp Group that, on that day at 17:30 hours,
the activity “salary” would be held.
25. On 2 December 2024, Mr. Areg forwarded two flight tickets to the Player. While the first
ticket appeared to be for a flight on 6 December 2024 from Yerevan (Armenia) to
Casablanca (Morocco), the second one was for a flight on 8 January 2025 from Barcelona
(Spain) to Yerevan (Armenia).
26. On 3 December 2024, Mr. Areg informed in the WhatsApp Group that on 4 December 2024
at 13:00 hours, the activity “salary” would be held.
27. On 23 December 2024, the Player and Mr. Areg had a WhatsApp conversation, in which the
latter informed the Player that his flight ticket to return to Urartu had been cancelled. The
Player requested an explanation and Mr. Areg explained him that when a player is not
returning to Urartu, the directives cancel the return flight ticket. The Player alleged that he
still had a valid contract with Urartu and argued that he had to return to Urartu since his
clothes were there.
28. Also on 23 December 2024, the Player informed Mr. Vardanyan that his flight ticket had
been cancelled. Mr. Vardanyan recalled that the Player had told him he would sign an
agreement and offered to buy him a ticket. The Player stated that they would reach an
agreement but argued that he still had 15 (sic) months remaining on his contract.
Additionally, he alleged that if Urartu did not want him to attend training, they should send
him a letter granting him leave. Moreover, they had the following conversation (quoted
verbatim):
Mr. Vardanyan: “hermano yo si me dejas intento buscar equipo has jugado todos los
partidos casi seguro que algo encontrare”
Player:

“Hablaré después con el agente
Si el presidente quiere que rescinda el contrato teniendo 15 meses más,
me tendrá que pagar algo, como hacen todos los clubes”

Mr. Vardanyan: “(voice message)

pg. 13

REF. FPSD-17964

cuantos meses ?
igualmente te voy a pagar yo pero quiero saber cuantos meses”
Player:

“Que no cojo tu dinero hermano de verdad
El que decidió eso es el presi , Q Lo tendrá que pagar el
Que me diga el hermano”

Mr. Vardanyan: “el no va a pagar hermano para mi es mejor que te page yo porque
ami me va a decir que page yo porque el fichaje lo hize yo”
Player:

“El decide y se piensa que todo es fácil, o como quiere
Hermano si quieres hablo con el
Yo no tengo problema ni miedo de verdad”

Mr. Vardanyan: “hermano puedes hablar
si tu piensas o el abogado que ganaras algo puedes denunciar a la fifa”
Player:

“Yo no quiero llegar a eso
Pero tú has visto lo que hacen
Me quitan el vuelo de vuelta”

Freely translated into English:
Mr. Vardanyan: “Brother, if you let me, I'll try to find a team. You've played in every
match, so I'm almost certain I'll find something.”
Player:

"I'll talk to the agent later.
If the president wants me to terminate my contract with 15 months left,
he'll have to pay me something, like all clubs do.”

Mr. Vardanyan: “(voice message)
How many months?
I'll pay you anyway, but I want to know how many months.”
Player:

“I'm not taking your money, brother, really
The one who decided that is the president. He'll have to pay me
Tell me, brother.”

Mr. Vardanyan: “He's not going to pay, brother. It's better for me to pay you because
he'll tell me to pay you because I made the signing.”
Player:

“He decides and thinks everything is easy, or however he wants.
Brother, if you want, I'll talk to him.
I really don't have a problem or fear.”

pg. 14

REF. FPSD-17964

Mr. Vardanyan: “Brother, you can talk
if you or your solicitor think you'll win something, you can report it to
FIFA.”
Player:

“I don't want to go that far
But you've seen what they're doing
They're taking away my return flight.”

29. On 24 December 2024, Mr. Vardanyan asked the Player whether they should send him his
clothes or buy him a flight ticket. The Player stated that he had 17 months remaining on
his contract and that, by cancelling the ticket, Urartu was breaching the agreement. Mr.
Vardanyan informed the Player that he had spoken to Mr. David and told him that they
needed to purchase the ticket. In this regard, Mr. Vardanyan stated that they would buy
the ticket and asked the Player to inform him how many months he wanted. Lastly, Mr.
Vardanyan acknowledged that it was a difficult situation.
30. On 30 December 2024, Mr. Areg sent the Player the following message:
“Hola máquina, como va todo?
Por favor no hagas ninguna publicación te mudas a otro club hasta que Urartu haga
una declaración oficial.”
Freely translated into English:
“Hello machine, how's everything going?
Please do not post anything about you moving to another club until Urartu makes an
official statement.”
31. On 3 January 2025, the Player sent a notice to Urartu, stating that he had been informed
Urartu would no longer consider him for training and matches, which could constitute a
termination without just cause. The Player noted that the Contract was valid until 31 May
2026 and stated that, if Urartu continued breaching the Contract, it would have to pay him
the entire value of the Contract, totalling USD 122,400. Additionally, the Player mentioned
that (i) Urartu had failed to provide him with the second flight ticket agreed for the current
season, as well as the two tickets stipulated for the second season, and (ii) it had failed to
provide him with a complete copy of the Contract. Based on this, the Player granted Urartu
15 days to: (i) reinstate him to his duties or, alternatively, pay the entire value of the
Contract; (ii) provide him with the three missing flight tickets; and (iii) provide him with the
complete copy of the Contract.
32. On 5 January 2025, Urartu sent an email to the Player, reminding him that the training
camp of the first team would begin on 9 January 2025. Therefore, Urartu requested that

pg. 15

REF. FPSD-17964

the Player be at Urartu on that date at 11:00 hours and offered him a flight ticket for 8
January 2025 from Barcelona (Spain) to Yerevan (Armenia).
33. On 6 January 2025, the Player replied to Urartu’s email, expressing appreciation for the
opportunity to work with Urartu and his desire to join the team. However, he also
expressed surprise, stating that he had understood the Contract had been terminated and
that Urartu had cancelled his return ticket. The Player reminded Urartu that he should train
with the first team and not separately and requested confirmation of his flight ticket.
34. Also on 6 January 2025, Urartu replied to the Player’s email dated 3 January 2025, arguing
that the legal representative had failed to provide any power of attorney.
35. On 7 January 2025, Urartu sent the Player a flight ticket.
36. On 8 January 2025, the Player flew from Barcelona (Spain) to Yerevan (Armenia).
37. On an unspecified date, the Player and Mr. Vardanyan had a call regarding the situation,
during which the Player informed him that he would not sign a termination agreement
without receiving any salary, as he still had 17 months remaining on his contract.
38. On 9 January 2025, Urartu replied to the Player’s email, arguing that the information
included therein was inaccurate and did not reflect the actual situation. Urartu alleged that
it had all the necessary documents and evidence to prove that its actions were legitimate
and justified. Urartu stated that it had invited the Player to participate in training camps,
and he had confirmed his willingness to attend, indicating that there were no
contradictions or issues. Lastly, Urartu remarked that the terms outlined in the letter were
false and erroneous, and that there was no ongoing or existing dispute between the
parties.
39. On an unspecified date, the Player recorded a video of himself training alone in the gym.
40. Also on an unspecified date, the Player recorded a video of the team playing a match and
claimed that he had trained alone.
41. Also on an unspecified date, the Player recorded a video of himself training alone in the
gym and stated that it was the second day he was training alone.
42. Also on an unspecified date, the Player recorded a video stating that the team was training
and that he was waiting to train alone.
43. Also on an unspecified date, the Player recorded a video stating that he was training alone.
44. Allegedly on 10, 11, 12, 13, 14, 15, 18, 19, and 20 January 2025, Urartu recorded videos
showing the Player training with the team.

pg. 16

REF. FPSD-17964

45. On 21 January 2025, the Player recorded a video showing that he underwent medical tests.
According to the Player, the entire team had undergone the tests on 9 January 2025.
46. Also on 21 January 2025, the physical coach of Urartu sent a letter to the head coach stating
that some players of the main team were in low physical condition after the winter break
and recommended that they not participate in the training camp in the UAE. He
recommended an individualized recovery and strength program at Urartu’s facilities under
his supervision until 15 February 2025. The Player was included in the list of four players.
47. On an unspecified date, 26 players and 16 coaches and staff were included in a list titled
“Urartu Football Club Delegation List”. The Player was not included in the list.
48. On an unspecified date, the Player recorded a video from Urartu’s premises, stating that
the entire team had travelled to Dubai and that he had been left alone, without any
member of the technical or medical staff.
49. On 24 January 2025, the Player sent a new letter to the Club, immediately terminating the
Contract, citing just cause based on art. 14 of the Regulations on the Status and Transfer
of Players (hereinafter: the Regulations). The Player argued that, on 8 January 2025, he
returned to Urartu, and on 9 and 10 January, he trained alone. Moreover, he stated that,
as of 11 January 2025, he was only allowed to participate in the initial part of training with
his teammates and was then required to train alone. He further argued that all the players
travelled to a pre-season camp in Dubai, except for him, and that he was left without
supervision. In addition, the Player alleged that Urartu failed to provide him with a copy of
the complete Contract, including a signed copy of the Alleged Annex. Notwithstanding the
above, the Player granted the Club 48 hours to explain and clarify his situation and justify
the decision to exclude him from the pre-season camp. He stated that, in the absence of a
satisfactory response, he would ratify the termination.
50. On 25 January 2025, Urartu sent an email to the Player, noting his absence from the training
session scheduled for that day. Urartu requested that the Player provide a written
explanation for his behaviour within one day.
51. On 25 January 2025, the Player replied to Urartu’s email, stating that the conditions for him
to attend training had not been met, as Urartu was continuously breaching the Contract.
He alleged that he was training alone and without supervision from the medical or technical
staff. The Player argued that it was unreasonable to demand his reinstatement until the
breaches were remedied. Lastly, he reserved his right to initiate legal action.
52. Also on 25 January 2025, Urartu sent an email to the Player, requesting that he attend
training on 26 January 2025. Urartu stated that failure to do so would compel it to initiate
disciplinary proceedings.

pg. 17

REF. FPSD-17964

53. On 25 January 2025, the Player replied to Urartu’s email, informing Urartu that his legal
representative had already sent an email explaining the reason for his absence from
training.
54. On 27 January 2025, Urartu sent an email to the Player, notifying him that he was required
to attend training at 11:00. Urartu stated that the training process was supported by its
representatives and claimed that it fully understood the Player’s motivation behind his
behaviour. Urartu also requested that the Player’s representative refrain from sending
repeated notifications. Lastly, Urartu requested that the Player fulfil his contractual
obligations in a timely manner.
55. Also on 27 January 2025, the Player sent a new email to Urartu, acknowledging receipt of
the email dated 27 January, in which he was summoned to attend training. In this letter,
the Player reiterated that the Contract had already been terminated due to Urartu’s fault.
He stated that he had been forced to train alone while the rest of the team travelled to
Dubai. The Player reaffirmed the termination of the Contract and informed Urartu that he
would lodge a claim before FIFA.
56. On 28 January 2025:
•

Urartu replied to the Player’s email, outlining the latest developments in the
relationship between the parties. In this regard, Urartu alleged that the parties had
intended to sign a mutual termination agreement, but the Player later refused to
sign it and instead sent an unsolicited email containing several claims, which it
responded to. Urartu further stated that, since the Contract was not mutually
terminated, it requested the Player’s return and purchased a flight ticket for him.
Urartu argued that the Player trained with the team but, due to his poor physical
condition, was assigned a personal training plan. However, Urartu alleged that,
unexpectedly, the Player terminated the Contract. Urartu rejected all allegations
of discrimination and abandonment and claimed that the Player had terminated
the Contract without just cause. Urartu requested that the Player revoke his
termination letter within three days, failing which it would seek enforcement of the
liquidated damages clause included in the Contract. Lastly, Urartu informed the
Player that he had been sanctioned with a reprimand.

•

The Player informed Urartu that the matter had already been submitted to the
Football Tribunal.

•

The Player and Mr. Vardanyan had a WhatsApp call.

•

Mr. Milija Savović, Sutjeska’s coach (hereinafter: Sutjeska’s Coach), contacted the
Player via WhatsApp, informing him that “Sinisa” had given him his number.
Sutjeska’s Coach asked the Player if he was interested in joining Sutjeska, and the
Player requested three days to consider the offer.

pg. 18

REF. FPSD-17964

57. On 29 January 2025, the Player and Mr. Vardanyan had the following WhatsApp
conversation (quoted verbatim):
Mr. Vardanyan: “Ayoub como estas ?
hermano si no quieres hablar conmigo dime i no te escribo mas”
Player:

“Normal aquí sin equipo sin nada, que el Urartu me puso en esta
situación difícil y tu?”

Mr. Vardanyan: “que dice el agente ?
no hay nada ?”
Player:

“No hay nada, todos los que han hechado nadie tiene equipo
Te dije que no es fácil después de armenia”

Mr. Vardanyan: “te llamo el del georgia ? o no te ha llamado nadie ?”
Player:

“No me llamo nadie
Dejare el fútbol te lo juro
El Urartu me ha jodido la carrera”

Mr. Vardanyan: “no digas eso porfavor no pienses así”
Player:

“Te lo juro no tengo ganas de nada
Iba todo bien y luego el presidente decide que me vaya fuera
Que le hize tío?
Si no jugaba podía entender que decida que me vaya”

Mr. Vardanyan: “cuando puedas llámame
si tendras ganas de hablar
que yo me siento culpable de verda no me imaginaba todo esto”
Player:

“Culpable el presidente de todo esto”

Mr. Vardanyan: “no tenias que ir a fifa pero ya paso solo que no quiero que tengas
problemas
i lo que no quiero que nuestra amistad se acabe espero que entiendas
que yo no queria todo esto
familia como esta ?”
Player:

“Porque no tenia que ir a la fifa?
Habéis Incumplido muchas cosas
Yo entrenando solo

pg. 19

REF. FPSD-17964

Me usaban solo cuando no hay jugadores
El equipo se va a Dubái, lleváis a juveniles y lesionados y ayoub
abandonado solo en erevan”
Freely translated into English:
Mr. Vardanyan: “Ayoub, how are you?
Brother, if you don't want to talk to me, just say so and I won't write to
you anymore.”
Player:

“Normal here, no team, nothing. Urartu put me in this difficult
situation. How about you?”

Mr. Vardanyan: “What does the agent say?
Nothing?”
Player:

“Nothing, everyone who's been let go has no team.
I told you it's not easy after Armenia.”

Mr. Vardanyan: “Did the guy from Georgia call you? Or has no one called you?”
Player:

“No one called me.
I'm going to quit football, I swear.
Urartu has ruined my career.”

Mr. Vardanyan: “Please don't say that. Don't think like that.”
Player:

"I swear, I don't feel like doing anything.
Everything was going well, and then the president decided to send me
away.
What did I do to him?
If I wasn't playing, I could understand him deciding to let me go.”

Mr. Vardanyan: “When you can, call me
if you feel like talking
because I feel really guilty. I never imagined all this would happen.”
Player:

“The chairman is to blame for all this."

Mr. Vardanyan: “You didn't have to go to FIFA, but it's already happened. I just don't
want you to have any problems
and I don't want our friendship to end. I hope you understand that I
didn't want any of this.
How is your family?”

pg. 20

REF. FPSD-17964

Player:

“Why didn't I have to go to FIFA?
You've broken many promises.
I'm training alone.
They only use me when there are no other players.
The team is going to Dubai, you're taking the youth players and the
injured players, and you've left Ayoub alone in Yerevan.”

58. On 31 January 2025, Jovan Papovic, Sutjeska’s general secretary (hereinafter: Sutjeska’s
General Secretary) sent the Player a flight ticket.
59. On 1 February 2025, Urartu sent a new email to the Player with a note dated 31 January
2025, stating that he was not even attempting to continue the employment relationship.
Moreover, Urartu imposed a reprimand on the Player due to his absences and informed
him that, if he continued with such behaviour, it would have no other choice but to
terminate the Contract.
60. On 2 February 2025, the Player and Mr. Vardanyan had the following WhatsApp
conversation (quoted verbatim):
Mr. Vardanyan: “estamos un poco mejor?
entrenas individualmente o no ?
Player:

“Si
Si”

Mr. Vardanyan: “te doy un abrazo se que te has cambiado conmigo por eso no quiero
hablar mucho”
Player:

“Hermano! No he cambiado estoy pasando momento difícil, imagínate
tú en mi situación, de la nada te quieren hachar, te meten a entrenar
solo, el equipo va a Dubái y me dejan solo ahí
Lo vez normal?
Urartu no hace bien las cosas”

Mr. Vardanyan: “Ayoub te deseo lo mejor en esta vida tu tienes corazón
que dice el agente ? hay algún equipo ?”
Player:

“De momento no hay nada”

Freely translated into English:
Mr. Vardanyan: “Are we a little better?
Do you train individually or not?”

pg. 21

REF. FPSD-17964

Player:

“Yes
Yes”

Mr. Vardanyan: “I'll give you a hug. I know you've changed with me, so I don't want to
talk too much"
Player:

“Brother! I haven't changed. I'm going through a difficult time. Imagine
yourself in my situation. Out of nowhere, they want to fire you, they
make you train alone, the team goes to Dubai and they leave me there
alone.
Do you think that's normal?
Urartu isn't doing things right.”

Mr. Vardanyan: “Ayoub, I wish you the best in life. You have a heart.
What does the agent say? Is there a team?”
Player:

“Nothing at the moment.”

61. On 4 February 2025, Urartu sent a new letter to the Player, requesting that he return within
five days. Urartu stated that, otherwise, it would have no other option but to terminate the
Contract.
62. Also on 4 February 2025, Marko Dokovic, Sutjeska’s deputy CEO (hereinafter: Sutjeska’s
Deputy CEO) contacted the Player.
63. On 6 February 2025, the Player and Sutjeska concluded a contract (hereinafter: the Sutjeska
Contract), valid from 1 February 2025 until 31 May 2025. According to this contract, the
Player would be entitled to EUR 600 net as monthly salary, as well as special compensation
payable as follows: EUR 1,600 net by 7 February 2025 and EUR 13,600 net by 15 June 2025.
64. On 7 February 2025, the FFA sent an email to Urartu, informing it that Sutjeska had
submitted a request for his International Transfer Certificate (ITC) on 6 February 2025,
seeking to register the Player.
65. On the same date, Urartu replied to the email, requesting further information about
Sutjeska and the ITC request.
66. On 11 February 2025, Sutjeska announced the Player on its official Instagram page.
67. On 15 February 2025, Urartu sent an email to the Player with a letter dated 14 February
2025 stating: (i) the Player’s absences; (ii) the warning and reprimand imposed; (iii) his
unauthorised departure from the training base; and (iv) the fact that he had signed a new
contract with another club without requesting authorisation from Urartu. Urartu stated

pg. 22

REF. FPSD-17964

that it had no alternative but to consider the Contract terminated without just cause as of
6 February 2025.
68. On 26 July 2025, the Player and the Portuguese club Feirense (hereinafter: Feirense)
concluded an employment contract (hereinafter: the Feirense Contract) valid as from 23 July
2025 to 30 June 2026, with an automatic renewal in case the club qualified for the first
division. According to this contract, the Player would be entitled to EUR 54,000 net to be
paid in 12 instalments of EUR 4,500 net, with the first instalment due five days after signing
and the remaining instalments due on the 5th day of the following month.

II. Proceedings before FIFA
69. On 28 January 2025, the Player filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Player
70. The Player argued that, on 17 June 2024, he and Urartu concluded an employment contract
that included an annex related to his salary (i.e., the Alleged Annex). According to the
Player, the contract was valid until 1 June 2026, and he was entitled to USD 7,200 gross.
Nevertheless, the Player claimed that the copy of the contract provided to him by Urartu
only stipulated a salary of AMD 200,000. In this regard, the Player stated that this
discrepancy constituted a fraudulent act by Urartu to avoid the payment of taxes and
alleged that he was paid the difference in cash. The Player submitted several pieces of
evidence to support his allegations and argued that he had received an offer from the
Luxembourger club Swift Hesperange, which he rejected in order to join Urartu.
71. According to the Player, in December 2024, he was verbally informed that Urartu’s
president no longer intended to retain his services and requested that he terminate his
contract without any compensation. Moreover, the Player alleged that he was on holiday
when Urartu cancelled his flight ticket. Furthermore, the Player stated that an Urartu’s
directive instructed him not to publish any posts before Urartu made an official statement.
In this sense, the Player asserted that Urartu had already decided not to count on his
services.
72. Based on the above, the Player argued that he placed Urartu in default, denouncing its
breaches, which were: (i) being sidelined from training; (ii) the cancellation of his flight
ticket; (iii) a threat to reduce his salary; and (iv) the failure to provide him with the complete
copy of the contract. The Player claimed that he granted Urartu 15 days to remedy the
breaches.
73. Although the Player acknowledged that Urartu provided him with a flight ticket on 8 January
2025, he stated that it failed to remedy the other breaches. In this regard, the Player alleged

pg. 23

REF. FPSD-17964

that he continued training alone and was not included in the list of players who travelled
to the training camp on 24 January 2025 in Dubai. According to the Player, even secondteam players and injured players travelled to the camp. He claimed that he was
discriminated against and alleged that Urartu attempted to fabricate a medical justification
for excluding him from the trip.
74. The Player stated that, instead of remedying the breaches, Urartu sent him an email
requesting that he return to training. However, the Player argued that the necessary
conditions for his return were not met. Consequently, he sent a second communication on
24 January 2025, reiterating the breaches and granting Urartu another deadline to remedy
them, under the warning that he would ratify the unilateral termination with just cause.
The Player asserted that, due to Urartu’s failure to respond, he ratified the termination on
27 January 2025.
75. According to the Player, Urartu committed the following breaches:
(i)

A discrepancy existed between his actual salary (USD 7,200) and the salary stated in
the Contract, preventing him from receiving his full remuneration;

(ii)

The Club failed to pay him the salaries from January 2025 to June 2026;

(iii)

He was sidelined from the first team and had to train alone, without supervision or
medical support;

(iv)

He was subjected to discrimination and psychological harassment to pressure him
into signing a termination agreement;

(v)

He was excluded from the training camp in Dubai;

(vi)

Urartu failed to provide him with the complete copy of the Contract.

76. In light of the above, the Player argued that he had just cause to terminate the Contract, as
he could no longer be expected to continue the employment relationship. Therefore, he
claimed entitlement to the residual value of the Contract, totalling USD 122,400, as well as
moral damages and compensation for loss of opportunity, considering the offer he had
rejected from the Luxembourger club.
77. The Claimant’s requests for relief were the following:
“Por todo lo expuesto, y con base en los fundamentos de hecho y de derecho, y en las
pruebas documentales, testificales y audiovisuales aportadas. SOLICITO a esta
Honorable Cámara de Resolución de Disputas de la FIFA que. previos los trámites de
rigor, dicte resolución por la que:

pg. 24

REF. FPSD-17964

1. Se declare JUSTIFICADA LA RESCISIÓN UNILATERAL DEL CONTRATO DE TRABAJO de
fecha 17 de junio de 2024. por EXCLUSIVA CULPA DEL CLUB SPORTING NGO “FC URARTU",
con fecha efectiva 24 de enero de 2025
2. Se CONDENE AL SPORTING NGO ‘FC URARTU’ AL PAGO ÍNTEGRO de la suma de CIENTO
VEINTIDOS MIL CUATROCIENTOS DÓLARES ESTADOUNIDENSES (USD 122.400). en
concepto de salarios adeudados al Jugador Demandante, correspondientes a las
mensualidades de enero de 2025 a mayo de 2026, más los intereses legales
correspondientes desde la fecha de vencimiento de cada mensualidad hasta la fecha de
efectivo pago.
3. Se CONDENE AL SPORTING NGO “FC URARTU" AL PAGO de una INDEMNIZACIÓN POR
DAÑO MORAL, en una cuantía que se determinará prudencialmente por esta Honorable
Cámara, pero que se estima, de manera provisional, en la suma de CINCUENTA MIL
DÓLARES ESTADOUNIDENSES (USD 50.000), o la cantidad superior o inferior que se
considere ajustada a derecho.
4 Se CONDENE AL SPORTING NGO ‘FC URARTU’ AL PAGO de una INDEMNIZACIÓN POR
LUCRO CESANTE Y PÉRDIDA DE OPORTUNIDADES PROFESIONALES, en una cuantía que
se determinará prudencialmente por esta Honorable Cámara, tomando como referencia
la oferta formal del club Swift Hesperange de Luxemburgo, pero que se estima, de
manera provisional, en la suma de SESENTA MIL DÓLARES ESTADOUNIDENSES (USD
60.000), o la cantidad superior o inferior que se considere ajustada a derecho.
5. Se CONDENE AL SPORTING NGO ‘FC URARTU’ AL PAGO ÍNTEGRO DE LAS COSTAS V
GASTOS DEL PRESENTE PROCEDIMIENTO, incluyendo los HONORARIOS DE
REPRESENTACIÓN LEGAL DEL DR. PABLO SEBASTIÁN RODRÍGUEZ, en una cuantía que se
determinará prudencialmente por esta Honorable Cámara.
6. Se adopte CUALQUIER OTRA MEDIDA que esta Honorable Cámara de Resolución de
Disputas de la FIFA estime pertinente para reparar integramente los daños y perjuicios
causados al Jugador Demandante, y para sancionar ejemplarmente la reprochable
conducta del Club Demandado.”
Freely translated into English:
“For all the above reasons, and based on the factual and legal grounds, and on the
documentary, testimonial and audiovisual evidence provided, I REQUEST that this
Honourable FIFA Dispute Resolution Chamber, after completing the necessary
formalities, issue a ruling whereby:
1. DECLARE THE UNILATERAL TERMINATION OF THE EMPLOYMENT CONTRACT dated 17
June 2024 to be JUSTIFIED, due to the SOLE FAULT OF THE CLUB SPORTING NGO ‘FC
URARTU’, with an effective date of 24 January 2025.

pg. 25

REF. FPSD-17964

2. SPORTING NGO ‘FC URARTU’ IS ORDERED TO PAY IN FULL the sum of ONE HUNDRED
AND TWENTY-TWO THOUSAND FOUR HUNDRED US DOLLARS (USD 122,400) in respect of
wages owed to the Plaintiff Player, corresponding to the monthly payments from January
2025 to May 2026, plus the corresponding legal interest from the due date of each
monthly payment until the date of actual payment.
3. SPORTING NGO ‘FC URARTU’ IS ORDERED TO PAY COMPENSATION FOR MORAL
DAMAGES, in an amount to be determined prudently by this Honourable Chamber, but
provisionally estimated at the sum of FIFTY THOUSAND US DOLLARS (USD 50,000), or
such greater or lesser amount as may be deemed appropriate in law.
4 ORDER SPORTING NGO ‘FC URARTU’ TO PAY COMPENSATION FOR LOST EARNINGS AND
LOSS OF PROFESSIONAL OPPORTUNITIES, in an amount to be determined prudently by
this Honourable Chamber, taking as a reference the formal offer from the Swift
Hesperange club in Luxembourg, but which is provisionally estimated at the sum of SIXTY
THOUSAND US DOLLARS (USD 60,000), or such greater or lesser amount as may be
deemed appropriate in law.
5. SPORTING NGO ‘FC URARTU’ IS ORDERED TO PAY IN FULL THE COSTS AND EXPENSES
OF THE PRESENT PROCEEDINGS, including the LEGAL REPRESENTATION FEES OF DR.
PABLO SEBASTIÁN RODRÍGUEZ, in an amount to be determined prudently by this
Honourable Chamber.
6. ANY OTHER MEASURES be adopted that this Honourable FIFA Dispute Resolution
Chamber deems appropriate to fully repair the damages caused to the Claimant Player
and to exemplarily sanction the reprehensible conduct of the Respondent Club.”
b. Reply and counterclaim of Urartu
78. In its reply and counterclaim, Urartu first stated that the Player was granted leave in
December 2024, as was every other player on the team. In this regard, Urartu stated that
during this period, there was back-and-forth communication regarding a possible mutual
termination if the Player found a new club.
79. According to Urartu, on 4 January 2025, it unexpectedly received a communication from
the Player that did not reflect any objective reality. On 5 January 2025, it purchased a flight
ticket for the Player, as expected. Additionally, Urartu argued that it replied to the notice.
Urartu further claimed that, on 9 January 2025, the Player began training with the team
and provided supporting evidence.
80. Urartu further alleged that, on 25 January 2025, the Player unexpectedly terminated the
Contract on the grounds of labour discrimination and contractual breach and failed to
attend training. Urartu stated that it was benevolent enough to disregard the unilateral

pg. 26

REF. FPSD-17964

termination, as it did not meet the ultima ratio criteria, and invited the Player to act
reasonably. In this respect, the Club claimed that it sent several communications to the
Player, to no avail.
81. Moreover, Urartu indicated that, on 7 February 2025, it was informed that Sutjeska had
requested the Player’s ITC and had then received the claim filed against it. Therefore,
Urartu argued that, on 15 February 2025, it terminated the Contract with just cause.
82. Urartu alleged that the Player wrongfully terminated the Contract without just cause,
invoking art. 14bis of the Regulations, despite never having challenged any unpaid salary
during the employment in his claim. In addition, Urartu stated that the Player violated his
most basic obligations and, although he alleged a mental breakdown in his claim, he never
consulted Urartu’s medical personnel regarding such an issue.
83. Conversely, Urartu argued that the Player breached the Contract by failing to attend
training and by signing a new contract with Sutjeska. Therefore, Urartu asserted that it had
just cause to terminate the Contract, as the Player’s conduct made it impossible to continue
the employment relationship. Additionally, Urartu stated that it had exhausted all available
and possible remedies before applying the ultima ratio.
84. Urartu contended that the Player was never discriminated against, as he trained with the
team. Moreover, the Contract did not grant the Player any right to interfere in matters
falling under the competence of Urartu’s management and coaching staff. Urartu
emphasized that there was no clause in the Contract obliging Urartu to include the Player
in the training camp, which was solely at Urartu’s discretion. Urartu maintained that the
decision was made to protect the Player’s health and to help him recover his fitness, as
substantiated by Urartu’s physical coach. In this respect, Urartu stated that the Player’s
salary was not reduced, he was not removed from the first-team squad, and the measure
was only temporary.
85. Regarding the alleged failure to provide the Player with a complete copy of the Contract,
Urartu pointed out that the Player submitted several conversations with an individual who,
at the time, was not an employee of Urartu and had no authority to negotiate on its behalf.
Urartu argued that this individual was only employed two months after the date of the
conversation with the Player and provided a copy of his employment contract.
86. Urartu argued that it never discussed the claimed amounts with the Player, nor did it ever
propose such amounts to him. In any event, it stated that, by signing the Contract, the
Player confirmed that he had received the original Contract and the Annex, in accordance
with clause 13.1 of the Contract. In this regard, Urartu reiterated that the Player did not
have just cause to terminate the Contract.
87. Regarding the videos submitted by the Player, Urartu pointed out that he recorded multiple
videos of himself speaking in Spanish, fully aware that the language is not commonly

pg. 27

REF. FPSD-17964

spoken in the country and that none of Urartu’s personnel speaks it. Urartu argued that
the Player was complaining without providing any verifiable proof. Conversely, Urartu
submitted videos showing the Player training with the team throughout the period during
which he claimed to have trained alone. Therefore, Urartu argued that the Player’s
termination should be disregarded.
88. Additionally, Urartu stated that Sutjeska was required to obtain authorization before
entering into negotiations with the Player and before submitting an ITC request. However,
Urartu argued that Sutjeska failed to contact the Club in good faith to verify the factual
background of the situation. As Urartu contended that the transfer was arranged behind
its back, it claimed to have no access to any evidence of communication between the Player
and Sutjeska. Therefore, it requested that FIFA obtain this information from Sutjeska.
Urartu alleged that it is clearly presumed that Sutjeska induced the Player and should be
held jointly and severally liable.
89. Regarding compensation, Urartu stated that the liquidated damages clause should apply
and that it is entitled to AMD 140,000,000. In this regard, Urartu recalled that, according to
the jurisprudence of the Court of Arbitration for Sport (CAS), liquidated damages clauses
do not need to be reciprocal to be valid. Alternatively, if the Football Tribunal were to reject
the primary request, Urartu calculated compensation based on the principle of positive
interest and claimed entitlement to either AMD 3,245,157 or AMD 3,141,922, depending on
the date of termination considered.
90. Regarding the Player’s claim, Urartu stated that the Player was always paid in accordance
with the contractual terms. It further contended that the Player was introduced to Urartu
by an intermediary, Mr. Vardanyan, who was acting independently. Urartu claimed that the
intermediary discussed an inflated salary with the Player, which had no connection to
Urartu’s actual offer, which was made in person and accepted by the Player. Urartu argued
that the intermediary was neither authorized nor mandated to negotiate on Urartu’s behalf
and was clearly acting as an independent intermediary.
91. Urartu argued that it never provided any document offering the Player a salary higher than
AMD 200,000. In this regard, Urartu stated that it is standard practice to offer new players
this amount and later renegotiate improved terms. Urartu claimed it was unaware of what
was sent to the Player or what may have been altered or drafted by the intermediary
without its authorization. Therefore, Urartu argued that no communication between the
Player and the intermediary could be considered as reflecting an agreement with Urartu.
Additionally, Urartu stated that the Player had the contract reviewed by a lawyer and
received independent legal advice.
92. Furthermore, Urartu insisted that the Player was neither discriminated against nor
subjected to psychological harassment and stated that he trained under adequate
conditions at the club’s facilities.

pg. 28

REF. FPSD-17964

93. The Respondent’s requests for relief were the following:
“191. On the grounds of all the abovementioned, the Club hereby requests from the FIFA
DRC to Issue a decision as follows:
A. To reject the Players claim entirely;
B. To accept this counterclaim;
C. To determine that the Player unilaterally terminated the Contract without just cause;
D. To issue a decision condemning the Player and the 2nd Respondent to pay the Club a
compensation in the amount of:
D.1. Up to 140,000,000 AMD (One Hundred and Forty Million Armenian Dram) as a
liquidated damage:
D.2. To award the application of five percent (5%) interest rate per annum, starting from
the date of the Player found to be in breach of contract: or alternatively
E. Should the FIFA DRC not accept the claim, set forth in the subpara. D. of this
paragraph, to issue a decision condemning the Player and the 2nd Respondent to pay the
Club a compensation in form of positive interest under article 17.1 of the FIFA RSTP
together with corresponding interests at a five percent (5%) rate as from:
F.1.24th of January 2025 If FIFA DRC finds that the Player terminated the Contract without
just cause on the aforementioned date, or
F.2. 06th of February 2025 if FIFA DRC finds that the Club terminated the Contract with
just cause on the aforementioned date and find the Player to have terminated the
Contract without just cause by that date accordingly;
F. Impose sporting sanctions on the Player in the form of a four-month restriction on
playing in official matches in accordance with the Article 17(3) of FIFA RSTP.
G. To order the Player to assume the entirety of the FIFA DRC administration and
procedural fees, if any.”
c. Player’s reply to the counterclaim
94. In his reply to the counterclaim, the Player reiterated that the breaches committed by
Urartu were severe.

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REF. FPSD-17964

95. In this regard, the Player first stated that Urartu (i) failed to acknowledge his actual salary,
(ii) employed a manoeuvre to establish a “dual salary” system - paying a minimal amount
officially and the remainder in cash - and (iii) failed to pay him the full amount due from
January 2025 until the termination.
96. He then again referred to the fact that he was sidelined and forced to train alone, being the
only first-team player excluded from the training camp in Dubai, which was organised as
from 24 January 2025. The Player argued that he was prevented from participating in the
team’s preparation and from competing for a place in the squad. Additionally, he claimed
that Urartu attempted to justify this decision based on an unfounded medical examination.
In this respect, the Player insisted that he was discriminated against and noted that he
trained without any supervision from medical or technical staff, which constituted a breach
of the Contract.
97. The Player also restated that (i) Urartu failed to provide him with a copy of the complete
contract, including the Alleged Annex, despite his requests; (ii) cancelled his flight ticket; (iii)
requested that he refrain from publishing anything regarding his contractual situation; (iv)
failed to satisfactorily respond to the notices of default dated 3 and 24 January 2025; and
(v) addressed hostile communications to him.
98. Moreover, the Player argued that he did not abandon the Contract, as on 24 and 27 January
2025 he communicated the termination with effect from 24 January 2025. Therefore, the
alleged absences occurred after the deadline to remedy the breaches had elapsed and
after the Player had decided to terminate the Contract. In fact, the Player referred to the
relevant facts and argued that he had attempted to resolve the issues before notifying his
decision.
99. In addition, the Player contended that the Sutjeska Contract was a consequence of the
termination, not a cause of it. According to the Player, he had no offer at the time he
terminated the Contract. He stated that on 27 January 2025, he communicated the
ratification of the termination, and on 28 January, Sutjeska’s Coach contacted him. The
Player even stated that he requested three days to consider his decision. He argued that
he had the right to seek employment.
100. Furthermore, the Player rejected any allegation by Urartu aimed at denying the authenticity
of the Alleged Annex and referred to the evidence submitted, in which Mr. Vardanyan
provided him with the Alleged Annex and acknowledged the actual salary. The Player also
stated that this salary was consistent with his professional level and with the offer he had
rejected from Swift Hesperange. Therefore, he asserted that it would not make sense for
him to have accepted a salary of only USD 500 in Armenia. Additionally, the Player argued
that he had provided evidence showing that Urartu paid amounts in cash and summoned
players for such payments, which would be unusual if his salary had indeed been only USD
500. Hence, he argued that this demonstrated the existence of a “dual salary” structure and
that Urartu had acted in bad faith.

pg. 30

REF. FPSD-17964

101. Moreover, the Player stated that he had always acted in accordance with the Contract and
fulfilled his obligations and argued that the termination was a measure of ultima ratio, as
he had sent two notices of default granting Urartu reasonable timeframes to remedy the
breaches. Therefore, he argued that he could no longer be reasonably expected to
continue the employment relationship.
102. The Player also alleged that Urartu’s request for compensation in the amount of AMD
140,000,000 cannot be upheld, as he terminated the Contract with just cause. In any event,
he argued that the clause is abusive and disproportionate when compared to the residual
value. The Player stated that the principle of positive interest should not apply, as Urartu’s
unlawful conduct should prevail, and that Urartu did not suffer any damage - rather, the
Player did. Therefore, he argued that the clause should be disregarded.
103. Finally, the Player contended that Sutjeska should not be held jointly liable, as the
presumption of inducement can only apply if the termination was made without just cause.
In this case, the Player argued that he had just cause and, in any event, Urartu failed to
prove that Sutjeska induced the termination. He affirmed that the termination was his own
decision, based on the breaches committed by Urartu, and that Sutjeska has no standing
to be sued.
104. The Player made the following requests for relief:
“(…) SOLICITO respetuosamente a esta Honorable Cámara de Resolución de Disputas
de la FIFA que, previos los trámites de rigor, dicte Resolución por la cual:
1. Se DECLARE JUSTIFICADA la rescisión unilateral del Contrato de Trabajo que
vinculaba al Sr. Abou Oulam Batas Ayoub con Sporting NGO ‘FC Urartu’, ejercida por
el Jugador con fecha efectiva 24/27 de enero de 2025 ,por EXCLUSIVA CULPA del Club
Demandado, en virtud de los graves y reiterados incumplimientos contractuales
detallados en el presente procedimiento.
2. Se RECHACE ÍNTEGRAMENTE la contrademanda interpuesta por Sporting NGO ‘FC
Urartu’ contra el Sr. Abou Oulam Batas Ayoub y contra FK Sutjeska Niksic, por carecer
manifiestamente de fundamento táctico y jurídico.
3. Se DECLARE EXPRESAMENTE que el club FK Sutjeska Niksic (Montenegro) no incurrió
en inducción a la ruptura contractual y, por lo tanto, NO TIENE RESPONSABILIDAD
SOLIDARIA ALGUNA en relación con la terminación del contrato entre el Sr. Ayoub y
FC Urartu, excluyéndolo de cualquier condena al respecto.
4. Se CONDENE a Sporting NGO ‘FC Urartu’ a abonar al Sr. Abou Oulam Batas Ayoub
la suma de CIENTO VEINTIDÓS MIL CUATROCIENTOS DÓLARES ESTADOUNIDENSES
(USD 122.400), en concepto de salarios adeudados correspondientes al valor residual

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REF. FPSD-17964

del contrato (17 mensualidades de enero de 2025 a mayo de 2026, calculadas sobre
el salario real bruto de USD 7.200), más los intereses legales correspondientes al 5%
anual desde la fecha de exigibilidad de cada mensualidad hasta su efectivo pago.
5. Se CONDENE a Sporting NGO ‘FC Urartu’ a abonar al Sr. Abou Oulam Batas Ayoub
una INDEMNIZACIÓN POR DAÑO MORAL, en una cuantía que se determinará
prudencialmente por esta Honorable Cámara, estimada por esta parte en
CINCUENTA MIL DÓLARES ESTADOUNIDENSES (USD 50.000), o la cantidad superior o
inferior que se considere justa y equitativa en atención a la gravedad de los hechos
probados, más los intereses legales correspondientes al 5% anual desde la fecha de
la presente decisión hasta su efectivo pago.
6. Se CONDENE a Sporting NGO ‘FC Urartu’ a abonar al Sr. Abou Oulam Batas Ayoub
una INDEMNIZACIÓN POR LUCRO CESANTE Y PÉRDIDA DE OPORTUNIDADES
PROFESIONALES, en una cuantía que se determinará prudencialmente por esta
Honorable Cámara, tomando como referencia la oferta formal rechazada del club
Swift Hesperange y el perjuicio general a su carrera, estimada por esta parte en
SESENTA MIL DÓLARES ESTADOUNIDENSES (USD 60.000), o la cantidad superior o
inferior que se considere ajustada a derecho, más los intereses legales
correspondientes al 5% anual desde la fecha de la presente decisión hasta su efectivo
pago.
7. Se CONDENE a Sporting NGO ‘FC Urartu’ al pago ÍNTEGRO DE LAS COSTAS Y
GASTOS del presente procedimiento, incluyendo los honorarios de representación
legal incurridos por el Sr. Ayoub, estimados prudencialmente por esta parte en
DIECISIETE MIL SEISCIENTOS DÓLARES ESTADOUNIDENSES (USD 17.600), o la cantidad
que esta Honorable Cámara determine conforme a la normativa y práctica aplicable,
más los intereses legales correspondientes al 5% anual desde la fecha de la presente
decisión hasta su efectivo pago.
8. Se considere la imposición de SANCIONES DEPORTIVAS a Sporting NGO ‘FC Urartu’,
conforme a lo previsto en el Reglamento sobre el Estatuto y la Transferencia de
Jugadores y el Código Disciplinario de la FIFA, en virtud de la gravedad de sus
incumplimientos, su conducta fraudulenta (doble salario) y su manifiesta mala fe
procesal.
9. Se ordene a Sporting NGO ‘FC Urartu’ a CESAR TODA COMUNICACIÓN INDEBIDA Y
HOSTIL dirigida al Jugador o a su representación legal fuera de los cauces oficiales
del Portal Jurídico de la FIFA, y a respetar en lo sucesivo las normas de procedimiento
y buena fe.”
Freely translated into English:

pg. 32

REF. FPSD-17964

“(…) I respectfully request that this Honourable FIFA Dispute Resolution Chamber,
after completing the necessary procedures, issue a ruling whereby:
1. DECLARE JUSTIFIED the unilateral termination of the Employment Contract between
Mr Abou Oulam Batas Ayoub and Sporting NGO ‘FC Urartu’, exercised by the Player
with effective date 24/27 January 2025, due to the EXCLUSIVE FAULT of the Defendant
Club, by virtue of the serious and repeated breaches of contract detailed in these
proceedings.
2. The counterclaim filed by Sporting NGO ‘FC Urartu’ against Mr Abou Oulam Batas
Ayoub and FK Sutjeska Niksic be REJECTED IN ITS ENTIRETY, as it is manifestly without
tactical and legal merit.
3. It is EXPRESSLY DECLARED that FK Sutjeska Niksic (Montenegro) did not induce the
breach of contract and, therefore, HAS NO JOINT AND SEVERAL LIABILITY in relation
to the termination of the contract between Mr. Ayoub and FC Urartu, excluding it from
any conviction in this regard.
4. Sporting NGO ‘FC Urartu’ is ORDERED to pay Mr Abou Oulam Batas Ayoub the sum
of ONE HUNDRED AND TWENTY-TWO THOUSAND FOUR HUNDRED US DOLLARS (USD
122,400), in respect of wages owed corresponding to the residual value of the
contract (17 monthly payments from January 2025 to May 2026, calculated on the
basis of the actual gross salary of USD 7,200), plus statutory interest at 5% per annum
from the date each monthly payment is due until the date of actual payment.
5. Sporting NGO ‘FC Urartu’ is ORDERED to pay Mr. Abou Oulam Batas Ayoub
COMPENSATION FOR MORAL DAMAGES, in an amount to be determined prudently by
this Honourable Chamber, estimated by this party at FIFTY THOUSAND US DOLLARS
(USD 50,000), or such greater or lesser amount as may be deemed fair and equitable
in view of the seriousness of the proven facts, plus statutory interest at 5% per annum
from the date of this decision until the date of actual payment.
6. Sporting NGO ‘FC Urartu’ is ORDERED to pay Mr. Abou Oulam Batas Ayoub
COMPENSATION FOR LOSS OF EARNINGS AND LOSS OF PROFESSIONAL
OPPORTUNITIES, in an amount to be determined prudently by this Honourable
Chamber, taking as a reference the formal offer rejected by the Swift Hesperange club
and the general damage to his career, estimated by this party at SIXTY THOUSAND US
DOLLARS (USD 60,000), or such greater or lesser amount as may be deemed
appropriate in law, plus legal interest at 5% per annum from the date of this decision
until actual payment.
7. Sporting NGO ‘FC Urartu’ is ORDERED to pay the FULL COSTS AND EXPENSES of
these proceedings, including the legal representation fees incurred by Mr Ayoub,
prudently estimated by this party at SEVENTEEN THOUSAND SIX HUNDRED US

pg. 33

REF. FPSD-17964

DOLLARS (USD 17,600), or such other amount as this Honourable Chamber may
determine in accordance with applicable rules and practice, plus interest at the rate
of 5% per annum from the date of this decision until the date of actual payment.
8. Consider the imposition of SPORTING SANCTIONS on Sporting NGO ‘FC Urartu’, in
accordance with the provisions of the Regulations on the Status and Transfer of
Players and the FIFA Disciplinary Code, by virtue of the seriousness of its breaches, its
fraudulent conduct (double salary) and its manifest procedural bad faith.
9. Sporting NGO ‘FC Urartu’ is ordered to CEASE ALL IMPROPER AND HOSTILE
COMMUNICATION directed at the Player or his legal representative outside the official
channels of the FIFA Legal Portal, and to respect the rules of procedure and good faith
in future.”
d. Sutjeska’s reply to the counterclaim
105. In its reply, Sutjeska stated that the Player unilaterally terminated the Contract on 24
January 2025 and that it had no prior contact with him or any related party. Sutjeska
explained that on 28 January 2025, a scout with informal ties to the club mentioned the
Player’s availability and confirmed that he was no longer under contract. Consequently, on
the same day, Sutjeska’s Coach contacted the Player, who requested three days to evaluate
his options. On 31 January 2025, its general secretary contacted the Player, and on 4
February 2025, the CEO and Transfer Matching System (TMS) manager reached out to
begin gathering the necessary documentation for his registration.
106. Additionally, Sutjeska recalled that the burden of proof lies with Urartu to demonstrate that
it induced the Player to breach his contract. In Sutjeska’s view, such evidence does not exist,
particularly considering that the Player was only contacted four days after the termination.
107. In light of the above, Sutjeska requested that the counterclaim against it, relating to
inducement or joint liability, be rejected.
e. Urartu’s final comments
108. In its final comments, Urartu noted that the Player invoked art. 14bis of the Regulations in
his response, although he had not done so in his initial claim. Additionally, Urartu observed
that the Player now requested 5% interest on each of his claims, which was not included in
the original claim. Urartu also pointed out that the Player did not challenge the video
evidence submitted by the club and made contradictory statements regarding the date of
termination.
109. In any case, Urartu reiterated that the Player’s claims lacked foundation and reaffirmed its
position.

pg. 34

REF. FPSD-17964

110. With regard to Sutjeska’s response, Urartu argued that inducement by Sutjeska may be
implied tacitly or is, at the very least, highly likely. In this respect, Urartu referred to the
annexed witness statements submitted by Sutjeska, noting that the individuals providing
such statements were directly under Sutjeska’s control and spoke about the connection
established with the Player. Therefore, Urartu contended that the witnesses were biased.
111. Furthermore, Urartu argued that the Contract had not yet been terminated in January and
that the alleged inducement occurred between 28 January and 6 February 2025, when
Sutjeska requested the Player’s ITC. As such, Urartu claimed that the Contract might not
have been terminated had Sutjeska not initiated contact with the Player.
112. Urartu also remarked that Sutjeska’s Coach contacted the Player on the same day the
Player filed his claim, making it impossible to determine which action occurred first. Urartu
further noted that Sutjeska did not consult with the Club prior to contacting the Player.
113. Lastly, Urartu argued that any evidence obtained unlawfully or without the consent of the
parties falls outside the scope of admissibility and reaffirmed its position.

III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
114. First of all, the Dispute Resolution Chamber (hereinafter: the 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 28 January 2025 and submitted for decision
on 13 November 2025. Taking into account the wording of arts. 31 and 34 of the January
2025 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.
115. Furthermore, 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 par. 1 lit. b) of the
Regulations (July 2025 edition), the Dispute Resolution Chamber is competent to deal with
the matter at stake, which concerns an employment-related dispute with an international
dimension between a Spanish player, an Armenian club, and a Montenegrin club.
116. 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. 29 of the
Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand as
to the substance.

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REF. FPSD-17964

b. Burden of proof and admissibility of evidence
117. 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 TMS.
118. In particular, and still as a preliminary remark, the Chamber decided to address Urartu’s
assertion that all evidence allegedly acquired unlawfully and without the consent of the
parties “falls out of scope”. In this respect, the Chamber acknowledged that the
admissibility of several pieces of evidence submitted by the Player was disputed by Urartu.
119. In this respect, the Chamber referred to art. 11, par. 3 of the Procedural Rules, which states:
“Any type of evidence may be produced. A chamber has ultimate discretion as to the weight it
gives to evidence. All the evidence upon which a party intends to rely must be filed in the original
language and, if applicable, translated into English, Spanish or French”.
120. Based on the aforementioned provision, the Chamber determined that there was no
procedural impediment to the admissibility of the evidence submitted by the Player.
121. The Chamber subsequently decided to admit all the submitted evidence into the case file.
It also emphasised that it retained full discretion to assess the probative value of the
evidence, taking into account the circumstances under which it was obtained and the legal
arguments presented by both parties.
c. Merits of the dispute
122. Having established the competence and the applicable regulations, 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, arguments and documentary evidence, which it considered pertinent for
assessing the matter at hand.
i. Main legal discussion and considerations
123. The Chamber then moved to the substance of the matter, noting that it concerned a claim
brought by a player against a club, and a counterclaim lodged by the club against the player
and his new club for breach of contract.

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REF. FPSD-17964

124. The Chamber recalled that, according to the Player, he terminated the Contract with just
cause, as Urartu: (i) forced him to train alone; (ii) did not allow him to travel to the preseason camp; (iii) failed to provide him with a copy of the Contract, including an annex
reflecting his actual remuneration; and (iv) discriminated against him.
125. The Chamber noted that, conversely, Urartu argued that the Player did not have just cause
to terminate the Contract, as it had not committed any breach, nor was the termination a
measure of ultima ratio. Furthermore, Urartu claimed that it was the party that terminated
the Contract with just cause and that Sutjeska should be held jointly liable for
compensation.
126. For its part, Sutjeska contended that it did not induce the Player to terminate the Contract
and that it only hired him after the termination had already occurred.
127. In this context, the Chamber acknowledged that its task was to determine (i) the Player’s
actual remuneration, which is central to one of the alleged breaches; (ii) which party
terminated the Contract; (iii) whether the termination occurred with or without just cause;
and (iv) its ensuing consequences. Accordingly, the Chamber moved on to analyse each of
these elements in turn.
A. The Player’s remuneration
128. The Chamber recalled that, according to the copies of the contracts duly signed by the
parties and submitted to the file, the Player was entitled to a monthly net salary of AMD
200,000. However, the Player argued that the Alleged Annex - allegedly an integral part of
the Contract and never provided to him by Urartu - stipulated a gross monthly salary of
USD 7,200. Urartu, on the other hand, maintained that it was only obliged to pay the
amount of AMD 200,000 net, as stated in the Contract.
129. Therefore, the Chamber concluded that it must be determined whether, despite the
absence of a duly signed copy of the Alleged Annex, it is possible to establish that the
Player’s actual remuneration consisted of USD 7,200.
130. At this point, the Chamber noted that the Player submitted several pieces of evidence to
support his claim that his actual salary was significantly higher than the amount stated in
the Contract. These include: (i) various conversations with Mr. Vardanyan, including those
in which he provided the Player with an offer and a copy of the Contract; (ii) WhatsApp
group messages concerning salary payments; and (iii) an offer the Player received from a
third club prior to joining Urartu.
131. Regarding the conversations with Mr. Vardanyan, the Chamber considered that it was first
necessary to determine whether he was acting on behalf of Urartu or merely as the Player’s
agent. The Player claimed that Mr. Vardanyan was an Urartu’s official, whereas Urartu

pg. 37

REF. FPSD-17964

asserted that he was the Player’s agent and only became affiliated with Urartu two months
after the relevant conversations.
132. The Chamber remarked that, based on the evidence on file, it appears that in the initial
conversations - held on unspecified dates - Mr. Vardanyan indeed acted as an intermediary.
The conversation submitted by Urartu shows that Mr. Vardanyan was seeking
opportunities for the Player with various clubs, not solely Urartu. He also invited the Player
to sign with his agency, suggesting he was acting in the capacity of an agent rather than a
club official.
133. Nevertheless, the Chamber emphasised that, in the same conversation, Mr. Vardanyan
explicitly referred to Urartu as “his” team, stating that the Player would always have a place
there because Urartu’s president intended to invest. While the Chamber acknowledged
that the precise meaning of “his” team is unclear, it suggests that Mr. Vardanyan had a
special relationship with Urartu.
134. Furthermore, in a message dated 8 June 2024, Mr. Vardanyan explicitly told the Player, “I
work at Urartu, and I can't go to the club, so I'm talking to the agent here,” and “we're starting
training today”. In additional conversations dated 13 and 17 June 2024, he discussed the
salary payment mechanism as if he were acting on behalf of Urartu, even stating that “they”
pay taxes on amounts exceeding AMD 200,000, with the remainder being paid in cash.
135. The Chamber found also relevant that Mr. Vardanyan provided the Player with an offer
allegedly made by Urartu on 7 June 2024, along with a copy of the Contract. Although these
documents were forwarded - implying they were sent to Mr. Vardanyan by someone else Urartu did not submit any evidence of communications in which Mr. Vardanyan received
these documents. The Chamber stressed that if he were merely an intermediary, one
would expect to see exchanges between him and Urartu negotiating the contract terms
and transmitting documents. However, such evidence was not presented.
136. Additionally, the Chamber highlighted that on 1 August 2024 - less than two months later Mr. Vardanyan was officially appointed as Urartu’s sporting director. While there is no
formal evidence of an employment relationship prior to that date, the Chamber considered
that the fact that the Player negotiated the Contract through Mr. Vardanyan, who was later
appointed to a senior position at Urartu, indicates a pre-existing connection. In the
Chamber’s view, this appointment does not preclude the possibility that Mr. Vardanyan
already held an informal or de facto role within the club, as he himself acknowledged in the
communication.
137. The Chamber also considered noteworthy that, following his appointment as sporting
director, Mr. Vardanyan continued to communicate with the Player in the same manner as
before the Contract was signed - for instance, when the Player requested a complete copy
of the Contract. Furthermore, in December 2024, during negotiations between the Player

pg. 38

REF. FPSD-17964

and Urartu, Mr. Vardanyan informed the Player that Urartu’s president would demand him
to pay his compensation, as it was Mr. Vardanyan himself who had signed the Player.
138. In light of all the above, the Chamber found it difficult to accept Urartu’s argument that Mr.
Vardanyan acted solely as an intermediary representing the Player. Rather, the Chamber
was of the opinion that, although Mr. Vardanyan may have initially acted as an
intermediary, he was also working for Urartu. Therefore, the Chamber concluded that the
messages exchanged between the Player and Mr. Vardanyan can be regarded as
communications between the Player and Urartu.
139. In this context, the Chamber recalled that on 7 June 2024, Mr. Vardanyan forwarded to the
Player an offer apparently issued by Urartu, which included a proposed salary of USD 7,300.
Even if Mr. Vardanyan were not considered to be acting on behalf of Urartu, the Chamber
found relevant that this document was not disputed by Urartu. Furthermore, on 8 June
2024, the Player and Mr. Vardanyan exchanged several messages discussing salary figures
between “5,500” and “9,000”. On 13 June 2024, Mr. Vardanyan informed the Player that he
would receive USD 500 in the bank and “the rest” in cash.
140. On 16 June 2024, Mr. Vardanyan forwarded a copy of the Contract to the Player, which
consisted of 17 pages and included the Alleged Annex, stipulating a gross monthly salary
of USD 7,200. Even if Mr. Vardanyan were not considered to be acting on behalf of Urartu,
the Chamber, again, considered that Urartu provided this copy to the Player, as there is no
evidence of any other source, and Urartu did not dispute the authenticity of the document.
141. The Chamber further recalled that, on 17 June 2024, Mr. Vardanyan sent a voice message
to the Player, explaining that AMD 200,000 was equivalent to USD 500 and that “they” would
pay taxes on that amount. He reiterated that the Player would receive AMD 200,000 via
bank transfer and the remainder in cash.
142. Moreover, the Chamber stressed that the Player was able to demonstrate that on 15
August 2024 - by which time Mr. Vardanyan was undisputedly acting as Urartu’s sporting
director - he requested a copy of the Alleged Annex. Mr. Vardanyan acknowledged the
request and did not deny the existence of the document, instead stating that it had not
been provided to anyone. On 19 August 2024, he informed the Player that he believed the
president would refuse to release the document.
143. In this regard, the Chamber found it implausible that Mr. Vardanyan and the Player would
have discussed a salary in the range of USD 7,000, only for the Player - allegedly with legal
advice - to sign a contract for an amount equivalent to USD 500. The Chamber found it
equally implausible that the Player and his purported agent would have negotiated a salary
more than ten times higher than the one reflected in the Contract without Urartu’s
knowledge or consent.

pg. 39

REF. FPSD-17964

144. Based on the foregoing, the Chamber considered that the Player has provided sufficient
evidence to demonstrate that, although the copies of the Contract submitted in the file do
not include the Alleged Annex, the parties in fact negotiated a salary significantly higher
than AMD 200,000, consistent with the amount stated in the Alleged Annex.
145. Regarding the WhatsApp group conversations concerning salary payments, the Chamber
noted that the Player has shown that, on a monthly basis, team members were informed
of the specific date and time for salary collection. Notably, in August 2024, an individual
informed the group that those unable to attend the scheduled payment time would have
to wait until the following week to receive their salary.
146. In the Chamber’s view, this evidence illustrates Urartu’s modus operandi for salary
payments, which aligns with the information provided to the Player by Mr. Vardanyan
during the contract negotiations. While this evidence does not conclusively prove that the
Player received USD 7,200 in cash, it supports the assertion that Urartu paid salaries in
cash.
147. As for the offer allegedly received by the Player from a club in Luxembourg, the Chamber
observed that the document is undated. However, it refers to a contract period from 1 July
2024 to 31 May 2026, which aligns with the term of the Contract with Urartu. The offer
included EUR 44,000 for the first season and EUR 49,000 for the second. Although this does
not definitively prove that the Player received USD 7,200 in cash, as he could have declined
the offer and accepted a lower salary, the Chamber found it difficult to believe that he
would have signed a contract for only USD 500 per month. This further supports the
conclusion that the Alleged Annex was indeed part of the Contract.
148. Taking into account all the evidence on file, the Chamber concluded that the Player has
sufficiently demonstrated that the Alleged Annex formed part of the Contract, despite the
absence of a signed copy. Importantly, Urartu failed to provide any evidence of
negotiations with the Player or, as it claims, with his agent, in which a salary of AMD 200,000
was agreed. The Chamber underscored that, if such an agreement had existed, one would
expect to find documentation beyond the Contract copy. The Chamber also found it
unlikely that the offer made by Urartu was made in person, based on the evidence on file.
149. Furthermore, the Chamber found it implausible that Mr. Vardanyan would have misled the
Player into signing a contract and that the Player, over a period of six months, would not
have raised any complaint about receiving a salary approximately 14 times lower than what
had been negotiated. This further supports the conclusion that the Alleged Annex was
indeed part of the Contract and that the Player actually received the salary stipulated
therein.
150. In light of the foregoing, the Chamber concluded that the Player’s actual remuneration
under the Contract amounted to USD 7,200 gross, as asserted by the Player. The Chamber
remarked that, given the existence of two annexes, it could be interpreted that the Player

pg. 40

REF. FPSD-17964

was entitled to both USD 7,200 and AMD 200,000. However, since the Player consistently
maintained that his salary was USD 7,200 and is claiming compensation only taking this
amount into account, the Chamber considered it appropriate to interpret that his
entitlement was limited to USD 7,200.
B. Who terminated the Contract?
151. Having established the Player’s real remuneration, the Chamber turned to the second
disputed issue: which party terminated the Contract. According to the Player, he
terminated the Contract on 24/27 (sic) January 2025. Conversely, Urartu argued that this
termination was invalid, as it did not constitute an ultima ratio measure, and therefore
claimed that it was Urartu that terminated the Contract on 15 February 2025.
152. The Chamber noted that on 24 January 2025, the Player sent a letter to Urartu titled
“Rescisión unilateral por exclusiva culpa del club FC Urartu”, freely translated into English as
“Unilateral termination due to the fault of FC Urartu”. In this letter, the Player confirmed his
decision to “consider himself dismissed” due to several breaches by Urartu, with immediate
effect. Nonetheless, he granted Urartu a 48-hour period to clarify the situation and explain
the decision to exclude him from the pre-season camp and the first-team dynamic. The
Player stated that, failing such clarification, the termination would be deemed final and
ratified, and he would proceed to file a claim before the Football Tribunal.
153. The Chamber further noted that on 27 January 2025, the Player sent another letter titled
“Rescisión de contrato por exclusiva culpa del club”, freely translated as “Unilateral termination
due to the club’s fault”. In this letter, the Player reiterated that the Contract had already been
terminated due to Urartu’s fault and informed it that he would proceed with his claim
before FIFA.
154. Following these letters, Urartu sent several communications to the Player, requesting that
he attend training sessions and issuing warnings and reprimands. Ultimately, on 15
February 2025, Urartu issued a letter terminating the Contract.
155. Based on the above evidence, the Chamber determined that it was the Player who
terminated the Contract on 24 January 2025. Although the Player granted Urartu 48 hours
to provide clarification, the letter clearly stated that the Contract was terminated with
immediate effect due to Urartu’s fault. This was further confirmed in the letter dated 27
January 2025, in which the Player reiterated that the Contract had already been terminated.
Although the Player referred to the 24 January letter as a “second default notice” in his
claim, in the Chamber’s view, it effectively constituted the termination letter.
156. In this respect, the Chamber concluded that, as of 24 January 2025, the Contract was
terminated by the Player. Consequently, the Chamber determined that any subsequent
communications or conduct by the parties are not material to the assessment of the
termination itself.

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REF. FPSD-17964

C. Did the Player have just cause to terminate the Contract?
157. First, the Chamber recalled the long-standing jurisprudence of the Football Tribunal,
according to which only a breach or misconduct which is of a certain severity justifies the
termination of a contract without prior warning. In other words, only when there are
objective criteria which do not reasonably permit to expect the continuation of the
employment relationship between the parties, a contract may be terminated prematurely.
Hence, if there are more lenient measures which can be taken in order for an employer to
assure the employee’s fulfilment of his contractual duties, such measures must be taken
before terminating an employment contract. A premature termination of an employment
contract can only be an ultima ratio measure.
158. In addition, the Chamber recalled the wording of art. 14 of the Regulations, which
stipulates:
“1. A contract may be terminated by either party without consequences of any kind
(either payment of compensation or imposition of sporting sanctions) where there is just
cause. In general, just cause shall exist in any circumstance in which a party can no
longer reasonably and in good faith be expected to continue a contractual relationship.
2. Any abusive conduct of a party aiming at forcing the counterparty to terminate or
change the terms of the contract shall entitle the counterparty (a player or a club) to
terminate the contract with just cause.”
159. In continuation, the Chamber also deemed important to recall that contractual stability is
the backbone of the entire football season, and employers and employees in the football
world are prevented from simply withdrawing from a previous employment relationship
without a valid reason. In this regard, the early termination of an employment contract
without just cause has consequences – both financial and sporting. The rules allow for the
parties to modulate the effects of such a premature termination, but the jurisprudence
also sets certain boundaries to limit the contractual freedom in favour of the legal certainty
and the legitimate expectation of contractual stability.
160. Bearing the above principles and regulations in mind, and based on the evidence on file,
the Chamber proceeded to analyse the facts and circumstances leading up to the
termination. At this point, the Chamber recalled the sequence of events from December
2024 until the termination:
•

On 23 December 2024, the Player was informed by Mr. Areg that his return flight
ticket had been cancelled. The Player subsequently informed Mr. Vardanyan, who
responded that the Player had previously told him he would sign a termination
agreement. The Player replied that he still had a valid contract and, if Urartu
wished to terminate it, they would need to compensate him.

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REF. FPSD-17964

•

On 30 December 2024, Mr. Areg informed the Player not to make any public
statement about his departure until an official announcement was made by
Urartu.

•

On 3 January 2025, the Player issued a notice of default to Urartu, stating that he
had been informed he would no longer be considered for training or matches.
He also claimed that (i) Urartu had failed to provide the second flight ticket agreed
for the current season, as well as the two tickets stipulated for the second season,
and (ii) had not provided him with a complete copy of the Contract. The Player
granted Urartu 15 days to (i) reinstate him to his duties or, alternatively, pay the
full value of the Contract, (ii) provide the three missing flight tickets, and (iii)
deliver the complete copy of the Contract.

•

On 5 January 2025, Urartu informed the Player that the training camp would
begin on 9 January 2025 and offered him a flight ticket for 8 January 2025.

•

On 6 January 2025, the Player responded to Urartu’s email, expressing his
willingness to join the team and reminding it that he should train with the first
team and not separately.

•

On 8 January 2025, the Player travelled to Armenia, and on 9 January 2025, he
joined the team.

•

Also on 9 January 2025, Urartu replied to the Player’s email, stating that the
information he had provided was inaccurate and did not reflect the actual
situation, as there was no ongoing or existing dispute between the parties.

•

Between 9 and 20 January 2025, it is disputed whether the Player trained with the
team or alone. Urartu claimed - and submitted alleged evidence - that the Player
trained with the team. The Player, in turn, claimed - and also submitted alleged
evidence - that he trained alone.

•

On 21 January 2025, the Player underwent a medical examination. On the same
day, the physical coach recommended that he not be included in the pre-season
squad and instead follow an individual training programme under supervision.

•

On 24 January 2025, the Player terminated the Contract, arguing that on 9 and 10
January he trained alone, and from 11 January 2025 onwards, he was only
allowed to participate in the initial part of training with his teammates before
being required to train alone. He further argued that all other team members
travelled to a pre-season camp in Dubai, while he was left behind without
supervision.

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REF. FPSD-17964

161. In this context, the Chamber moved on to assess the alleged breaches committed by Urartu
and determine whether the termination constituted an ultima ratio measure.
c.1.1) Failure to consider the Player for training and football matches and to provide him
with the flight ticket
162. Having established the context of the employment relationship in December 2024, the
Chamber observed that Urartu appeared to have cancelled the Player’s return flight ticket
from the holiday break, justifying this by stating that the Player was expected to sign a
termination agreement. The Chamber considered that this action clearly indicates Urartu’s
intention to end the employment relationship.
163. However, the Chamber recalled that after the Player issued a notice of default - claiming
that Urartu had informed him he would no longer be considered for training or matches
and had failed to provide the flight ticket, while granting the club 15 days to remedy the
breaches - Urartu responded by inviting him to the training camp and providing the flight
ticket.
164. In this regard, the Chamber was of the opinion that, although the evidence suggests that
Urartu initially intended to terminate the Contract and breached its obligations by failing
to provide the return flight ticket and excluding the Player from training, it ultimately
remedied these breaches within the 15-day period granted by the Player
165. Nevertheless, the Chamber also remarked that in his response, the Player warned Urartu
that (i) he must be allowed to train with the first team and not separately, as training in
isolation was unlawful, and (ii) reiterated that, as previously discussed, continuing to train
with the second team would hinder his development and career. There is no evidence that
Urartu responded to or refuted these allegations.
c.1.2) Failure to provide the complete copy of the Contract
166. At this point, the Chamber referred to its findings under section “a” supra and reiterated
its conclusion that the Alleged Annex formed part of the Contract, establishing that the
Player was entitled to a gross monthly salary of USD 7,200.
167. The Chamber indeed confirmed that Urartu failed to provide the Player with the complete
copy of the Contract, despite both informal and formal requests. The Player submitted
evidence showing that he requested the Alleged Annex in August 2024 and again formally
in January 2025. Notably, in his notice of default, the Player granted Urartu 15 days to
comply with this request, which Urartu failed to do.
168. Furthermore, in its response to the notice of default, Urartu did not address this specific
claim. It merely stated that the allegations were inaccurate or false, without providing any

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REF. FPSD-17964

explanation or justification regarding the Alleged Annex. It was only on 28 January 2025 after the termination - that Urartu addressed the matter.
169. Therefore, in the Chamber’s opinion, Urartu’s conduct constituted a severe breach.
Although the Chamber was of the view that the Player received the agreed remuneration
up until the termination, he was not provided with a complete record of his contractual
terms.
170. Based on the evidence on file, the Chamber stressed that it appears that Urartu
deliberately withheld the full documentation of the Player’s employment relationship,
particularly concerning such a sensitive matter as his salary. This conduct forced the Player
to submit extensive evidence to prove his actual remuneration, when a simple copy of the
Contract should have sufficed. The Chamber also found it relevant that the Player received
part of his salary off the record and that his actual remuneration was not registered in the
TMS, also constituting undue behaviour and, ultimately, a violation of the Regulations.
171. Consequently, the Chamber considered this to be a serious breach committed by Urartu.
c.1.3) Individual trainings
172. Although the Player did not allege in his 3 January 2025 notice of default that he was
training alone - since he was not even training at that time – the Chamber noted that in his
termination letter, he claimed that on 9 and 10 January 2025 he trained alone, and from 11
January 2025 onwards, he was only permitted to warm up with the team before being
required to train separately. Additionally, in his email dated 6 January 2025, the Player
warned Urartu that he must be allowed to train with the first team and not separately.
173. In this regard, the Chamber observed that the Player submitted several videos purporting
to show that he was training alone, while Urartu submitted videos suggesting that he was
training with the team.
174. Based on the evidence on file, the Chamber found that it is not possible to conclusively
determine whether the Player was indeed training alone as of 9 January 2025. In the
Chamber’s view, the evidence submitted by both parties is insufficient to establish whether
the Player was fully integrated into team training or was being isolated.
175. While the Player submitted several videos, the Chamber highlighted that these are short
and undated, and do not conclusively demonstrate that he was training alone or excluded
from team activities. Conversely, the videos submitted by Urartu are also inconclusive. The
Player himself acknowledged that he was allowed to participate in the warm-up with the
team before being separated. In this regard, the Chamber stressed that if the Player had
participated in full training sessions, Urartu could have submitted longer videos - especially
considering that it appears Urartu recorded all training sessions. Nevertheless, the

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REF. FPSD-17964

Chamber also recalled that, pursuant to art. 13 par. 5 of the Procedural Rules, the burden
of proof lies with the Player to demonstrate that he was training alone.
176. Therefore, based on the evidence on file, the Chamber concluded that it cannot be
established that the Player was forced to train alone as of 9 January 2025.
c.1.4) Training camp in Dubai
177. Notwithstanding the above, the Chamber noted that it is undisputed that the Player did
not travel to the training camp in Dubai and was instead recommended to follow an
“individualized recovery and strength program at the facilities under the supervision of the
physical coach until 15 February 2025”.
178. In this respect, the Chamber recalled that, according to the Player, the team departed for
the training camp on 24 January 2025 - the same day he terminated the Contract. Although
Urartu argued that the decision not to include the Player was based on his physical
condition, the Chamber observed that, aside from a statement issued by the physical coach
- who is an employee of Urartu and whose testimony therefore carries limited probative
value - Urartu failed to provide any additional evidence substantiating the Player’s alleged
physical limitations.
179. Specifically, Urartu did not submit any medical reports, performance data, or objective
indicators demonstrating that the Player was unfit to travel. The Chamber also wished to
remark that, according to the evidence submitted by the Player, he underwent medical
examinations just days prior to the commencement of the training camp, after he was
informed that he was not going to be included. However, Urartu failed to provide any
documentation or evidence indicating that the Player was in poor physical condition at that
time.
180. Moreover, although Urartu claimed that the exclusion was a temporary measure, there is
no evidence that it informed the Player of this or communicated that the individualized
training program would only last until 15 February 2025. As such, even if the decision was
initially intended to be temporary, the lack of communication meant the Player could not
reasonably have perceived it as such.
181. The Chamber also found it relevant that, although the physical coach was purportedly
assigned to supervise the Player’s individualized training, the Player submitted a list of
coaching staff members who attended the pre-season camp in Dubai, which included the
physical coach. This suggests that this coach could not have been supervising the Player’s
training in Armenia during that period. Additionally, Urartu provided an alleged list of
doctors that would supervise the Player in Armenia but did not prove that he was under
the supervision of a physical coach or another coach.

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REF. FPSD-17964

182. While it is true that the Contract did not explicitly require Urartu to include the Player in
the pre-season camp, the Chamber recalled that, based on the jurisprudence of the
Football Tribunal, excluding a player from a training camp could constitute a violation of
the player’s personality rights: a club – as an employer – has the duty to protect the
personality rights of the player – as an employee. The career development of a footballer
may be prejudiced as a result of inactivity and thus, the club has a duty to allow its players
to engage in the activity for which they have been in principle employed and are qualified
for. The DRC has already confirmed in multiple occasions that among a player’s
fundamental rights under an employment contract, is not only his right to a timely payment
of his remuneration, but also his right to access training and to be given the possibility to
compete with his fellow teammates in the team’s official matches. The same reasoning
applies mutatis mutandis to the training sessions - in particular, regarding a training camp.
183. Furthermore, although it may be assumed that no official matches were scheduled during
this period, the Chamber underscored that Urartu’s decision to exclude the Player from the
training camp not only deprived him of the opportunity to train with his teammates but
also excluded him from the team environment and group dynamics without a valid reason,
which implied a more serious breach.
184. Therefore, the Chamber concluded that the exclusion of the Player from the pre-season
camp constituted a significant breach, especially in light of the broader context in which
the Player had already been informed that Urartu no longer intended to retain his services.
c.1.5) Other alleged breaches / damages
185. The Player also argued that Urartu threatened him of reducing his salary to USD 500, but
failed to provide any evidence of this, although it submitted many communications with
Urartu. In addition, in his claim he argued that he was prevented from collecting his real
remuneration. However, the Chamber remarked that this claim is not clear, as he did not
request any difference for the salaries from July to December 2024, but only argued that
he was prevented from collecting his salaries as from January 2025, when he actually
terminated the Contract.
186. Additionally, the Player alleged that he suffered emotional harm. However, aside from his
own statements, the Player did not submit any supporting evidence to substantiate this
claim.
c.1.6) Interim conclusion
187. Based on all the above, the Chamber found that there are several elements indicating that
Urartu’s conduct toward the Player was abusive. While it may be argued that none of the
individual breaches alone would suffice to justify termination, the Chamber was of the
opinion that the cumulative effect of Urartu’s actions demonstrates a pattern of behaviour

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REF. FPSD-17964

aimed at pressuring the Player to either terminate the Contract or accept a modification of
its terms.
188. In the same vein, the Chamber noted that, based on the evidence on file, it appears that in
December 2024, Urartu expressed its intention not to continue the employment
relationship with the Player. Although the Player appeared open to a mutual termination,
he insisted that Urartu compensate him, given that he still had a valid contract. Urartu itself
acknowledged that there were discussions regarding a potential termination agreement
and that it was the Player who ultimately refused to terminate the Contract. The Chamber
also noted that Mr. Vardanyan, Urartu’s sporting director, offered to help the Player find a
new club, clearly indicating that Urartu was no longer interested in retaining his services.
189. Therefore, in the Chamber’s view, it is evident that Urartu had lost interest in retaining the
Player. Nevertheless, in the absence of a mutual agreement, Urartu formally reinstated
him. Ultimately, however, it obstructed his actual participation in team activities.
c.2) Ultima ratio
190. The Chamber then recalled that termination must be, in any event, a measure of ultima
ratio.
191. In this respect, the Chamber acknowledged that the Player did not issue a specific notice
of default requesting Urartu to cease the alleged abusive conduct that began on 9 January
2025, nor did he formally request to be included in the training camp. However, the
Chamber emphasised that the Player had already put Urartu in default on 3 January 2025,
and, on 6 January 2025, he warned Urartu that sidelining him would constitute unlawful
conduct.
192. In this context, the Chamber considered that, following these two warnings, and in light of
his exclusion from the training camp and Urartu’s continued failure to provide the
complete copy of the Contract - particularly after having expressed disinterest in his
services - the Player could no longer reasonably and in good faith be expected to continue
the contractual relationship.
193. While the Chamber noted - and was unimpressed – that the Player did not issue a further
warning notice immediately prior to terminating the Contract and instead terminated it
while granting Urartu 48 hours to clarify the situation, it determined that the breaches were
sufficiently serious to constitute just cause under art. 14 of the Regulations.
c.3) Conclusion
194. In light of all the above, the Chamber concluded that the Player had just cause to terminate
the Contract.

pg. 48

REF. FPSD-17964

D. Consequences
195. The Chamber first highlighted that, since the Player had just cause to terminate the
employment relationship, this necessarily led to the conclusion that Urartu’s counterclaim
against the Player and Sutjeska must be rejected in its entirety.
196. Having stated the above, the Chamber turned its attention to the question of the
consequences of such unjustified breach of contract committed by Urartu.
197. The Chamber noted that the Player claimed the following:
•

USD 122,400 as “outstanding salaries” from January 2025 to May 2026, plus
interest as from each due date;

•

USD 50,000 as moral damages;

•

USD 60,000 as loss of opportunity.

d.1) Outstanding remuneration and compensation
198. With respect to the claim for outstanding salaries, the Chamber noted that the Player
effectively sought the residual value of the Contract as compensation. However, given that
the termination occurred on 24 January 2025, and in line with the jurisprudence of the
Football Tribunal, the Chamber determined that the Player is entitled to the salary for
January 2025 as outstanding remuneration.
199. Therefore, the Chamber decided to award the Player USD 7,200 as outstanding
remuneration, with interest accruing from 24 January 2025, i.e., the date of the termination.
The Chamber remarked that, although Urartu argued that the Player did not request
interest in his original claim, he actually did.
200. Having stated the above, the Chamber turned to the calculation of the amount of
compensation payable by Urartu 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, taking into account the damage suffered, according to
the “positive interest” principle, having regard for the individual facts and circumstances of
each case, and with due consideration for the law of the country concerned.
201. 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 case, the Chamber noted that
clause 8.3 of the Contract stated:

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REF. FPSD-17964

“8.1.2. In accordance with the article 8.1.1 of the present Contract, if the Contract is
prematurely and unilaterally terminated by the Football Player (at his own will) or in case
of termination of this Contract upon the initiative of the Club on disciplinary grounds,
the Football Player shall be obliged to pay a fine in 140,000,000 (one hundred and four
million) in Armenian dram (AMD) as a liquidated damage.”
202. However, the Chamber observed that the Player and Urartu did not agree on any clause
establishing the amount payable to the Player in the event of termination with just cause.
In this regard, the Chamber established that no applicable compensation clause was
included in the employment contract at the basis of the matter at stake.
203. As a consequence, the Chamber determined that the amount of compensation payable by
Urartu to the Player had to be assessed in application of the other parameters set out in
art. 17, par. 1 of the Regulations. In this respect, the Chamber recalled that, as a general
rule, the compensation to be paid to a player by a club shall be equal to the residual value
of the contract that was prematurely terminated, unless this player signed a new contract
following the termination of his previous contract (cf., art. 17 par. 1 lit. i) of the Regulations).
204. Bearing in mind the foregoing as well as the claim of the Player, the Chamber proceeded
with the calculation of the monies payable to the Player under the terms of the Contract
(the Alleged Annex included) from the date of its unilateral termination until its end date.
Given that the Contract was valid until 1 June 2026, the Player was entitled to 16 monthly
salaries, totalling USD 115,200. Consequently, the Chamber concluded that the amount of
USD 115,200 (i.e., USD 7,200 times 16) serves as the basis for the determination of the
amount of compensation for breach of contract.
205. In continuation, the Chamber verified as to whether the Player 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 general obligation to mitigate
his damages.
206. Indeed, the Player found employment with Sutjeska and Feirense.
207. The Chamber noted that the Sutjeska Contract was valid from 1 February 2025 to 31 May
2025, and, under this contract, the Player was entitled to EUR 600 per month, as well as
lump sums of EUR 1,600 and EUR 13,600. Thus, the Chamber concluded that under the
Sutjeska Contract, the Player earned EUR 17,600, equivalent to USD 18,305.90 as of 6
February 2025

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REF. FPSD-17964

208. Additionally, the Feirense Contract is valid from 23 July 2025 to 30 June 2026, and, under
this contract, the Player is entitled to EUR 54,000, payable in 12 monthly instalments of EUR
4,500. Since the Contract was valid until 1 June 2026, the Chamber observed that during
the overlapping period the Player would receive EUR 49,500, which was equivalent to USD
58,099.60 on 26 July 2025.
209. Based on the above, the Chamber found that the Player mitigated his damages by USD
76,405.50. Therefore, the mitigated compensation amounts to USD 38,794.50 (i.e., USD
115,200 minus USD 76,405.50).
210. Subsequently, the Chamber referred to art. 17 par. 1 lit. ii) of the Regulations, according to
which a player is entitled to an amount corresponding to three monthly salaries as
additional compensation should the termination of the employment contract at stake be
due to overdue payables. In the case at hand, the Chamber confirmed that the contract
termination did not take place due to said reason i.e., overdue payables by Urartu and
therefore decided that the Claimant shall not receive additional compensation.
211. Consequently, on account of all the above-mentioned considerations and the specificities
of the case at hand, the Chamber decided that Urartu must pay the amount of USD
38,794.50 to the Player, which was to be considered a reasonable and justified amount of
compensation for breach of contract in the present matter.
212. Lastly, taking into consideration the Player’s request as well as the constant practice of the
Football Tribunal in this regard, the Chamber decided to award the Player interest on said
compensation at the rate of 5% p.a. as of 24 January 2025 until the date of effective
payment.
d.2) Moral damages
213. As the Player did not substantiate or quantify his claim for moral damages, nor did he
provide any evidence of the alleged harm, the Chamber decided to reject it. Furthermore,
the Chamber stressed that this claim lacks a contractual or regulatory basis.
d.3) Loss of opportunity
214. Although the Player demonstrated that he received an offer from the club Swift
Hesperange, the Chamber did not find sufficient evidence of a loss of opportunity,
particularly as the Player subsequently secured employment under better financial terms
with Urartu. Therefore, the Chamber decided to reject this claim due to lack of
substantiation.
ii. Compliance with monetary decisions

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REF. FPSD-17964

215. 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.
216. 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.
217. Therefore, bearing in mind the above, the DRC decided that Urartu must pay the full
amount due (including all applicable interest) to the Player within 45 days of notification of
the decision, failing which, at the request of the Player, 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 Urartu in
accordance with art. 24 par. 2, 4, and 7 of the Regulations.
218. Urartu shall make full payment (including all applicable interest) to the bank account
provided by the Player in the Bank Account Registration Form, which is attached to the
present decision.
219. 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
220. 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.
221. 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.
222. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.

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REF. FPSD-17964

IV. Decision of the Dispute Resolution Chamber
1.

The claim of the Claimant / First Counter-Respondent, Ayoub Abou Oulam Batas, is partially
accepted.

2.

The counterclaim of the Respondent / Counterclaimant, Urartu FC, is rejected.

3.

The Respondent / Counterclaimant must pay to the Claimant / First Counter-Respondent
the following amounts:
- USD 7,200 as outstanding remuneration plus 5% interest p.a. as from 24 January 2025
until the date of effective payment;
- USD 38,794.50 as compensation for breach of contract plus 5% interest p.a. as from 24
January 2025 until the date of effective payment.

4.

Any further claims of the Claimant / First Counter-Respondent are rejected.

5.

Full payment (including all applicable interest) shall be made to the bank account indicated
in the enclosed Bank Account Registration Form.

6.

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 / Counterclaimant shall be banned from registering any new players,
either nationally or internationally, up until the due amount is paid. The maximum
duration of the ban shall be of up to 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.

7.

The consequences shall only be enforced at the request of the Claimant / First
Counter-Respondent in accordance with art. 24 par. 7 and 8 and art. 25 of the Regulations
on the Status and Transfer of Players.

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REF. FPSD-17964

8.

This decision is rendered without costs.

For the Football Tribunal:

Emilio García Silvero
Chief Legal & Compliance Officer

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REF. FPSD-17964

NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 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.
NOTE RELATED TO THE PUBLICATION:
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., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
Fédération Internationale de Football Association – Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777

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