Labour Disputes
Texto da decisão
REF. FPSD-21168
Decision of the
Dispute Resolution Chamber
passed on 20 January 2026
regarding an employment-related dispute concerning the player Bouly Junior
Sambou
BY:
Stella MARIS JUNCOS (Argentina)
CLAIMANT:
Bouly Junior Sambou, Senegal
Represented by Hamouda Bouazza
RESPONDENT:
Sanliurfaspor, Türkiye
Represented by Korhan Armağan
pg. 2
REF. FPSD-21168
I. Facts of the case
1.
On 5 February 2025, Bouly Junior Sambou (hereinafter: the Player or the Claimant) and
Sanliurfaspor (hereinafter: the Club or the Respondent) entered into an employment
contract (hereinafter: the Standard Contract) valid as from 5 February 2025 until 30 June
2025.
2.
According to its clause 3, the Player’s monthly salary corresponded to the “minimum wage.”
3.
On 7 February 2025, the parties signed a second employment contract (hereinafter: the
Contract) valid for the season 2024/2025.
4.
According to art. 6 of the Contract, the parties agreed on the following remuneration:
-
5.
USD 25,000 net that has been paid as advance payment on signature date;
USD 60,000 net in total payable in 3 equal instalments of USD 20,000 net between
March 2025 and May 2025.
On 15 September 2025, the Player sent a default notice to the Club requesting the total
amount of USD 60,000 corresponding to the salaries of March, April and May 2025 of the
amount of USD 20,000 net each. The Player gave a 10-day deadline to the Club to comply
with its default.
II. Proceedings before FIFA
6.
On 3 October 2025, the Claimant filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Claimant
7.
The Player lodged the present claim with FIFA for overdue salaries.
8.
The Player argued that the Club has not paid the salaries corresponding to the months of
March, April and May 2025 of USD 20,000 net each.
9.
In view of the above, the Player requested the following relief:
-
USD 20,000 net corresponding to the salary of March 2025, plus 5% interest as from 31
March 2025 until the date of effective payment;
USD 20,000 net corresponding to the salary of April 2025, plus 5% interest as from 30
April 2025 until the date of effective payment;
pg. 3
REF. FPSD-21168
-
USD 20,000 net corresponding to the salary of May 2025, plus 5% interest as from 31
May 2025 until the date of effective payment.
b. Reply of the Respondent
10. In its reply, the Club argued that the Contract is not signed and therefore it cannot serve
as legal basis for the present claim.
11. In view of the above, the Club claimed that the only document on the basis of the
employment relationship is the Standard Contract that establishes as salary the “minimum
wage”. According to the Club, the minimum wage in Türkiye is approximately EUR 700.
12. In addition, the Club provided a document claiming it to be a proof of payment. According
to the Club, the proof of payment corresponded to the following amounts:
-
TRY 900,000 (approx. USD 25,139.66) in the concept of “Protokol”;
USD 14,000 on 26 March 2025 in the concept of “Salary”.
13. Furthermore, the Club argued that the reference to dollar is vague and it cannot be
established whether it corresponded to USD or to another dollar such as CAD or AUD.
14. Consequently, the Club requested the following relief:
“In view of the foregoing, we respectfully request:
- In any cases, that all claims of the Claimant be dismissed in their entirety;
- In the event that the Tribunal reaches a contrary conclusion, deduct the Payments made by
the Club from the Player’s earnings,
- In any case we respectfully also request that the claim be dismissed at least in respect of the
unclear interest commencement dates and rule that the interest shall be start from the date
of filing of the claim.”
c. Replica of the Claimant
15. The Player argued that the only payment that he has received corresponded to the sign-on
fee of USD 25,000. In addition, he claimed that he did not request the payment of this
amount in the present claim and therefore, the payment of the sign-on fee remained
undisputed.
16. The Player denied having received any other payment from the Club.
17. Regarding the document provided by the Club, he argued that such document did not show
the concept of the payment made on 26 March 2025 of USD 14,000.
pg. 4
REF. FPSD-21168
18. Consequently, the Player reiterated his initial request for relief.
d. Duplica of the Respondent
19. Despite being invited to do so, the Club did not provide its final comments.
pg. 5
REF. FPSD-21168
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
20. First of all, the Single Judge of the Dispute Resolution Chamber (hereinafter: the Single Judge)
analysed whether she was competent to deal with the case at hand. In this respect, she
took note that the present matter was presented to FIFA on 3 October 2025 and submitted
for decision on 20 January 2026. Taking into account the wording of arts. 32 and 35 of the
January 2026 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.
21. Furthermore, the Single Judge 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 on the Status and Transfer of Players (hereinafter: 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
an Senegalese player and a Turkish club.
22. Subsequently, the Single Judge analysed which regulations should be applicable as to the
substance of the matter. In this respect, she 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.
b. Burden of proof
23. The Single Judge 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 Single Judge
stressed the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which she may
consider evidence not filed by the parties, including without limitation the evidence
generated by or within the Transfer Matching System (TMS).
c. Merits of the dispute
24. Having established the competence and the applicable regulations, the Single Judge
entered into the merits of the dispute. In this respect, the Single Judge started by
acknowledging all the above-mentioned facts as well as the arguments and the
documentation on file. However, the Single Judge emphasised that in the following
considerations she will refer only to the facts, arguments and documentary evidence,
which she considered pertinent for assessing the matter at hand.
pg. 6
REF. FPSD-21168
i. Main legal discussion and considerations
25. The Single Judge then moved to the substance of the matter and took note of the fact that
the parties strongly disputed the amount that has remained outstanding from their
employment relationship.
26. In this context, the Single Judge acknowledged that her task was to determine which
amount remained outstanding and the consequences thereof.
27. The Singe Judge recalled that the Player requested the following amounts arising from the
Contract:
-
USD 20,000 net for the salary of March 2025;
USD 20,000 net for the salary of April 2025;
USD 20,000 net for the salary of May 2025.
28. The Singe Judge also noted that the Club argued that the Contract, which is the basis on
which the Player requested the above amounts, is null and void as it does not bear the
Club’s signature. However, the Single Judge observed that the Contract is duly signed and
stamped by the Club and therefore, the Club’s argument was considered moot.
29. In addition, the Single Judge took note of the fact that the Club claimed to have paid the
amounts of TYR 900,000 and USD 14,000. In this regard, the Single Judge observed that the
Club provided a document alleging to be a proof of payment. However, such document,
not only did not include the concept of the payments but also it did not specify in which
currency the payments were made.
30. For the sake of completeness, the Single Judge wished to clarify that the Club also provided
a document purportedly representing a translation of the proof of payment that was in the
Turkish language which included both the currency and the concept that was missing from
the original document. However, the Single Judge considered that this translation did not
appear to be official, as it was incomplete and seemed to contain discrepancies and
additional information compared to the original document.
31. In view of the Club’s allegations, the Player argued that he never requested the payment of
the sign-on fee (which corresponded to TYR 900,000, approx. USD 25,000). In addition, he
claimed that he never received the alleged payment of USD 14,000.
32. In light of the above, the Single Judge considered that the Club did not discharge its burden
of proving compliance with its financial obligations towards the Player.
33. Consequently, the Single Judge decided to award the Player the total amount of USD 60,000
net arising from the Contract.
pg. 7
REF. FPSD-21168
34. In addition, taking into consideration the Player’s request as well as the constant practice
of the Football Tribunal in this regard, the Single Judge decided to award the Player interest
at the rate of 5% p.a. on the outstanding amounts as follows:
o
o
o
5% interest p.a. over the amount of USD 20,000 as from 1 April 2025 until the
date of effective payment;
5% interest p.a. over the amount of USD 20,000 as from 1 May 2025 until the
date of effective payment;
5% interest p.a. over the amount of USD 20,000 as from 1 June 2025 until the
date of effective payment.
ii. Art. 12bis of the Regulations
35. The Single Judge then referred to art.12bis par. 2 of the Regulations, which stipulates that
any club found to have delayed a due payment for more than 30 days without a prima facie
contractual basis may be sanctioned, in accordance with art. 12bis par. 4 of the Regulations.
36. To this end, the Single Judge confirmed that the Claimant put the Respondent in default of
payment of the amounts sought, which had fallen due for more than 30 days, and granted
the Respondent with at least 10 days to cure such breach of contract.
37. Accordingly, the Single Judge also confirmed that the Respondent had delayed a due
payment without a prima facie contractual basis. It followed that the criteria enshrined in
art. 12bis of the Regulations were met in the case at hand.
38. The Single Judge further established that, by virtue of art. 12bis par. 4 of the Regulations
the Single Judge has competence to impose sanctions on the club. On account of the above,
and bearing in mind that this is the sixth offense by the Respondent within the last two
years, the Single Judge decided to impose a fine of USD 12,500 on the Respondent in
accordance with art. 12bis par. 4 lit. c) of the Regulations.
39. The Single Judge also highlighted that a repeated offence will be considered as an
aggravating circumstance and lead to more severe penalty, in accordance with art. 12bis
par. 6 of the Regulations.
iii. Compliance with monetary decisions
40. Finally, taking into account the applicable Regulations, the Single Judge 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.
pg. 8
REF. FPSD-21168
41. In this regard, the Single Judge 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.
42. Therefore, bearing in mind the above, the Single Judge decided that the Respondent must
pay the full amount due (including all applicable interest) to the Claimant within 45 days of
notification of the decision, failing which, at the request of the Claimant, a ban from
registering any new players, either nationally or internationally, for the maximum duration
of three entire and consecutive registration periods shall become immediately effective on
the Respondent in accordance with art. 24 par. 2, 4, and 7 of the Regulations.
43. The Respondent shall make full payment (including all applicable interest) to the bank
account provided by the Claimant in the Bank Account Registration Form, which is attached
to the present decision.
44. The Single Judge 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
45. The Single Judge 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 Single Judge decided that no procedural costs were to be
imposed on the parties.
46. Likewise, and for the sake of completeness, the Single Judge recalled the contents of art.
25 par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
47. Lastly, the Single Judge concluded her deliberations by rejecting any other requests for
relief made by any of the parties.
pg. 9
REF. FPSD-21168
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Bouly Junior Sambou, is partially accepted.
2.
The Respondent, Sanliurfaspor, must pay the Claimant the following amount:
- USD 60,000 net as outstanding remuneration plus 5% interest p.a. as follows:
- 5% interest p.a. over the amount of USD 20,000 as from 1 April 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of USD 20,000 as from 1 May 2025 until the date of
effective payment;
- 5% interest p.a. over the amount of USD 20,000 as from 1 June 2025 until the date of
effective payment.
3.
Any further claims of the Claimant are rejected.
4.
A fine in the amount of USD 12,500 is imposed on the Respondent, which must be paid
to FIFA within 30 days of notification of this decision. Such fine must be paid to the
following bank account with a clear reference to the case FPSD-21168:
UBS Zurich
Account number 230-366677.61N (FIFA Players’ Status)
Clearing number 230
IBAN: CH12 0023 0230 3666 7761 N
SWIFT: UBSWCHZH80A
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 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 in accordance
with art. 24 par. 7 and 8 and art. 25 of the Regulations on the Status and Transfer of Players.
pg. 10
REF. FPSD-21168
8.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 11
REF. FPSD-21168
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
pg. 12