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Why did Manchester City escape with a fine when Chelsea were banned for violating FIFA Article 19?

Trying to make sense of FIFA’s decisions

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Earlier this week, FIFA fined Manchester City a little over £300,000 (370k Swiss Francs) for violating Article 19 (“among others”), which, as we know, is the rule regarding the international transfers of players under the age of 18.

It’s the same rule that Chelsea, Barcelona, Real Madrid, and Atlético Madrid were all found to have breached in the last few years. All four clubs were given transfer bans of at least one transfer window, though Real Madrid successfully appealed to CAS and had their two-window ban cut in half (the bans were also frozen during appeal). In Chelsea’s case, the club were banned for two consecutive windows and fined CHF 600k. The club currently have an appeal ongoing with CAS (but without a freeze), which could yet reduce the ban to just one transfer window, the just completed summer one.

So what’s the difference? Why did City escape with a fine and why were Chelsea hit with the harshest penalties yet?

While we’re not privy to FIFA’s decision-making process, we can make a few educated guesses as to why this discrepancy may exist. On the surface, the City decision is “astonishing” but when we look closer, it’s decidedly less so. It’s still not a good look if FIFA want to avoid accusations of bias and collusion, but that’s FIFA for you.


Chelsea were found to have breached Article 19 (“Protection of Minors”) — both 19.1 and 19.3 — as well as Article 18 bis (“Third-party influence on clubs”). The former is the one that makes all the headlines, and the one that is common between all the banned teams. The latter is a bit murkier, but was specifically called out in Chelsea’s case.

City were found to have breached Article 19, “among others”. Unfortunately, FIFA’s statement does not specify what other breaches have occurred, though reports have speculated that it could involve third-party ownership.

In essence, both clubs violated the same rules.


FIFA made it a point to emphasize that Chelsea breached Article 19 in 29 cases (from the 92 that were under investigation!). The number of violations of Article 18 is unknown, but it was usually reported as just 2.

FIFA did not specify the number of violations in City’s case, but reports only ever spoke of maybe a handful of players.

What is clear is that Chelsea’s breaches were an all-time high, and City’s numbers paled in comparison. And while a breach is a breach, punishments in most cases, be they civil, criminal, or sporting, depend a great deal on the magnitude of the breach.


It’s assumed that Chelsea were investigated for transfers occurring in the last 10 years (the maximum allowed by FIFA’s own rules), with many of the violations occurring in the last few years.

All of City’s violations apparently occurred before 2016, which is when FIFA issued the new and still current guidance. City claim they simply “misinterpreted” the rules, though it should be noted that when Chelsea were punished, FIFA also fined the English FA for violating FIFA rules (i.e. both teams probably complied with FA regulations, but those regulations themselves were in violation of FIFA rules).


Chelsea denied and denied; cooperated, but denied.

City “accepted responsibility”, as pointed out in FIFA’s statement. Reports also speak of a “very open” and “transparent” dialogue between the team and the governing body.

Neither approach is inherently wrong. But in essence, City agreed to a plea deal.


Chelsea’s prior history (i.e. Gaël Kakuta) probably played a role, even if the punishment in that case was eventually thrown out on appeal. Chelsea were also the first club to be investigated after FIFA made it a point to emphasize and streamline these investigations — thus throwing out the precedent set by the three La Liga cases — and ensure that they actually have some “bite” (and clubs can’t just freeze them and basically avoid the negative effects).

Both City and Chelsea had been on FIFA’s radar for a while: City since 2014, Chelsea since at least the first time Bertrand Traoré turned up as a trialist for the youth team in 2012.

UEFA and The FA are also investigating Manchester City at this time, for financial irregularities and youth recruitment violations, respectively, but those don’t actually have anything to do with the FIFA investigation. UEFA could conceivably throw City out of the Champions League if they manage to conclude the obvious (that City are practically state-funded), while The FA’s investigation, which relates to the signing of Jadon Sancho from Watford’s academy, is unlike to produce anything but a fine.

In short, Chelsea were made an example of and City got off lightly. But City also broke the rules in a much less egregious fashion, and took the friendly approach to negotiate a good deal. C’est la vie.

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