FIFA Clearing House Payment Process PDF

8 Article 1: Objectives 1.1 FIFA has a statutory obligation to regulate all matters relating to the football transfer system. The FIFA Clearing House shall serve to protect the core objectives of the football transfer system in accordance with the FIFA Statutes and the RSTP, notably to: a) protect...

8 Article 1: Objectives 1.1 FIFA has a statutory obligation to regulate all matters relating to the football transfer system. The FIFA Clearing House shall serve to protect the core objectives of the football transfer system in accordance with the FIFA Statutes and the RSTP, notably to: a) protect the contractual stability between professional players and clubs; b) encourage the training of young players; c) promote a spirit of solidarity between the elite and grassroots football; d) protect minors; e) maintain competitive balance; and f) 1.2 ensure the regularity of sporting competitions. The specific objectives of the FIFA Clearing House are to: a) process specific payments related to the transfer of football players between clubs; b) protect the integrity of the football transfer system; c) enhance and promote financial transparency in the football transfer system; and d) prevent fraudulent conduct in the football transfer system. 1.3 In pursuit of these objectives, the FIFA Clearing House acts as an intermediary for the payment of training rewards in the football transfer system that fall due pursuant to the RSTP and performs all required Compliance Assessments in their execution. Article 2: Scope 2.1 These Regulations lay down the process for the payments processed through the FIFA Clearing House. 2.2 These Regulations apply to all such payments relating to eleven-a-side football only. 2.3 These Regulations apply to all parties bound by the FIFA Statutes. Football Agent Exam Study Materials – May 2023 edition - 346 9 Article 3: FIFA Clearing House The FIFA Clearing House is a separate entity from FIFA and was established to act as an intermediary in payments deriving from the football transfer system. The FIFA Clearing House is a payment service provider with a licence from the appropriate regulatory authorities. Its governance structure is detailed in its articles of association. 3.2 The FIFA Clearing House shall not make a financial profit from the assets it receives and/or transactions it undertakes. 3.3 The legal relationship between the FIFA Clearing House and the parties involved in transactions processed through the FIFA Clearing House is governed exclusively by the FCH Terms & Conditions and these Regulations. 3.4 The FIFA Data Protection Regulations apply to all matters described in these Regulations, including all interactions with the FIFA Clearing House. Introductory provisions 3.1 I. Football Agent Exam Study Materials – May 2023 edition - 347 PROCEDURE GOVERNING THE CALCULATION AND PAYMENT OF TRAINING REWARDS II. Football Agent Exam Study Materials – May 2023 edition - 348 11 Article 4: Registration and transfer of players 4.1 Member associations and clubs shall ensure that reliable, accurate, and complete player registration and transfer information is made available electronically to FIFA at all times. 4.2 Member associations and clubs shall use an electronic player registration system, an electronic domestic transfer system, TMS, the FIFA Connect ID Service, and the FIFA Connect Interface to communicate registration and transfer information electronically to FIFA. 4.3 Each member association shall: a) use an electronic player registration system, integrated with the FIFA Connect ID Service and FIFA Connect Interface, to register players; and b) use an electronic domestic transfer system, integrated with the FIFA Connect Interface, to process national transfers. 4.4 Each member association shall maintain accurate and up-to-date player registration data in its electronic player registration system and the FIFA Connect ID Service at all times, including, without limitation, the following information: b) the type(s) of football (11-a-side football, futsal, and/or beach soccer) that the player is registered to participate in; and c) 4.5 the category of the club(s) with which the player is registered. Each member association shall maintain accurate and up-to-date data regarding its affiliated clubs (whether current or former) in its electronic player registration system and the FIFA Connect ID Service at all times, including, without limitation, the following information: a) address and contact details; b) current and historical data regarding club categorisation; and c) 4.6 current and historical data regarding the affiliation to the member association. A club shall be categorised by a member association based on the criteria established in the RSTP. No other categorisation system shall be recognised. PROCEDURE GOVERNING THE CALCULATION AND PAYMENT OF TRAINING REWARDS a) the status of the player in accordance with article 2 of the RSTP; II. Football Agent Exam Study Materials – May 2023 edition - 349 12 4.7 Subject to article 17 of these Regulations, only players registered by a member association with a club and identified with a FIFA ID through the electronic systems described in this article shall be considered for the automatic calculation and payment of training rewards. 4.8 Member associations are responsible for the registration information that is included in the final EPP. Article 5: Training rewards trigger: first registration as a professional First registration as a professional at the same member association where the player was most recently registered as an amateur 5.1 The first registration of a player as a professional at the same member association where the player was most recently registered as an amateur shall be entered or confirmed by the member associations in the electronic player registration system, following a request from the club for which the player will be registered. a) If the first registration as a professional is with the same club where the player was most recently registered as an amateur, the member association shall update the status of the player. b) If the first registration as a professional occurs after a transfer between clubs affiliated to the same member association, the relevant club(s) and/or member association shall enter the national transfer in the electronic domestic transfer system and update the status of the player at the new club. c) Such procedures shall be governed by specific regulations issued by each member association. 5.2 The electronic player registration system shall communicate the details of the first registration as a professional to FIFA through the FIFA Connect Interface within thirty (30) days of the domestic registration. 5.3 TMS will identify, from the information communicated by the member association, the first registration of a player as a professional, which may trigger an entitlement to training rewards pursuant to the RSTP. Football Agent Exam Study Materials – May 2023 edition - 350 13 First registration as a professional at the same member association where the player was most recently registered as an amateur – manual declaration 5.4 Where the electronic player registration system of a member association is not fully integrated and unable to communicate the first registration of a player as a professional to FIFA through the FIFA Connect Interface, the member association shall exceptionally declare that registration manually in TMS within thirty (30) days of the domestic registration, subject to the following conditions: a) Member associations shall request the prior written approval of the FIFA general secretariat to make manual declarations in TMS. b) Written approval may be granted, at the discretion of the FIFA general secretariat, for a defined period of time. Conditions may be attached to the written approval on a case-by-case basis, at the discretion of the FIFA general secretariat. At the conclusion of this period, member associations shall comply with the electronic-system obligations set out in article 4 paragraph 2. 5.5 A member association shall provide the compulsory data when entering this manual declaration in TMS. 5.6 A member association shall upload the employment contract of the player as part of the manual declaration to support the information that has been entered in TMS. 5.7 FIFA may request further documentation or information from the member association at any time. 5.8 TMS will identify, from the information declared by the member association, the first registration of a player as a professional, which may trigger an entitlement to training rewards pursuant to the RSTP. First registration as a professional at a different member association from that where the player was most recently registered as an amateur 5.9 The first registration of a player as a professional at a different member association from that where the player was most recently registered as an amateur shall be entered in TMS as an international transfer as required by the RSTP and its Annexe 3. 5.10 TMS will identify, from the information provided in the international transfer instruction, the first registration of a player as a professional, which may trigger an entitlement to training rewards pursuant to the RSTP. PROCEDURE GOVERNING THE CALCULATION AND PAYMENT OF TRAINING REWARDS c) II. Football Agent Exam Study Materials – May 2023 edition - 351 14 Article 6: Training rewards trigger: international transfer 6.1 All details relating to the international transfer of a player within the scope of eleven-a-side football shall be entered in TMS as provided in Annexe 3 to the RSTP. 6.2 For the avoidance of doubt, any training reward payable pursuant to the RSTP shall not be included in the amount declared as transfer compensation. 6.3 TMS will identify international transfers that may trigger an entitlement to training rewards pursuant to the RSTP. Article 7: T  raining rewards trigger: national transfer involving transfer compensation 7.1 A national transfer shall be entered in the electronic domestic transfer system whenever a player is registered with a new club within the same member association. 7.2 Each member association shall ensure and verify, if required, the accuracy of the data declared and supporting documents submitted by its affiliated clubs in the electronic domestic transfer system. 7.3 The electronic domestic transfer system shall communicate information about the transfer and proof of (each) payment to FIFA through the FIFA Connect Interface within thirty (30) days of registration of the player or date of (each) payment. 7.4 TMS will identify, from the information communicated by the member association, national transfers for compensation that may trigger an entitlement to training rewards pursuant to the RSTP. National transfer involving transfer compensation – manual declaration 7.5 Where the electronic domestic transfer system of a member association is unable to communicate the details of a national transfer involving transfer compensation to FIFA through the FIFA Connect Interface, the member association shall exceptionally manually declare the transfer in TMS within thirty (30) days, subject to the following conditions: a) Member associations shall request the prior written approval of the FIFA general secretariat to make manual declarations in TMS. b) Written approval may be granted, at the discretion of the FIFA general secretariat, for a defined period of time. Conditions may be attached to the written approval on a case-by-case basis, at the discretion of the FIFA general secretariat. Football Agent Exam Study Materials – May 2023 edition - 352 15 c) At the conclusion of this period, member associations shall comply with the electronic-system obligations set out in article 4 paragraph 2. 7.6 A member association shall provide the compulsory data, including the transfer agreement where applicable, when entering this manual declaration in TMS. 7.7 FIFA may request further documentation or information from the member association at any time. 7.8 TMS will identify, from the information declared by the member association, national transfers for compensation that may trigger an entitlement to training rewards pursuant to the RSTP. National transfer involving transfer compensation – exception A member association may apply to the FIFA general secretariat for an exception to paragraph 3 (or paragraph 5) of this article if, in the calendar year prior to its application, there were at least one hundred (100) national transfers involving transfer compensation. If approval is granted, the member association is only obliged to communicate information about a national transfer involving transfer compensation if: (i) the training club(s) of the relevant player is/are affiliated to another member association, or (ii) not all training clubs in the player’s career have been identified. The following terms apply: a) Member associations shall request the prior written approval of the FIFA general secretariat. b) Written approval may be granted, at the discretion of the FIFA general secretariat, for a defined period. Conditions may be attached to the written approval on a case-by-case basis, at the discretion of the FIFA general secretariat. c) At the conclusion of this period, member associations shall submit a new application for the exception. d) Member associations shall communicate details of the relevant national transfers within thirty (30) days, regardless of whether they believe training rewards are payable. e) A member association that was granted an exception and fails to comply with this paragraph 9 shall be subject to disciplinary proceedings in accordance with article 17 paragraph 4. PROCEDURE GOVERNING THE CALCULATION AND PAYMENT OF TRAINING REWARDS 7.9 II. Football Agent Exam Study Materials – May 2023 edition - 353 16 Article 8: Electronic Player Passport (EPP) 8.1 When a training rewards trigger is identified as defined in these Regulations and in accordance with articles 20 and 21 of the RSTP, a provisional EPP for the relevant player will be generated by TMS. 8.2 The provisional EPP will be available for inspection in TMS by all member associations and clubs for ten (10) days after generation (inspection period). 8.3 During the inspection period: a) a member association that is not listed in the provisional EPP and believes that one or more of its affiliated clubs should be included in the final EPP may request to be included in the EPP review process; b) a club that is not listed in the provisional EPP and believes that it should be included in the final EPP may request its member association to be included in the EPP review process and to provide pertinent registration information. Member associations must act in good faith when responding to this request. 8.4 Upon completion of the inspection period, the FIFA general secretariat will assess the provisional EPP for accuracy and relevance. It may discard a provisional EPP in cases where, according to the registration information available in the provisional EPP, there is no indication that the player was registered with a different member association. Upon the substantiated request of an interested member association or club, and even after a provisional EPP has been discarded, the FIFA general secretariat may, at its discretion, reopen a provisional EPP at any time. Article 9: EPP review process 9.1 Upon completion of the inspection period and after assessment by the FIFA general secretariat as per article 8, the FIFA general secretariat will open an EPP review process in TMS and invite the following parties to participate: a) the member associations that have provided registration information relating to the player through the FIFA Connect interface; b) their relevant affiliated club(s); c) the new club and its member association; d) any member association that has requested or been requested to be included (cf. article 8 paragraph 3) and their relevant affiliated club(s), at the discretion of the FIFA general secretariat; and e) any other member association(s) deemed relevant by the FIFA general secretariat, at its discretion. Football Agent Exam Study Materials – May 2023 edition - 354 17 9.2 The EPP review process shall last ten (10) days. The FIFA general secretariat may, at its discretion, exceptionally extend its duration. 9.3 Member associations may review and/or request the amendment of any registration information. 9.4 Any request to amend registration information shall be submitted in TMS by the relevant member association. Such requests shall include, without limitation: a) a document corroborating the registration of the player, issued by the member association; b) a copy of any relevant International Transfer Certificate, if applicable; and a copy of any relevant employment contract, if applicable. 9.5 Where a former club is required to have offered a contract to a player to retain its entitlement to training compensation in accordance with the RSTP, proof of that offer and its notification shall also be uploaded in TMS by the former club. 9.6 Where a former club did not offer a contract to a player and it believes that it is still entitled to training compensation, a request shall be submitted in TMS by the club or its member association, including written reasons for the request and supporting evidence. 9.7 Where a training club has waived its right to receive training rewards, proof of a valid waiver shall be uploaded in TMS by the new club. 9.8 A training club that believes that a waiver submitted by the new club in relation to the registration of the player at the training club is not valid may challenge the validity of the waiver by submitting a written notice in TMS. 9.9 The FIFA general secretariat may request any party involved in an EPP review process to provide further information at any time. 9.10 The FIFA general secretariat will notify all parties in TMS when the EPP review process has been completed. PROCEDURE GOVERNING THE CALCULATION AND PAYMENT OF TRAINING REWARDS c) II. Football Agent Exam Study Materials – May 2023 edition - 355 18 Article 10: FIFA determination 10.1 After completion of the EPP review process, the FIFA general secretariat will evaluate any request to amend registration information. a) Where a request is unclear or incomplete, the FIFA general secretariat may request the relevant party to provide further information within five (5) days. b) Failure to comply with FIFA’s request within the time limit shall result in the request being disregarded. 10.2 The FIFA general secretariat may request any party involved in an EPP review process, whether during or after the EPP review process, to provide its position as to the entitlement of a club to receive training rewards (e.g. with respect to the alleged registration of a player, the validity of a waiver or a contract offer). 10.3 Following the completion of its evaluation, the FIFA general secretariat will decide on the registration information to be incorporated and amended in the final EPP. In situations of legal or factual complexity, the following shall apply: a) The FIFA general secretariat shall refer the matter to the Dispute Resolution Chamber in accordance with the Procedural Rules. b) The complete file is transferred to the Dispute Resolution Chamber and the EPP review process is paused pending a decision. c) The Dispute Resolution Chamber will decide on the final EPP in accordance with the Procedural Rules. 10.4 An Allocation Statement will be automatically calculated by TMS based on the final EPP, including the amount(s) to be distributed to training clubs. 10.5 The FIFA general secretariat will notify the final EPP and the Allocation Statement to all parties in the EPP review process. a) This notification will include the decision of the Dispute Resolution Chamber and its grounds for cases covered under article 10 paragraph 3. b) This notification shall be considered a final decision by the FIFA general secretariat for the purposes of article 57 paragraph 1 of the FIFA Statutes and may be appealed to the Court of Arbitration for Sport (CAS). c) Failure to appeal by the time limit in the FIFA Statutes shall result in the EPP and the Allocation Statement becoming final and binding. d) A valid and timely appeal to CAS shall suspend the legal effects of an EPP and of the corresponding Allocation Statement for the duration of the respective proceedings before CAS. Football Agent Exam Study Materials – May 2023 edition - 356 19 10.6 A final EPP for each training rewards trigger will be permanently available in TMS for inspection by all member associations and clubs. a) The registration information contained in the first final EPP of a player is binding on any future final EPP of a player. b) Where the first final EPP of a player is created before the calendar year of the player’s 23rd birthday, the addition of registration information by a member association for subsequent years will be only considered for future final EPP processes. c) Where a decision of the Dispute Resolution Chamber in relation to an EPP is made, the decision shall be binding on any future final EPP of a player as from the date on which the decision becomes final and binding. d) Where a future final and binding EPP of a player contains different registration information than that which is binding in accordance with paragraph (a), (b) or (c), the member association that failed to provide accurate registration information shall be sanctioned in accordance with article 17. 11.1 For an international transfer involving transfer compensation, the new club shall upload proof of (each) payment in TMS within thirty (30) days of the date of the payment, as provided for in Annexe 3 to the RSTP. 11.2 For a national transfer involving transfer compensation, the new club shall upload proof of (each) payment in the electronic domestic transfer system within thirty (30) days of the date of the payment. a) This information shall be validated by the relevant member association before being communicated to FIFA. b) The electronic domestic transfer system shall communicate this data to FIFA through the FIFA Connect Interface. 11.3 For a national transfer involving transfer compensation that is manually declared in TMS in accordance with article 7 paragraph 5, the relevant member association shall upload proof of (each) payment in TMS within thirty (30) days of the date of the payment. 11.4 For the purposes of calculating the Allocation Statement, the amount declared in the proof of payment will be considered to reflect the respective transfer compensation (or instalment thereof), with 5% as solidarity contribution having been withheld by the club making the payment, in accordance with article 1 paragraph 1 of Annexe 5 to the RSTP. PROCEDURE GOVERNING THE CALCULATION AND PAYMENT OF TRAINING REWARDS Article 11: Proof of payment of transfer compensation II. Football Agent Exam Study Materials – May 2023 edition - 357 FIFA CLEARING HOUSE PAYMENT PROCESS III. Football Agent Exam Study Materials – May 2023 edition - 358 21 Article 12: Allocation Statement 12.1 Each Allocation Statement will be sent by TMS to the FIFA Clearing House immediately after it is generated and will contain all the information required to collect the relevant amount(s) and distribute payment(s) to the training club(s). 12.2 Relevant information on clubs and member associations available in TMS (including banking details) will be sent to the FIFA Clearing House for payment processing. If relevant information on the clubs and member associations is not included or is incomplete, the FIFA Clearing House will procure this information. If the missing information is essential for the identification of, and initial communication to, the club(s), the FIFA Clearing House will request this information from the member association of the relevant clubs(s). Member associations shall, where necessary, provide further contact details, including, without limitation, a valid and operational email address of the club, within seven (7) days of the request by the FIFA Clearing House. 12.3 The Allocation Statement will be generated as follows: a) training compensation: after the EPP is final (article 10); b) solidarity mechanism: after the EPP is final (article 10) and after receipt of proof of (each) payment (article 11); in cases where a decision of the Dispute Resolution Chamber is rendered pursuant to these Regulations (cf. article 10 paragraphs 3 a) and b) and/ or article 18 paragraph 2), after such decision becomes final and binding in accordance with the Procedural Rules. 12.4 In cases of solidarity mechanism where the training rewards are calculated in a different currency to the euro (EUR), United States dollar (USD) or British pound sterling (GBP), the FIFA general secretariat will convert the amount of training rewards payable to EUR. The exchange rate used will be the rate on the date when the corresponding payment of transfer compensation was made. There shall be no right to challenge the exchange rate applied. 12.5 The FIFA Clearing House may start the Compliance Assessment in accordance with article 15 before the deadline for appeal to CAS has expired. FIFA Clearing House payment process c) III. Football Agent Exam Study Materials – May 2023 edition - 359 22 Article 13: Payment by the new club to the FIFA Clearing House 13.1 Subject to the new club and training club(s) passing the Compliance Assessment and the relevant EPP and the Allocation Statement becoming final and binding, the FIFA Clearing House will issue a Payment Notification to the new club detailing the total amount due. a) The Payment Notification shall be sent by the FIFA Clearing House via email or registered post to the address obtained in accordance with article 12 paragraph 2. Notification by these means shall be considered valid to establish time limits. b) The new club is liable for any consequences in case of failure to maintain up-to-date addresses in TMS. Notification to an address registered in TMS shall, in any event, be considered valid to establish time limits. 13.2 Upon receipt of the payment notification, the new club shall pay the requested amount within thirty (30) days to the FIFA Clearing House. 13.3 The new club shall pay the requested amount, including any applicable bank fees. The FIFA Clearing House must receive the requested amount in full. The new club may not assign responsibility to pay the requested amount to any other party. The FIFA Clearing House will only accept payment of training rewards through a bank transfer from a bank account in the name of the club. 13.4 If a new club fails to pay the requested amount in full by the specified deadline, it shall be: a) charged an administrative levy of 2.5% of the requested amount by the FIFA Clearing House, payable to each training club instead of interest for late payment; and b) given a further seven (7) days to pay the requested amount in full by the FIFA Clearing House. 13.5 A new club that fails to pay the requested amount in full by the further deadline in accordance with paragraph 4 above shall be subject to disciplinary proceedings in accordance with article 17. Football Agent Exam Study Materials – May 2023 edition - 360 23 Article 14: Payment by the FIFA Clearing House to the training club(s) Upon receipt of full payment from the new club, the FIFA Clearing House will generate a Distribution Statement based on the final and binding EPP and Allocation Statement, which shall include the purpose and source of each payment, to make payment(s) to the training club(s). Such Distribution Statement will be sent via email or registered post to each training club. 14.2 The FIFA Clearing House will make payment into the bank account (registered in the name of the training club) provided by each training club. FIFA Clearing House payment process 14.1 III. Football Agent Exam Study Materials – May 2023 edition - 361 COMPLIANCE ASSESSMENT IV. Football Agent Exam Study Materials – May 2023 edition - 362 25 Article 15: Compliance Assessment 15.1 The FIFA Clearing House has a legal obligation to monitor its business relationships and the transactions carried out during the existence of those relationships. 15.2 The FIFA Clearing House will assess all parties that are involved in the payment of money to, or receipt of money from, the FIFA Clearing House, to ensure that they comply with national and international laws and regulations in relation to, without limitation: a) international payment sanctions; b) anti-money laundering; c) anti-bribery and corruption; and d) countering the financing of terrorism. 15.3 To perform the required Compliance Assessment, the FIFA Clearing House may request an individual, club, and/or member association to provide information regarding the following, as applicable and without limitation: a) corporate structure; b) organisational structure; c) beneficial ownership; d) source of funding; 15.4 Individuals, clubs, and member associations shall actively cooperate with a request for information from the FIFA Clearing House. The degree of cooperation of an individual, club, or member association shall form part of the Compliance Assessment. Lack of cooperation by the parties may result in a failure to pass the Compliance Assessment. 15.5 All documents provided to and communications with the FIFA Clearing House shall be in English, Spanish or French. Documentation in any other language shall be translated into one of these three languages. 15.6 After receipt and analysis of the information requested from a party to carry out the Compliance Assessment, the FIFA Clearing House will make a first assessment and determination on whether a party passes or fails the Compliance Assessment (First Compliance Assessment). Compliance Assessment e) source of wealth. IV. Football Agent Exam Study Materials – May 2023 edition - 363 26 15.7 Any determination of the FIFA Clearing House in relation to a Compliance Assessment shall be final and binding and shall not be subject to any appeal. 15.8 Any determination of the FIFA Clearing House in relation to the Compliance Assessment related to one transaction is without prejudice to Compliance Assessments carried out for a different transaction. Article 16: Consequences of a Compliance Assessment failure 16.1 Where a party fails the First Compliance Assessment: a) the FIFA Clearing House will notify the Non-Compliant Party of its failure to pass the Compliance Assessment; b) the FIFA Clearing House will not process the transaction, or any payments related thereto; c) the respective Compliance Assessment shall continue and the NonCompliant Party shall remain obliged to pass the Compliance Assessment for the same transaction. The FIFA general secretariat will submit the transaction to the FIFA Clearing House to start this Second Compliance Assessment six (6) months after the date of notification in paragraph 1 a). The relevant Non-Compliant Party may request FIFA to initiate the Second Compliance Assessment earlier than the said six (6) months; d) the Non-Compliant Party shall be subject to disciplinary proceedings in accordance with article 17; and e) if the Non-Compliant Party is the subject of a new Compliance Assessment for a different transaction while already undergoing a Compliance Assessment, both processes will be conducted independently of each other. Only in cases where a player’s new club fails the First Compliance Assessment: f) As a transitory measure, if the First Compliance Assessment is completed by 31 December 2023, the training rewards as set out in the Allocation Statement shall be paid by the Non-Compliant Party directly to the bank account of each training club. The payment(s) shall be made within thirty (30) days of notification by the FIFA Clearing House of the failure to pass the First Compliance Assessment. Evidence of payment must be provided to the FIFA general secretariat. g) If payment(s) as per article 16 paragraph 1 f) have not yet been made at the point in time when a Non Compliant Party passes the Compliance Assessment, the transaction and payments must be processed via the FIFA Clearing House, in accordance with these Regulations. Football Agent Exam Study Materials – May 2023 edition - 364 27 16.2 Where a party fails the Second Compliance Assessment, article 16 paragraph 1 a), b), d) and e) shall apply. Only in cases where a player’s new club fails the Second Compliance Assessment, the Non-Compliant Party shall remain obliged to pass a Compliance Assessment for the same transaction. At the request of the relevant Non Compliant Party or ex officio, the FIFA general secretariat may submit the transaction to the FIFA Clearing House to start this subsequent Compliance Assessment. A Non-Compliant Party shall not be subject to disciplinary proceedings if the compliance failure is due to: a) the Non-Compliant Party being domiciled in a country or territory that is the subject of international sanctions; or b) extraordinary circumstances beyond the Non-Compliant Party’s control brought to the attention of the FIFA Clearing House during the Compliance Assessment(s). Compliance Assessment 16.3 IV. Football Agent Exam Study Materials – May 2023 edition - 365 SANCTIONS AND DISPUTES V. Football Agent Exam Study Materials – May 2023 edition - 366