The case involves USD Lavagnese, an amateur Italian football club, appealing a decision by FIFA regarding breaches of FIFA’s Regulations on the Status and Transfer of Players (RSTP), specifically Article 19, which governs the international transfer of minor players. The dispute arose from Lavagnese’s registration of underage Nigerian players, allegedly linked to the "Nigeria System," a scheme uncovered by Italian authorities involving the illegal recruitment and exploitation of young players. The scheme, initially tied to professional club Spezia Calcio, facilitated the entry of minors into Italy under false pretenses, such as sporting event invitations, violating immigration laws. Once in Italy, the minors were managed by Spezia Calcio and later "parked" at amateur clubs like Lavagnese to avoid scrutiny.
FIFA’s investigation found Lavagnese guilty of violating Article 19, which prohibits the international transfer of players under 18 unless specific exceptions apply, such as the player moving with their parents for non-football reasons. Lavagnese had registered the minors under the claim that they were accompanied by guardians, but the Court of Arbitration for Sport (CAS) panel determined the move was football-related, breaching Article 19(1) and (4). The club argued it followed Italian Football Federation (FIGC) procedures and Italian law, which allowed guardianship as equivalent to parental relocation. However, CAS dismissed this, stating FIFA regulations take precedence over national laws and that ignorance of the rules was no excuse.
Lavagnese also contested the sanctions—a two-registration-period transfer ban and a CHF 4,000 fine—arguing they were disproportionate for an amateur club with no financial gain or malicious intent. The club highlighted its reliance on FIGC guidance and the lack of evidence tying it directly to the Nigeria System. FIFA maintained the sanctions were necessary to deter violations and protect minors, emphasizing that Article 19 applies universally, regardless of a club’s amateur status.
CAS upheld FIFA’s decision but reduced the registration ban to one period, acknowledging the club’s amateur context and the absence of systemic exploitation. The panel emphasized the importance of protecting minors in football transfers while ensuring sanctions are proportionate. The ruling reinforced that clubs must independently verify compliance with FIFA regulations, even if national associations provide conflicting guidance. The case underscores the tension between enforcing global football regulations and considering the operational realities of amateur clubs, balancing deterrence with fairness.
Ultimately, the decision highlighted FIFA’s commitment to safeguarding minors in football, stressing that clubs bear responsibility for adhering to transfer rules, irrespective of their size or intent. The adjusted sanctions reflected Lavagnese’s specific circumstances while upholding the broader principle of minor protection in international football.