TAS - CAS 2025-A-11852

CAS 2025/A/11852 FC Olexandriya v. FC Polissya

AWARD

Delivered by the

COURT OF ARBITRATION FOR SPORT

sitting in the following composition:

Sole Arbitrator: Mr. Wouter Lambrecht, Attorney-at-law, Geneva, Switzerland

in the arbitration between

FC Olexandriya, Oleksandriya city, Ukraine Represented by Ms Yuliya Bogdanova, Attorney-at-law, Ukraine

• Appellantagainst

FC Polissya, Zhytomyr, Ukraine Represented by Ms Maryia Zhurava and Mr Mikhail Zaleuski, Attorneys-at-law, FREE SPOrT, Warsaw, Poland

• Respondent -CAS 2025/A/11852 - Page 2

I. THE PARTIES

1. FC Olexandriya, (the " Appellant" or " Olexandriya") is a professional football club with its registered seat in Oleksandriya, Ukraine. It is affiliated to the Ukrainian Association of Football ( the “UAF”) which in turn is affiliated to the Fédération Internationale de Football Association (“ FIFA”). During the 2024/2025 sporting season, the Appellant competed in the Ukrainian Premier League, the top division of Ukrainian football, finishing as runner-up.

2. FC Polissya (the "Respondent" or “Polissya") is a professional football club with its registered seat in Zhytomyr, Ukraine. It is affiliated to the UAF which in turn is affiliated to FIFA. During the 2024/2025 sporting season, the Respondent competed in the Ukrainian Premier League, the top division of Ukrainian football, finishing fifth.

3. The Appellant and the Respondent are together referred to as the " Parties", and individually as a “Party” when referenced separately.

II. FACTS

A. Introduction

Ukrainian Premier League, the top division of Ukrainian football, finishing fifth.

3. The Appellant and the Respondent are together referred to as the " Parties", and individually as a “Party” when referenced separately.

II. FACTS

A. Introduction

4. The summary below contains the principal facts relevant to the present dispute, as established on the basis of the Parties’ written and oral submissions and the documents filed in these proceedings including the materials from the proceedings before the UAF Dispute Resolution Chamber (the “UAF DRC”). This summary is included for the sole purpose of setting out the factual background to the dispute. Additional facts may be referred to, where relevant, in the legal discussion below.

B. Background

5. On 1 June 2021, Olexandriya and the player Emil Ramil Ogli Mustafayev, born on 24

September 2001 (the “ Player”), entered an employment contract valid until 31 May 2023 (the “Contract”). The parties subsequently extended the term of the Contract until 5 June 2023 by means of Addendum No. 4 executed on 30 May 2023.

6. In addition to the Contract and Addendum No. 4, the Parties also executed two further addenda regulating the Player’s remuneration.

7. Under an addendum dated 1 June 2021, the Player’s monthly salary was set at UAH 20,000. Under a further addendum dated 10 June 2022, the Player’s monthly salary was set at UAH 75,000 with effect from 1 July 2021 (NB: The Respondent does not dispute the existence of the contractual documentation but contests its relevance for the dispute hand).

8. On 1 July 2023, the Player was registered with Polissya. Such registration triggered an obligation to pay training compensation under the applicable regulations of the UAF.CAS 2025/A/11852 - Page 3

9. On 26 September 2023, Olexandriya sent a written request to Polissya seeking training

obligation to pay training compensation under the applicable regulations of the UAF.CAS 2025/A/11852 - Page 3

9. On 26 September 2023, Olexandriya sent a written request to Polissya seeking training compensation in the amount of UAH 7,145,870.40, including VAT, and default interest at a rate of 5% per annum accruing from 1 August 2023 until the date of effective payment.

10. The amount claimed by Olexandriya was based on the Player’s remuneration, including bonuses, during the final twelve months of his employment, multiplied by the applicable coefficient (4) under the UAF regulations.

11. On 2 October 2023, Polissya replied to that request. While it disputed Olexandriya’s calculation basis and the amount claimed , Polissya did accept that training compensation was payable and proposed to pay a lower amount.

12. On 19 October 2023, Olexandriya filed a claim before the UAF D ispute Resolution Chamber (“DRC”) seeking payment of training compensation.

13. On 2 November 2023, Polissya paid Olexandriya the amount of UAH 1,343,927.80 as confirmed by a copy of the Information Notice on Fund Transfer No. 1730 dated 2

November 2023 . The Parties agree that such payment was made. They disagree, however, as to its legal effect: Olexandriya considers it to be a partial payment only, whereas Polissya maintains it represented the full amount of training compensation due.

14. By a ruling dated 20 November 2023, the UAF DRC opened proceedings under case No. 362/11/2023 and invited Polissya to submit its position. Polissya subsequently filed a response requesting the dismissal of the claim.

15. During the proceedings before the UAF DRC, Olexandriya reduced its claim to UAH 4,610,965.20, considering the payment already received from Polissya, while

a response requesting the dismissal of the claim.

15. During the proceedings before the UAF DRC, Olexandriya reduced its claim to UAH 4,610,965.20, considering the payment already received from Polissya, while maintaining its request for interest. • On the amount of UAH 5,954,892.00 from 1 August 2023 to 2 November 2023; • On the amount of UAH 4,610,965.20 from 3 November 2023 until the date of actual payment.

16. In 2024 and 2025, the UAF DRC issued various procedural rulings, held hearings, requested additional submissions, admitted supplementary evidence and heard the Parties’ representatives and certain witnesses.

17. Throughout this procedure Olexandriya submitted various documents and materials intended to substantiate the remuneration allegedly paid to the Player during the relevant twelve-month period preceding the expiration of the Contract. Those materials included salary certificates, payment instructions, internal handwritten records, cash payment vouchers, a video, expert handwriting reports and witness evidence.

18. At the same time, Polissya, throughout the procedure challenged the evidentiary value and admissibility of a substantial part of those materials. More precisely, on 3 MarchCAS 2025/A/11852 - Page 4

2025, Polissya specifically argued that pursuant to the UAF Regulations , only documents complying with the requirements applicable to primary accounting documents under Ukrainian law could validly support the calculation of any further training compensation.

19. On 5 March 2025, the UAF DRC issued a reading stating as follows:

“[…]

4. The written explanations submitted by LLC “Football Club Polissya” (Outgoing No. 28 dated 03 March 2025), regarding the admissibility of evidence submitted by LLC “Football Club Olexandriya”, shall be included in the case materials.

5. In order to ensure a comprehensive, complete and objective examination of the case,

28 dated 03 March 2025), regarding the admissibility of evidence submitted by LLC “Football Club Olexandriya”, shall be included in the case materials.

5. In order to ensure a comprehensive, complete and objective examination of the case, LLC “Football Club Olexandriya” shall be granted a time limit until 02 May 2025

(inclusive) to submit to the Chamber its written explanations regarding the written explanations of LLC “Football Club. […]”

20. By ruling dated 26 May 2025, the UAF DRC scheduled the matter for determination on 28 May 2025.

21. On 28 May 2025, the UAF DRC rendered its decision in case No. 362/11/2023 (the “Appealed Decision”) the grounds of which were communicated to the Parties on 25

September 2025.

22. In the operative part of the Appealed Decision, the UAF DRC dismissed Olexandriya’ s claim in its entirety.

23. In substance, the UAF DRC held that although Polissya had acknowledged in principle its obligation to pay training compensation and had already paid UAH 1,343,927.80, Olexandriya had failed to establish its entitlement to any additional amount.

24. More specifically, the UAF DRC considered that, in a dispute concerning the amount of training compensation, the relevant remuneration had to be proven by means of reliable and admissible primary accounting documents complying with the requirements of Ukrainian law. In its view, several items of evidence relied upon by Olexandriya, including handwritten notebook records, video materials and certain cash payment documents, did not satisfy that standard requirement and therefore could not, in light of the disagreement between the Parties, serve as a valid basis for the calculation of training compensation.

25. The UAF DRC accepted that the documentation corresponding to the amount already paid by Polissya was sufficient but found that no further proven remuneration had been established beyond such sum.

in light of the disagreement between the Parties, serve as a valid basis for the calculation of training compensation.

25. The UAF DRC accepted that the documentation corresponding to the amount already paid by Polissya was sufficient but found that no further proven remuneration had been established beyond such sum.

26. Accordingly, the UAF DRC concluded that Olexandriya had not discharged its burden of proof in respect of the additional amount claimed and dismissed the claim in full.CAS 2025/A/11852 - Page 5

III. PROCEEDINGS BEFORE THE COURT OF ARBITRATION FOR SPORT

27. On 16 October 2025, the Appellant filed a Statement of Appeal with the Court of Arbitration for Sport (the “ CAS”) against the UAF and Polissya , challenging the Appealed Decision, this pursuant to Articles R47 and R48 of the Code of Sports-related Arbitration ed. 1 July 2025 (the “CAS Code”). In its Statement of Appeal, the Appellant proposed the case be submitted to a sole arbitrator and proposed to appoint Wouter

Lambrecht.

28. On 21 October 2025, the CAS Court Office acknowledged receipt of the Statement of Appeal and inter alia invited the Respondents to state their position on Appellant’s request and proposal for a sole arbitrator to be appointed.

29. On 27 October 2025, the UAF informed the CAS Court Office that it had acted solely as adjudicating body in the first instance proceedings and requested to be excluded from the arbitration.

30. On the same date, Polissya inter alia agreed to submit the matter to a sole arbitrator and accepted to appoint Wouter Lambrecht as Sole Arbitrator in the case at hand.

31. On 2 November 2025, the Appellant withdrew its appeal insofar as directed against the

UAF.

32. On 4 November 2025, the CAS Court Office took note of such withdrawal and confirmed that the UAF was no longer a party to the proceedings.

31. On 2 November 2025, the Appellant withdrew its appeal insofar as directed against the

UAF.

32. On 4 November 2025, the CAS Court Office took note of such withdrawal and confirmed that the UAF was no longer a party to the proceedings.

33. On 6 November 2025, the Appellant filed its Appeal Brief in accordance with Article R51 of the CAS Code, this within the extended deadline, previously extended.

34. On 27 November 2025, the Respondent filed its Answer within the prescribed time limit, as previously extended.

35. By letter dated 6 January 2026, the CAS Court Office transmitted to the Parties the Acceptance and Statement of Independence completed by Mr Wouter Lambrecht, who, based on the agreement of the Parties, had been nominated as Sole Arbitrator by the President of the CAS Appeals Arbitration Division. In his declaration, Mr Wouter Lambrecht disclosed that he was the General Counsel of the association of European Football Clubs (EFC), formerly known as the European Club Association (ECA), and that both Parties were members of that organisation. The Parties were reminded that, pursuant to Article R34 of the CAS Code, any challenge had to be brought within seven days after the relevant grounds became known.

36. On 16 January 2026, considering no challenges had been filed, the CAS Court Office notified the Parties pursuant to Article R54 of the CAS Code and on behalf of the President of the CAS Appeals Arbitration Division, that the Panel appointed to decide the present appeal had been constituted as follows: Sole Arbitrator: Mr Wouter Lambrecht, Attorney-at-Law in Geneva, Switzerland.CAS 2025/A/11852 - Page 6

37. By letter dated 5 February 2026 and after due consultation with the Parties , the CAS Court Office informed the Parties that the Sole Arbitrator had decided to hold a hearing by videoconference and invited them to state their availability.

38. On 17 February 2026, the CAS Court Office, on behalf of the Sole Arbitrator, and

Court Office informed the Parties that the Sole Arbitrator had decided to hold a hearing by videoconference and invited them to state their availability.

38. On 17 February 2026, the CAS Court Office, on behalf of the Sole Arbitrator, and considering the Parties’ availabilities, confirmed a hearing by videoconference on 4

March 2026.

39. On 19 February 2026, the CAS Court Office issued an Order of Procedure, which was subsequently signed and returned by the Appellant on 23 February 2026 and by the Respondent on 25 February 2026.

40. On 4 March 2026, a hearing was held by videoconference. In addition to the Sole Arbitrator and Ms Pauline Pellaux, CAS Counsel, the following persons attended the

hearing:

For the Appellant:

• Ms Yuliya Bogdanova, counsel
• Ms Yanina Kuchanska, witness
• Ms Yulia Kurienkova, interpreter

For the Respondent:

• Ms Mariya Zhurawa, counsel
• Mr Mikhail Zaleuski, counsel
• Mr Sergey Tsurgan, counsel
• Ms Tetiana Aleynikova, counsel

41. At the outset of the hearing, the Parties confirmed that they had no objection to the constitution of the Panel nor to the way the proceedings had been conducted leading up to the hearing. The Parties were given ample opportunity to present their case, make their arguments, question the witness and answer the questions posed by the Sole Arbitrator. At the conclusion of the hearing, the Parties expressly confirmed that their right to be heard and to be treated equally had been fully respected.

42. On 19 March 2026 , the Respondent, pursuant to Article R44.3 of the CAS Code was invited to file any documents (contract with all its exhibits, pay slips, etc.) establishing the salary of the Player upon joining the Respondent.

43. On 25 March 2026, the Respondent filed the requested documentation , which was

invited to file any documents (contract with all its exhibits, pay slips, etc.) establishing the salary of the Player upon joining the Respondent.

43. On 25 March 2026, the Respondent filed the requested documentation , which was communicated to the Appellant. The Parties were granted the opportunity to submit observations strictly limited to such documentation by 2 April 2026.

44. On 30 March 2026, the Appellant filed some observations.CAS 2025/A/11852 - Page 7

45. By letter dated 7 April 2026, the CAS Court Office noted that no further comments had been received from the Respondent within the prescribed deadline and, on behalf of the Sole Arbitrator, declared the evidentiary proceedings closed.

IV. SUBMISSION OF THE PARTIES

A. The Appellant

46. In its Statement of Appeal and Appeal Brief, the Appellant requested that the Appealed Decision be set aside and that the Respondent be ordered to pay outstanding training compensation in the amount of UAH 4,610,965.20, together with interest and costs.

47. As a preliminary matter, the Appellant submitted that the UAF DRC erred by adopting an excessively formalistic approach to the assessment of evidence. According to the Appellant, the UAF DRC erroneously considered the so-called “primary accounting documents” as the exclusive means of proving payments made to the Player and, in doing so, disregarded other relevant documentary and testimonial evidence.

48. The Appellant argues that such approach was contrary to the applicable UAF Regulations on the Status and Transfer of Players (“UAF RSTP”) and to the evidentiary rules contained in the Regulations of the UAF DRC (“UAF DRC Regulations”), which, according to the Appellant, do not establish any hierarchy of evidence and permit the submission of all evidence capable of establishing the relevant facts, including written statements, certificates, witness testimony, expert opinions, audio -visual material and other relevant documents. In doing so, the UAF DRC, according to the Appellant, also

according to the Appellant, do not establish any hierarchy of evidence and permit the submission of all evidence capable of establishing the relevant facts, including written statements, certificates, witness testimony, expert opinions, audio -visual material and other relevant documents. In doing so, the UAF DRC, according to the Appellant, also applied the wrong standard of proof in that given the financial nature of the dispute, the UAF DRC should have applied the balance of probabilities’ standard and not the one of comfortable satisfaction.

49. On the merits, the Appellant submitted that the Player was registered with the Appellant during the season in which he turned 21 years old and subsequently registered with the Respondent on 1 July 2023, i.e. before the end of the season in which he turned 23.

Therefore, pursuant to the UAF RSTP, the Resp ondent became liable to pay training compensation to the Appellant.

50. The Appellant maintained that, under the relevant UAF RSTP, training compensation is to be calculated on the basis of the total salary and bonuses accrued and/or paid to the player during the final twelve months of his registration with the former club, multiplied by the applicable age coefficient set out in the UAF RSTP . In the present case, the relevant coefficient was four (4).

51. The Appellant contend ed that during the relevant twelve -month period , the Player received a total remuneration of UAH 1,488,723.00, composed , as per the Appellant’s Salary Certificates (“SC”) 1 to 3: SC1: UAH 222,733.28 net (UAH 276,687.29 gross) as salary paid under the employment contract, SC2: UAH 617,700.00 as payments under the additional agreement dated 10 June 2022, and SC3: UAH 648,300.00 as bonuses .CAS 2025/A/11852 - Page 8

[NB: the actual sum of the three amounts mentioned here is slightly higher and equal to

the additional agreement dated 10 June 2022, and SC3: UAH 648,300.00 as bonuses .CAS 2025/A/11852 - Page 8

[NB: the actual sum of the three amounts mentioned here is slightly higher and equal to UAH 1,488,733.28 ]. Applying the coefficient of four (4), the total training compensation allegedly due would amount to UAH 5,954,892.00.

52. The Appellant explain ed that its initial claim also included VAT at a rate of 20%, bringing the total amount originally claimed to UAH 7,145,870.40, but that its claim was subsequently reduced after the Respondent’s partial payment. Namely, t he Appellant acknowledge d that the Respondent made a partial payment of UAH 1,343,927.80 on 2 November 2023 . After deducti ng said partial payment from the principal amount of UAH 5,954,892.00, and no longer requesting VAT, the outstanding balance allegedly due according to the Appellant equalled UAH 4,610,965.20 [NB: if one deducts the partial payment from the principal amount , the difference is UAH

4,610,964.20].

53. In support of the amount claimed, the Appellant relied on several categories of evidence submitted during the national proceedings and again in the present arbitration, including: • the Contract concluded with the Player and subsequent addenda; • a certificate indicating that the Player’s income between June 2022 and May 2023 under the basic contract amounted to UAH 276,687.29 gross (UAH 222,733.28 net payable); • a consolidated certificate setting out monthly remuneration totals and aggregating the sums of UAH 1,488,723.00 for the relevant period; • bank payment instructions relating to amounts transferred to the Player; • extracts from wage ledgers and internal payment records concerning cash payments; • cash disbursement orders relating to bonuses; • handwritten notebooks allegedly recording payments acknowledged by the

Player;

• bank payment instructions relating to amounts transferred to the Player; • extracts from wage ledgers and internal payment records concerning cash payments; • cash disbursement orders relating to bonuses; • handwritten notebooks allegedly recording payments acknowledged by the Player; • video material showing the club’s internal payroll documentation; • private handwriting experts’ analysis reports concluding that the signatures appearing on certain notebooks and cash orders were made by the Player; and • witness evidence from the club cashier.

54. The Appellant emphasised that the certificates submitted were signed by club officials and stamped with the club seal, and that the amounts reflected therein correspond with the underlying payment records and supporting schedules produced in the file.

55. The Appellant further argued that the UAF DRC had no proper basis to reject the claim solely for lack of specific accounting forms, particularly after having admitted and examined the various items of evidence produced during the proceedings , let aloneCAS 2025/A/11852 - Page 9

without first requesting any supplementary documents or clarifications from the Appellant. Consequently, it was contradictory and procedurally unfair for the UAF DRC to dismiss the claim on the basis that such documents had not been submitted.

56. The Appellant also submit ted that the decisive factual issue was whether the Player actually received the relevant sums, not whether each payment was documented in a particular accounting format under Ukrainian law. In the Appellant’s view, the evidence on file demonstrates, far above the applicable standard of proof of balance of probabilities, that the Player received the amounts claimed.

57. The Appellant further submit ted that the handwriting reports corroborate the authenticity of the Player’s signatures on a number of payment acknowledgments, thereby reinforcing the reliability of the documentary record relied upon by the

Appellant.

58. Based on these arguments, the Appellant submitted the following requests for relief: “1. Annul the decision issued by the UAF DRC on 28 May 2025.

2. Order FC “Polissya” to pay to FC “Oleksandriya” a training compensation

Appellant.

58. Based on these arguments, the Appellant submitted the following requests for relief: “1. Annul the decision issued by the UAF DRC on 28 May 2025.

2. Order FC “Polissya” to pay to FC “Oleksandriya” a training compensation regarding the player Emil Ramil Ogli Mustafayev, born on 24.09.2001, in the amount of UAH 4,610,965.20 (four million six hundred ten thousand nine hundred sixty-five hryvnias and 20 kop).

3. Order FC “Polissya” to pay to FC “Oleksandriya” an interest for the late compliance with its financial obligations, to be calculated as follows: - 5% annual interest on the amount of UAH 5,954,892.00 (five million nine hundred fifty-four thousand eight hundred ninety -two hryvnias, 00 kop), accruing from 01.08.2023 until 02.11.2023; - 5% annual interest on the amount of UAH 4,610,965.20 four million six hundred ten thousand nine hundred sixty -five hryvnias and 20 kops.), accruing from 03.11.2023 until the date of effective payment of the debt in full; 4.Order FC “Polissya” to bear all costs of the present proceedings. 5.Order FC “Polissya” to pay to the Appellant a contribution towards its legal and other costs, in an amount to be determined at the Sole Arbitrator’s discretion.

B. The Respondent

59. The Respondent does not dispute, in principle, that its registration of the Player gave rise to an obligation to pay training compensation. It maintains, however, that the only issue in dispute concerns the proper calculation basis of the training compensation payable and the evidence capable of substantiating the Player’s remuneration as invoked by the Appellant.CAS 2025/A/11852 - Page 10

60. According to the Respondent, under the applicable UAF regulatory framework, the

issue in dispute concerns the proper calculation basis of the training compensation payable and the evidence capable of substantiating the Player’s remuneration as invoked by the Appellant.CAS 2025/A/11852 - Page 10

60. According to the Respondent, under the applicable UAF regulatory framework, the amount of training compensation must be determined exclusively on the basis of the remuneration duly proven by primary accounting records and supporting documents compliant with Ukrainian law. It therefore rejects the Appellant’s reliance on documents which, in its view, do not meet the required standard.

61. The Respondent further argues that the Appellant failed to produce any primary accounting documents that evidence the actual disbursement of the alleged payments contained in the notebook and submits that the documentation produced by the Appellant, mainly consists of unilateral internal records and that, even where certain documents could be considered primary accounting documents, such as the cash payment vouchers, they lacked the formal requisites required under Ukrainian accounting legislation , such as the company name, document title, creation date, identification of the responsible official, necessary signatures, and other mandatory requisites.

62. The Respondent further submits that the UAF DRC correctly applied the standard of proof of comfortable satisfaction, which it considers consistent with CAS jurisprudence in regulatory and compensation -related disputes. In any event, the Respondent argues that the Appellant’s evidence would fail even under the lower standard of a balance of probabilities.

63. The Respondent contends that the UAF DRC carried out a complete and objective assessment of the evidence, examining each item individually and in conjunction with the evidentiary record as a whole, with due regard to its relevance, admissibility, reliability and sufficiency. It therefore denies that the UAF DRC adopted any unlawful or excessively formalistic approach.

64. In particular, the Respondent maintain ed that the UAF DRC – by virtue of the lex specialis principle set out in Article 4 of the Annex 1 of the UAF RSTP – was entitled to attach decisive weight to the absence of primary accounting documentation

or excessively formalistic approach.

64. In particular, the Respondent maintain ed that the UAF DRC – by virtue of the lex specialis principle set out in Article 4 of the Annex 1 of the UAF RSTP – was entitled to attach decisive weight to the absence of primary accounting documentation complying with the applicable legal requirements and to disregard documents which could not reliably establish the accrual or payment of the Player’s remuneration. The Respondent further submitted that the UAF DRC was not required to request such primary accounting documents under the relevant provision and that, in any event, the Appellant had already been given the opportunity, by means of the ruling dated 21

August 2024, to submit any documents it wished in support of its claim.

65. As to the contractual basis of the alleged remuneration, the Respondent notes that,

although the original employment contract and Addendum No. 4 were registered with the relevant league authorities, the addenda dated 1 June 2021 and 10 June 2022, which allegedly increased the Player’s remuneration, were never registered. According to the Respondent, this circumstance undermines the reliability and enforceability of the salary increases relied upon by the Appellant.

66. The Respondent particularly emphasise d that the addendum dated 10 June 2022 purportedly increased the Player’s monthly remuneration to UAH 75,000 withCAS 2025/A/11852 - Page 11

retroactive effect from 1 July 2021, i.e. approximately one year before its execution. In its submission, such retroactive amendment further weakens the credibility of the remuneration structure advanced by the Appellant. The Respondent additionally argues that the timing and structure of that addendum cast doubt on whether the alleged remuneration was genuinely agreed and implemented during the relevant contractual period.

67. The Respondent disputed the evidentiary value of many of the documents produced by the Appellant, including handwritten “grid notebooks”, internal summaries, extracts from wage ledgers, and similar unilateral internal records. According to the Respondent,

remuneration was genuinely agreed and implemented during the relevant contractual period.

67. The Respondent disputed the evidentiary value of many of the documents produced by the Appellant, including handwritten “grid notebooks”, internal summaries, extracts from wage ledgers, and similar unilateral internal records. According to the Respondent, those materials are not primary accounting documents and do not reliably establish either accrued remuneration or actual payment to the Player.

68. With regard to the video material filed by the Appellant, the Respondent submitted that it merely demonstrate d the existence of notebooks or records but did not prove the accuracy of their contents or the actual disbursement of any sums to the Player.

69. The Respondent further argue d that several banking documents produced by the Appellant did not demonstrate with certainty that the alleged transfers were made by or on behalf of the Appellant, nor that they were connected specifically to the Player’s remuneration. In its view, such documents are incomplete, ambiguous or insufficiently linked to the amounts claimed.

70. As to the cash vouchers relied upon by the Appellant, the Respondent submit ted that, even if some of them formally resemble accounting documents, they contained material deficiencies, including missing signatures and missing mandatory requisites. It also relied on the te