Fédération Royale Marocaine de Football v. FIFA

I. THE PARTIES

1. The Fédération Royale Marocaine de Football (the “Appellant” or “FRMF”) is the national association governing football in Morocco, with its headquarters in Rabat, Morocco, and is a member of the Fédération Internationale de Football Association.

2. The Fédération Internationale de Football Association (the “Respondent” or “FIFA”) is the worldwide governing body of international football and exercises regulatory, supervisory and disciplinary functions over continental confederations, national associations, clubs, officials and players. FIFA is an association under Swiss law with its registered office in Zurich, Switzerland, and is the governing body for international football.

3. In this appeal proceedings (the “Appeal”), the FRMF and FIFA are collectively referred to as the “Parties”.

V. The penalty imposed by FIFA on the Royal Moroccan Football in the disciplinary

procedures FDD-19662 (FDD-19087 before the FIFA Disciplinary Committee) and (…) [is] substantially reduced to a warning or reprimand.

In any event

VI. FIFA shall bear all the arbitration costs, if any, and shall be ordered to reimburse

the minimum CAS Court Office fee of CHF 1,000 in each of the CAS proceedings as well as any other advances of costs paid by FRMF.

VII. FIFA shall be ordered to pay FRMF a contribution towards the legal and other

costs incurred in the framework of these proceedings.”

41. The FRMF puts forth the following arguments in support of its position, which are summarized hereunder:

A.1 FIFA has no legal basis to sanction member associations for incidents occurred at Olympic matches

42. The FRMF submits that the Appealed Decision must be annulled for lack of any legal basis by FIFA. Under the principle of legality, consistently upheld by the CAS, disciplinary sanctions must have a clear and specific legal basis. They cannot result from an arbitrary extension of a regulatory framework to contexts not foreseen by the

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43. The incidents occurred during the OFT, held as part of the Paris Olympics. The Matches were organized by the IOC and the Paris 2024 Organizing Committee (the “Organizing Committee”) and so, they are governed by the Olympic Charter (the “Olympic Charter”).

44. Article 59 (2) of the Olympic Charter provides for specific disciplinary measures applicable in cases of misconduct during the Olympic Games, but the measures only apply to individual athletes, teams, officials and accredited persons. The Olympic Charter contains no provision for disciplinary sanctions against national football associations, particularly not on the basis of strict liability for the behavior of its supporters.

45. While Article 59 (4) of the Olympic Charter permits international federations (the “IFs”) to impose sanctions under their own regulations, this assumes that such rules are applicable within the context of the Olympic Games.

46. In this regard, the regulations for the OFT, as agreed between the IOC, the Organizing Committee and FIFA, expressly states that FIFA is responsible for enacting and applying its own specific disciplinary rules for the purposes of the Olympic Games.

47. FIFA has not adopted any specific regulations tailored to the Olympic Games context. It has not issued a distinct and specific disciplinary framework, adapted to the particular circumstances and distinctive nature of the Olympic Games.

48. FIFA has merely inserted a general reference to Article 8 of the FDC within the Olympic Football Tournaments – Games of the XXXIII Olympiad Paris 2024 Regulations – Final Competition (the “OFT Regulations”), stating that it shall apply as is, to the Olympic Games. With this general reference, FIFA now seeks to impose sanctions on the FRMF under Article 17 of the FDC.

A.1.1 The concept of strict liability under Article 17 of the FDC:

49. Strict liability has been recognized by CAS as a lawful doctrine under Swiss law, both within the UEFA and FIFA disciplinary frameworks. It acts as a legitimate and necessary tool in the effort to combat violence and disorder in football stadiums and to ensure that supporters’ unlawful conduct do not go unnoticed (CAS 2012/A/2802).

50. Since individual supporters are not subject to FIFA’s direct disciplinary jurisdiction, the only mechanism available to FIFA to address their misconduct is through indirect attribution of responsibility by holding their national federations accountable.

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51. Article 17 (2) of the FDC does enshrine the principle of strict liability, holding federations accountable for misconduct by their supporters, even in absence of any fault or any negligence in relation to the organization of the match.

52. This framework ensures that there is always a responsible entity, namely, the organizing or participating federation, who is incentivized to take meaningful preventive measures and, where those measures fail, bears the consequences. This system is fundamentally rooted in deterrence and prevention, operating on the premise that federations possess both the institutional capacity and operational tools to influence and manage their supporter base.

53. For that reason, it must be applied restrictively, and only where its underlying rationale, namely deterrence through accountability, is clearly fulfilled. For the doctrine to be applied legitimately, two essential conditions must be met:

• The federation must play a direct and active role in organizing or participating in the match; and

• There must be a genuine link between the federation and the individuals involved. In other words, the individuals must be supporters in the disciplinary sense, forming part of a recognizable group over which the federation has at least some degree of influence.

54. Without these conditions, the very foundation of strict liability collapses, and its application becomes punitive rather than preventive. It should be noted that the rule is premised on the assumption that the association concerned is either the host or a directly participating body, with clear responsibilities before, during and after the match.

55. Indeed, Article 17 (1) of the FDC explicitly ties liability to operational duties, such as collaborating with local authorities, implementing safety precautions and ensuring the security of the players, officials and the venue itself. These responsibilities presuppose a meaningful role in the organization and execution of the match, and cannot be dissociated from the federation’s ability to influence the event.

56. Article 17 (2) of the FDC also presupposes a concrete link between the federation and the individuals concerned, along with a capacity to influence their conduct. It specifically refers to the liability even in case of “absence of negligence in the organization of the match”, implying its participation in the organization as the invited association.

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57. Therefore, Article 17 of the FDC does not, and cannot, extend to passive, non-involved entities that play no role in organizing the event, have no contact with attendees, and exercised no control over ticketing, security, or logistics, whether as host or participation in the Matches. In practice, national football federations are not even considered stakeholders in Olympic competitions.

A.1.2 The FRMF cannot be held liable for the incidents that occurred during the Matches:

58. As confirmed by the Olympic Charter, participation quotas are allocated to National Olympic Committees (the “NOC’s”), not to national football federations. The Olympic Charter explicitly state that it is the NOC’s who are responsible for entering teams into Olympic competitions.

59. In the Matches, the team representing Morocco was not entered by the FRMF, but by the Moroccan NOC.

60. Under the conditions of Article 17 (2) of the FDC, namely the genuine link between the federation and the individuals involved, the provision clearly uses the word “their” supporters. Yet, despite this, FIFA seeks to hold the FRMF strictly liable for the alleged spectators’ misconduct occurring in an event the FRMF did not organize, did not participate in as a football federation, over which it exercised no control and for a crowd of spectators it is not connected to.

61. The FRMF points out that there are fundamental differences between a FIFA-regulated football competition and the Olympic Games. During FIFA-regulated competitions, the participating federation is deeply involved in every aspect of the event from managing ticket distribution, coordinating supporter travel to collaborating with local law enforcement.

62. The Paris Olympics, by contrast, operated differently; matches were organized by the Organizing Committee, ticketing, security, crowd management were all managed through the Olympic systems and host authorities. The organization and security of the OFT fell exclusively within the remit of the IOC and the Organizing Committee, with no involvement from FIFA or the national football associations.

63. The FRMF were not assigned fan sections, did not liaise with police or stadium staff and had no capacity to instruct, warn or remove individuals. It had no institutional, structural or practical relationship with the Paris Olympics or with those attending it. The FRMF

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had no access to ticketing data, no information about the identities of the spectators and none of the typical means of engagement.

64. Article 17 of the FDC was never intended to regulate anonymous Olympic crowds. Unlike dedicated support groups typically seen at FIFA events, Olympic spectators are a mixed and unregulated crowd. Some may cheer for a country or wear its colors, but these symbolic acts do not amount to a formal affiliation in the disciplinary sense.

65. To apply the referred provision in this context is to distort its purpose and is to abandon the principle of legality. It turns a rule of deterrence into an instrument of arbitrary blame, punishing a federation for conduct it could neither influence nor prevent. Such an approach departs from both the wording and the spirit of the provision and risks reducing strict liability to a tool of nationality-based attribution.

66. In every relevant case where strict liability was upheld, there was a clear and verifiable link between the federation and the supports in question, namely through ticketing, formal participation, supporter group coordination or direct match involvement as an opposing federation participating in the match. The rationale was always tied to actual influence and foreseeable responsibility.

67. None of those elements exist here, according to FRMF. The misconduct occurred at an event that the FRMF did not organize, involving spectators it did not know, control or engage with, in a stadium managed by a third-party Olympic authority.

68. If FIFA’s interpretation was to be accepted, it would allow federations to be sanctioned for virtually any incident loosely connected to their national identity, regardless of whether they were involved or had any relationship with the individuals concerned.

69. The principle of strict liability presumes accountability, but accountability requires some degree of control. Without it, liability becomes punitive for its own sake. If the principle of strict liability were to be meaningfully applied in the Olympic context, it would need to rest with the entities that actually exercise control over the event, namely the IOC , the NOC and the Organizing Committee. Holding them accountable would be the only way to preserve the logic and legitimacy of the principle of strict liability in this setting.

70. Based on the foregoing, it should be concluded that Article 17 of the FDC is not applicable in the framework of the Olympic Games and in particular to the Paris Olympics, given the complete absence of any direct or indirect involvement of the FRMF.

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71. Therefore, the Appealed Decision must be annulled.

A.2 Subsidiarily, no sanction should be imposed on the FRMF

72. Subsidiarily, even if Article 17 of the FDC and the principle of strict liability were deemed applicable, no sanction should be imposed on the FRMF.

73. CAS jurisprudence confirms that strict liability does not entail automatic sanctions (CAS 2014/A/3578 and CAS 2013/A/3090), distinguishing between “recognition of responsibility” and the “imposition of a disciplinary sanction”, with discretion expressly embedded in Article 17 of the FDC.

74. Unlike in previous CAS cases, the FRMF had no role in organizing or participating in the OFT, nor any authority over logistics, ticketing, or security, such that sanctions would serve no preventing or deterrent purpose.

75. Moreover, the alleged link between the FRMF and the supporters involved was not proven, since FIFA relied only on indirect indicators (e.g., shirt colors, chants, seating), which fall short of the required standard of proof.

76. In both cases (see para. 73 above), the federations were either hosts or participating in the matches and thus had a degree of operational control. Even then, CAS accepted that no sanction was warranted based on the specific facts.

77. That distinction is enshrined in the very structure of Article 17 of the FDC which, by using discretionary language such as “may be fined”, grants the FIFA DC the authority to refrain from imposing sanctions altogether where the circumstances so warrant.

78. Even the FIFA DC acknowledged the difficulty of establishing any connection between the supporters and Morocco.

79. In light of these specific circumstances, no sanction should be imposed on the FRMF.

A.2.1 The sanction imposed is manifestly disproportionate:

80. In the alternative, if any sanction under Article 17 of the FDC is deemed warranted, it should be substantially reduced for reasons of proportionality.

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81. CAS jurisprudence requires sanctions to reflect the nature, severity and context of the offence, and to promote “prevention” and “deterrence” rather than undermine them

82. FIFA imposed two separate sets of sanctions arising from the same tournament context, resulting in cumulative penalties of CHF 144,500, which are manifestly disproportionate.

83. The burden of proof was applied inadequately given the diverse and unaffiliated composition of Olympic crowds, making attribution unreliable.

84. The FRMF had no role in organizing the Matches, no control over the venue, security, ticketing, or logistics, and no ability to influence spectators at the Olympic Games.

85. Therefore, the sanction serves no preventive purpose, and any penalty, if imposed, should be limited to a symbolic warning or reprimand.

B. FIFA’s Submissions

86. In its Answer, FIFA submitted the following prayers and requests for relief:

“(…)

(a) Rejecting the reliefs sought by the Appellant;

(b) Confirming the Appealed Decision;

(c) In any event, dismissing the appeal in full; and

(d) Ordering the Appellant to bear the full costs of these arbitration proceedings. ”

87. FIFA puts forth the following arguments in support of its position:

B.1 The alleged inapplicability of Article 17 of the FDC

88. The FRMF alleges that Article 17 of the FDC is not applicable to the present matter and that there is no legal basis for sanctioning the FRMF. This position is not only legally flawed but is also clearly inconsistent with the stance it adopted during the FIFA Appealed Decision proceedings.

B.1.1 General applicability of the FDC to incidents occurred at the OFT:

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89. The FDC applies to all FIFA competitions (Article 2 (1) of the FDC).

90. The OFT are expressly defined as FIFA events under the FIFA Statutes (Article 1 (1) of the OFT Regulations) and organized by the Organizing Committee appointed by the FIFA Council (Article 3 (1) of the OFT Regulations).

91. The OFT Regulations confirm that the FIFA Statutes and all FIFA regulations apply in full (Article 1 (6) of the OFT Regulations) and explicitly state that disciplinary matters fall under the FDC and the jurisdiction of the FIFA DC (Article 8 (1) and (4) of the OFT Regulations). These regulations were approved by the FIFA Council in its 26th meeting, held on 17 December 2023 in Jeddah, Saudi Arabia.

92. Accordingly, the FRMF’s claim that FIFA failed to adopt competition-specific disciplinary rules is unfounded. The FDC is of general applicability and governs all FIFA competitions, including the OFT. There is no requirement for a separate code per tournament.

93. This framework is consistent with the Olympic Charter, which affirms the authority of the IFs to establish and apply rules for their sport at the Olympic Games (Rule 46 (1) of the Olympic Charter) and to impose sanctions without prejudice to the rights of the IOC and other bodies (Rule 59 (1) of the Olympic Charter).

94. In sum, both the OFT Regulations and the Olympic Charter recognize FIFA’s autonomy to regulate and enforce disciplinary matters at the OFT.

B.1.2 Specific applicability of Article 8 and Article 17 (2) of the FDC:

95. Article 8 of the FDC establishes strict liability: infringements are punishable regardless of intent, and associations and clubs are responsible for the conduct of players, officials, supporters, and others acting on their behalf – even in the absence of fault or negligence. Article 17 (2) of the FDC reinforces this principle by holding all associations, not just hosts, liable for the inappropriate behaviour of their supporters.

96. The CAS jurisprudence consistently upholds this strict liability regime, confirming that associations remain responsible for supporter conduct even at away matches or tournaments they did not organize (CAS 2009/A/1944 and CAS 2014/A/3944). The rationale, as emphasized in CAS 2013/A/3094, is not to sanction fault but to deter misconduct by placing responsibility on the team’s association.

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97. Against this backdrop, the FRMF claims that the individuals were “not its supporters”, because the Olympic team was not directly affiliated with it is untenable. Not only does this contradict the clear wording of the FDC, but during the FIFA Appeal Committee proceedings the FRMF acknowledged the misconduct, accepted responsibility, and apologized for “mistakes made by some of its attributed fans”. The FRMF also expressly recognized that Article 17 (2) of the FDC applied, disputing only the severity of the sanction.

98. FIFA’s strict liability framework applies unequivocally, and the FRMF’s attempt to disclaim responsibility is inconsistent with both the FDC and its own prior admissions.

B.1.3 The link between the representative team of Morocco in the OFT and the FRMF:

99. The operational link between the FRMF and Morocco’s representative team at the OFT is beyond dispute.

100. The qualification pathway for the OFT is regulated in Section D of the “Qualification System – Games of the XXXIII Olympiad – Paris 2024 – Football” (the “OFT Qualification System”), which assigns to the confederations, the organization of qualifying tournaments subject to FIFA’s approval. In Africa, the Confédération Africaine de Football (the “CAF”) designated the 2023 U-23 Africa Cup of Nations as its qualifier, where Morocco’s U-23 national team – affiliated with the FRMF – secured its place at the OFT.

101. The FRMF itself publicly acknowledged this affiliation by consistently referring to the U-23 squad as “our team” in official communications and social media, prominently featuring its logo alongside Olympic branding. Thus, Morocco’s representative team was formally and substantively under FRMF’s responsibility.

102. The CAS jurisprudence confirms that the notion of “supporters” is an open concept, to be assessed from the standpoint of a reasonable and objective observer, taking into factors such as clothing, stadium location, and the use of team symbols (CAS 2015/A/3874). In the present case, the individuals involved were wearing Moroccan jerseys, positioned in sections designated for Moroccan fans, and using red and green flares timed to Moroccan goals and the national anthem, as documented in the Match Reports.

103. While FRMF did not deny the incidents, it argued that FIFA had not proven a concrete link between the individuals and the FRMF. This position fails for two reasons: (i) under

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Article 40 of the FDC, match reports are presumed accurate, and the burden of proof lies with the association to rebut them; and (ii) despite being granted access to video and photographic evidence, FRMF submitted no rebuttal.

104. Accordingly, the incidents were clearly committed by Moroccan supporters and under Articles 8 and 17 (2) of the FDC, by application of the principle of strict liability, the FRMF is responsible.

B.2 As to the sanction imposed

105. FIFA rejects FRMF’s argument that the fine imposed is disproportionate or should be symbolic due to its lack of organizational control over the OFT. Under Article 6 (1) of the FDC, a wide range of sanctions may be imposed on associations, with the nature and degree of misconduct guiding the choice.

106. In this case, the FRMF was sanctioned with a fine of CHF 44,500 calculated in line with Annex 1 of the FDC, which provides indicative amounts for first-time offenses. No mitigating factors were established by the FRMF, as required under Article 25 of the FDC.

107. The CAS jurisprudence confirms that association’s internal judicial bodies enjoy wide discretion in determining sanctions, and CAS panels should intervene only where a sanction is unlawful, arbitrary, discriminatory, or clearly disproportionate (CAS OG

108. A mere warning or a reprimand, as sought by the FRMF, would not serve the necessary deterrent effect, especially given the principle of strict liability under Article 17 (2) of the FDC, where absence of fault is irrelevant.

109. Accordingly, the fine imposed was fair, proportionate, and well within FIFA’s disciplinary discretion. The Appealed Decision cannot be considered arbitrary or excessive.

V. JURISDICTION

110. In accordance with Article 186 of the Swiss Private International Law Act (the “PILA”), the CAS has the power to decide upon its own jurisdiction.

111. Article R47 of the CAS Code states that:

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“An appeal against the decision of a federation, association or sports-related body may be filed with CAS if the statutes or regulations of the said body so provide or if the parties have concluded a specific arbitration agreement and if the Appellant has exhausted the legal remedies available to it prior to the appeal, in accordance with the statutes or regulations of that body.”

112. Pursuant to Article 49 (1) of the FIFA Statutes (2024 Edition):

“FIFA recognizes the independent Court of Arbitration for Sport (CAS) with headquarters in Lausanne (Switzerland) to resolve disputes between FIFA, members associations, confederations, leagues, clubs, players, officials, football agents and match agents.”

113. Pursuant to Article 52 of the FDC (edition 2023):

“Decisions passed by the Disciplinary and Appeal Committees may be appealed against before CAS, subject to the provisions of this Code and articles 56 and 57 of the FIFA Statutes.”

114. The FRMF also relies on Article 50 (1) of the FIFA Statutes (2024 Edition) as the provision conferring jurisdiction on the CAS to hear this dispute, since it states that “[a]ppeals against final decisions passed by FIFA and its bodies shall be lodged with CAS within 21 days of receipt of the decision in question.” FIFA, in turn, did not contest the jurisdiction of CAS to hear this dispute.

115. The Order of Procedure has been duly signed by the Parties, confirming the jurisdiction of the CAS.

116. Therefore, it expressly follows that the CAS has jurisdiction to hear this dispute.

VI. ADMISSIBILITY

117. Article R49 of the CAS Code provides as follows:

“In the absence of a time limit set in the statutes or regulations of the federation, association or sports-related body concerned, or of a previous agreement, the time limit for appeal shall be twenty-one days from the receipt of the decision appealed against. After having consulted the parties, the Division President may refuse to entertain an appeal if it is manifestly late.”

118. Pursuant to Article 50 (1) of the FIFA Statutes:

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“Appeals against final decisions passed by the FIFA’s legal bodies and against decisions passed by confederations, member associations or leagues shall be lodged with CAS within 21 days of receipt of the decision in question.”

119. The Appealed Decision was notified to the FRMF on 26 February 2025, and the Statement of Appeal was filed on 19 March 2025, i.e. within the 21-day deadline. Furthermore, FIFA have not contested the admissibility of the Appeal.

120. In view of the above, the Appeal is admissible.

VII. APPLICABLE LAW

121. Pursuant to Article R58 of the CAS Code, in an appeal arbitration procedure before the CAS:

“The Panel shall decide the dispute according to the applicable regulations and, subsidiarily, to the rules of law chosen by the parties or, in absence of such choice, according to the law of the country in which the federation, association or sports-related body which has issued the challenged decision is domiciled or according to the rules of law that the Panel deems appropriate. In the latter case, the Panel shall give reasons for its decision.”

122. Article 49 (2) of the FIFA Statutes provides as follows:

“The provisions of the CAS Code of Sports related Arbitration shall apply to the proceedings. CAS shall primarily apply the various regulations of FIFA and, additionally, Swiss law.”

123. The Parties do not dispute the applicability of FIFA regulations as the “applicable regulations” within the meaning of Article R58 of the CAS Code, with Swiss law being applied on a subsidiary basis, in the event that it is necessary to fill any gap or omission in the FIFA regulations. The Panel further notes that, since the present case concerns a tournament held within the framework of the Paris Olympics, the applicable regulations under Article R58 of the CAS Code include both the OFT Regulations and the Olympic Charter.

VIII. MERITS OF THE APPEAL — A. PRELIMINARY ISSUES

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A.1 The Extent of the Powers of the CAS

124. Pursuant to Article R57 (1) of the CAS Code, the Panel has the “full power to review the facts and the law”. As repeatedly stated under CAS jurisprudence, with reference to this provision, the CAS appeals arbitration procedure entails a de novo review of the merits of the case and is not confined merely to deciding whether the decision appealed was correct or not. Accordingly, it is the function of the Panel to make an independent determination as to the merits.

A.2 The Applicable Burden and Standard of Proof

125. The Panel notes that the burden of proof lies with the party that relies on a particular fact. This principle is expressly contained under Article 13 of the Procedural Rules Governing the Football Tribunal and is likewise reflected in Article 8 of the Swiss Civil Code (the “SCC”). As to the standard of proof, the Panel applies the test of comfortable satisfaction, which is less demanding than proof beyond a reasonable doubt but higher than a mere balance of probability.

B. THE SCOPE OF THE APPEAL

126. The Panel holds that the scope of the Appeal is limited to a review of the FRMF’s liability, and the sanction imposed in the Appealed Decision (see paras. 18-19 above), namely the fine of CHF 44,500 for the misconduct of certain individuals during the OFT Matches of the Paris Olympics.

127. As previously noted, the Panel has full authority to review the Appealed Decision de novo. However, this review is strictly limited to the issues adjudicated therein. Accordingly, the Panel is not called upon to examine broader matters relating to tournament organization or Olympic governance. Its task is confined to determining whether the sanction imposed on the FRMF was legally justified and proportionate in light of the circumstances. The Panel further notes that the facts recorded in the Match Reports are not in dispute.

C. ISSUES TO BE DETERMINED

128. The Panel must examine and determine the following issues:

(1) The First Issue:

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To determine whether FIFA had a valid legal basis to apply the FDC to the OFT, and thus disciplinary jurisdiction over the FRMF.

The FRMF maintains that, as the OFT falls under the IOC’s authority, FIFA lacked competence to sanction incidents arising from its tournaments. FIFA, however, argues that the OFT Regulations expressly incorporate the FIFA Statutes and the FDC, thereby affirming its jurisdiction. The Panel must therefore examine the regulatory framework to determine whether FIFA was legally entitled to impose sanctions on the FRMF.

(2) The Second Issue:

To determine whether the individuals responsible for the misconduct during the Matches can be regarded as supporters of Morocco’s team under Article 17 (2) of the FDC.

The FRMF argues that, given the global nature of the Olympic Games and its lack of control over ticketing and security, the disruptive behavior cannot be specifically attributed to Moroccan supporters. FIFA, relying on the Match Reports, points to individuals wearing Moroccan colors, chanting during the anthem, and igniting fireworks during Moroccan celebrations as evidence of such affiliation. The Panel must therefore determine, in light of the evidence and CAS jurisprudence, whether the misconduct is attributable to the FRMF through its supporters.

(3) The Third Issue:

To determine whether FRMF can be held strictly liable under Article 17 (2) of the FDC.

The FRMF maintains that it should not be sanctioned, as it had no organizational authority or practical ability to prevent incidents at the Matches. FIFA, by contrast, invokes the principle of strict liability, which holds associations responsible for the conduct of their supporters regardless of fault or negligence. The Panel must therefore determine whether FRMF’s lack of control exempts it from liability, or whether strict liability applies regardless of such circumstances.

(4) The Fourth Issue:

To determine whether the sanction imposed is proportionate.

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The FRMF argues that the fine of CHF 44,500 is excessive, given its lack of control over the event and the cumulative effect of multiple disciplinary proceedings. FIFA, by contrast, submits that the sanction is proportionate, noting it was already reduced from the amount initially proposed and is consistent with precedents. The Panel must therefore assess whether the fine appropriately reflects the seriousness and recurrence of the incidents, in line with the principle of proportionality and CAS jurisprudence.

C.1 Does FIFA have legal and disciplinary authority over the OFT?

129. The Panel starts by highlighting that the OFT is a competition organized within the sporting context of the Paris Olympics. This was not contested by any of the Parties.

130. With this in mind, it is relevant to also consider what is established in the Olympic Charter, since, inter alia, it “(…) governs the organization, action and operation of the Olympic Movement and sets forth the conditions for the celebration of the Olympic Games” (Introduction, Olympic Charter).

131. According to Rule 46 (1) of the Olympic Charter:

“Each IF is responsible for the control and direction of its sport at the Olympic Games. All elements of the competitions, including the schedule, field of play, training sites and all equipment must comply with its rules. For all such arrangements, the OCOG must consult the relevant IFs.”.

132. Based on the foregoing, the Panel considers that, notwithstanding the IOC’s overarching role in organizing and coordinating the Paris Olympics, it is the responsibility of each IF to control and direct the conduct of its respective sport. This responsibility encompasses the power to establish and enforce the rules, regulations and technical requirements governing all elements of the competition and to ensure that the integrity and proper organization of the events are preserved.

133. Within this framework, the Panel notes that FIFA, as the IF entrusted with the worldwide governance of football, assumed responsibility for regulating the OFT. In discharge of this mandate, the FIFA Council approved the OFT Regulations at its 26th meeting, held on 17 December 2023 in Jeddah, Saudi Arabia, which are intended to apply in full to both to the final stages of the OFT.

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134. In fact, Article 1 (1) of the OFT Regulations expressly recognizes the OFT as official FIFA events under the FIFA Statutes:

“The Olympic Football Tournaments Paris 2024 (…) are FIFA events embodied in the FIFA Statutes.”

135. Article 1 (6) of the OFT Regulations follows this understanding, since it expressly determines that FIFA regulations are applicable in the context of the OFT:

“The FIFA Statutes and all FIFA regulations in force shall apply. Any reference in these Regulations to the FIFA Statutes and regulations refers to the FIFA Statutes and regulations valid at the time of application.”

136. Article 3 (1) of the OFT Regulations further confirms that the OFT is organized under the authority of FIFA, through its Organizing Committee appointed by the FIFA Council, in accordance with the FIFA Statutes and Governance Regulations:

“The Organizing Committee for FIFA Competitions (hereinafter the FIFA Organizing Committee), appointed by the FIFA Council, is responsible for organizing the Tournaments in accordance with the FIFA Statutes and the FIFA Governance Regulations.”

137. Additionally, the OFT Regulations expressly link disciplinary matters to the FDC. Articles 8 (1) of the OFT Regulations provides:

“Disciplinary infringements are dealt with in compliance with the FIFA Disciplinary Code in force as well as with all relevant circulars and directives, with which the Participating Member Associations and Delegation Members undertake to comply”.

(Emphasis added by the Panel)

138. Likewise, Article 8 (4) of the OFT Regulations states:

“Any violations of these Regulations or any other FIFA regulations, circulars, guidelines, directives and/or decisions that do not come under the jurisdiction of another FIFA body shall be dealt with by the FIFA Disciplinary Committee in accordance with the FIFA Disciplinary Code”.

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(Emphasis added by the Panel)

139. Understanding all the above-mentioned provisions together, the Panel finds that (i) the OFT is organized by FIFA (even if under the authority and coordination of the IOC in the context of the Olympic Games) and that (ii) as the responsible IF, FIFA has complied with its duty to regulate and direct the OFT, namely by issuing the OFT Regulations, which expressly determine the applicability of FIFA’s regulatory and organizational framework, as well as provide that disciplinary matters are to be decided under the FDC and by the FIFA DC.

140. Moreover, even in the absence of the OFT Regulation’s reference to FIFA disciplinary framework, the Panel considers that, since FIFA is “responsible for the control and direction of its sport at the Olympic Games”, the FDC is applicable, as per the default rule set by Article 2(1):

“This code applies to every match and competition organized by FIFA and to matches and competitions in association football that do not fall under the jurisdiction of the confederations and/or the associations, unless otherwise stipulated in this Code”.

(Emphasis added by the Panel)

141. It is true that it is usual for competitors to sign an “entry form” whereby they also confirm acceptance of the applicable regulations. This is also the case with the OFT, as per Article 6 (4) of the OFT Regulations:

“All Participating Member Associations shall confirm their participation in the final competition by submitting the entry form and any other required documentation as communicated by FIFA (…)”.

142. In the present case, the Panel notes that the case file does not contain evidence that the FRMF expressly undertook to comply with the OFT Regulations, i.e., the entry form that it presumably signed, was not provided.

143. However, the Panel considers this to be immaterial.

144. Firstly, the Panel notes that, in any event, FIFA’s disciplinary authority does not rest solely on the undertaking clause of Article 8 (1) of the OFT Regulations but derives

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directly from the Olympic Charter’s Rule 46 (1) read together with Articles 1 (1) and 3 (1) of the OFT Regulations, which place the OFT under FIFA’s authority. This conclusion is further supported by Article 2 (1) of the FDC, which establishes its wide scope of application.

145. Secondly, it is explicit from the OFT Regulations that, by entering its qualified national team in the OFT, the FRMF necessarily participated as a “Participating Member Association” in the sense of the OFT Regulations and thereby accepted the applicable framework, at least by tacit adhesion. In fact, the Panel notes that the OFT Regulations are not dubious in this matter, establishing the following:

Article 6 (1) OFT Regulations:

“The member associations that qualify for the Tournaments (the “Participating Member Associations”) agree, in collaboration with the respective NOC, to comply with and ensure that every player, coach, manager, official, media officer, representative, guest and any other person carrying out duties throughout the final competition, and for the entire stay in the host countries, on behalf of a Participating Member Association (hereinafter “Delegation Member”) complies with these Regulations, the Laws of the Game, the FIFA Statutes and FIFA’s other regulations, in particular the FIFA Disciplinary Code, the FIFA Anti-Doping Regulations, the FIFA Code of Ethics and the FIFA Equipment Regulations, as well as with any other FIFA circular letters, regulations, guidelines, directives and/or decisions. (…)”

Article 6 (2) OFT Regulations:

“On entering the final competition, the Participating Member Associations automatically undertake to: a) observe and comply with these Regulations and ensure that each of their Delegation Members also observes and complies with these Regulations and the principles of fair play; b) observe and comply with the FIFA Statutes, as well as with any other FIFA regulations, directives, circular letters, guidelines and decisions as well as all applicable laws relating to the final competition; (…) c) observe and comply with all instructions and decisions taken by the bodies and officials of FIFA under the terms of these Regulations; (…).”

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(Emphasis added by the Panel)

146. The provisions above leave no room for doubts: by entering the final competition (played during the Paris Olympics), the FRMF automatically undertook to observe and comply with the OFT Regulations, which expressly mandate the application of the FIFA Disciplinary Code, and also with “any other FIFA regulations” and all instructions and decisions taken by the bodies and officials of FIFA.

147. Finally, the Panel also rejects the FRMF’s contention that FIFA lacked jurisdiction because it did not adopt competition-specific disciplinary regulations for the OFT. No separate code is required where, as here, the FDC already applies by explicit reference in the OFT Regulations. The FDC is, in a way, integrated into the OFT Regulations by this clear (cross) reference.

148. For all these reasons, the Panel finds that FIFA possessed a valid legal basis to assert disciplinary jurisdiction over the OFT and to apply the FDC to the incidents at issue.

C.2 Can the Moroccan representative team and its supporters be linked to the FRMF?

149. In assessing whether the individuals involved in the incidents can properly be regarded as supporters of Morocco’s representative team, the Panel recalls CAS 2007/A/1217, which held that “(…) the only way to ensure that responsibility is to leave the word “supporters” undefined so that clubs know that the Disciplinary Regulations apply to, and they are responsible for, any individual whose behaviour would lead a reasonable and objective observer to conclude that he or she was a supporter of that club. ” Similarly, in CAS 2015/A/3874 the panel clarified that the definition of supporter is not limited to persons with a formal or contractual link to club or federation, but extends to any individual whose conduct, appearance, or behavior objectively demonstrates support for a particular team.

150. CAS 2014/A/3944 further emphasized that the assessment must be made from the standpoint of an objective observer. Indicators such as wearing national colors, chanting during the anthem, or celebrating a team’s goals are sufficient to establish the requisite affiliation with the relevant team.

151. The Panel notes that this consistent line of CAS jurisprudence confirms that the notion of supporter is intentionally broad and functional. Its purpose is to ensure accountability

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for the conduct of individuals who visibly identify with, and lend their support to, a team in the context of a match, regardless of formal membership of legal ties.

152. Applying these principles to the present case, the undisputed Match Reports leave little doubt as to the identity of the individuals concerned and their connection to the Moroccan team. The Match Reports described persons dressed in red and green, displaying Moroccan flags, igniting flares in Moroccan colors, and setting fireworks during Moroccan celebrations. The pitch invasion during Match 4 originated from a section visibly populated by Moroccan supporters.

153. The Panel has also considered the FRMF’s argument that the Moroccan Olympic football team was formally entered by the Moroccan NOC, rather than the FRMF, and that no genuine link therefore exists between the FRMF and either the team or its supporters. This argument cannot be upheld.

154. According to Article 5 of the OFT Regulations, which establishes the eligibility for the OFT in the final competition, it is explicitly stated that “[t]he associations affiliated to FIFA may participate in the final competition provided there is a National Olympic Committee (NOC) in their respective country, which is already recognized or about to be recognized by the IOC.”

(Emphasis added by the Panel)

155. In addition, Article 6 of the OFT Regulations, which sets out the responsibilities of the participating national associations in the OFT, leaves no doubts that it is the FRMF – not the Moroccan NOC – that qualifies and enters a team into the OFT, since the expression “member associations” relates, without a doubt, to FIFA member associations in light of the context. Article 6 (1) of the OFT Regulations further stipulates that such associations undertake and agree to comply with the OFT Regulations “in collaboration with” their respective NOC’s, thereby recognizing a cooperative role for the NOC but not displacing the primacy of the association’s responsibility.

156. Furthermore, the FRMF actively promoted the team on its official platforms and social media channels, particularly during its progression to the semi-finals, consistently presenting it as Morocco’s national football team under its auspices. It would now be a clear case of “venire contra factum proprium” to ostensibly deny being involved with the team and state that the same was the Moroccan NOC’s sole responsibility.

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157. In light of these facts, and consistent with established CAS jurisprudence, the Panel is comfortably satisfied that the individuals responsible for the misconduct must be regarded as supporters of the Moroccan team within the meaning of Article 17 (2) of the FDC.

C.3 Can the FRMF be sanctioned under Article 17 (2) of the FDC?

158. Article 17 (2) of the FDC provides that all associations (not only host associations) are liable for the inappropriate behavior of their supporters “even if they can prove the absence of any negligence.” This establishes a rule of strict liability, applicable equally to home, away, and neutral-site matches, as well as to events not organized by the association concerned.

159. The CAS jurisprudence has consistently confirmed the validity and purpose of such strict liability provisions. In CAS 2013/A/3094 para. 90, the panel emphasized that Article 17 of the FDC “was clear and expressly removed any consideration of fault” from the inquiry. Likewise, in CAS 2002/A/493, the panel described the rule as having “a preventive and deterrent effect”, designed to ensure that associations remain responsible for the actions of their supporters.

160. The absence of negligence or organizational control does not exempt an association from liability. On the contrary, the rule exists precisely to guarantee responsibility for misconduct that may occur beyond an association’s direct control, thereby reinforcing deterrence and ensuring accountability.

161. Against this background, the Panel considers that FRMF’s submission that FIFA had “no involvement whatsoever” in the organization of the OFT is also misplaced. As established above, the OFT is an official FIFA event, governed and administered by FIFA through its Organizing Committee and regulations.

162. While the FRMF did not deny that incidents occurred, it disputes their attribution, challenging the attire, seating location, and reliability of the Match Reports. This contention cannot prevail. Pursuant to Article 40 of the FDC, the Match Reports are presumed accurate, and the burden rests on the FRMF to rebut them with specific evidence. Despite access to photographs and video footage, the FRMF failed to submit any such rebuttal. The Panel therefore accepts that the incidents described were committed by the Moroccan supporters.

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163. On this basis, the FRMF is liable under Articles 8 and 17 (2) of the FDC for the following misconduct:

• 33 instances of lighting fireworks or other objects;

• 6 instances of throwing objects;

• 1 pitch invasion;

• 3 instances of disorder in the stadium; and

• 1 instance of use of a laser pointer.

164. The FRMF further submits that it cannot be sanctioned because it was not the host of the Paris Olympics and had no role in ticketing, security, or logistics. However, strict liability applies equally to misconduct at away or neutral-site matches. Without this principle, FIFA would have no effective means to address supporter misconduct, as individual fans cannot themselves be subjected to disciplinary proceedings.

165. The CAS jurisprudence has consistently confirmed that liability under Article 17 (2) of the FDC arises automatically once improper conduct by supporters is established. The rule is preventive rather than punitive, designated to influence fan behavior indirectly by incentivizing associations to deter misconduct through education, awareness and cooperation with event organizers (CAS 2009/A/1944; CAS 2014/A/3944).

166. The fact that the Matches were organized by the Organizing Committee, and that the FRMF lacked direct operational control, does not alter this conclusion. By entering its qualified national team in the OFT, the FRMF accepted the applicable regulatory framework, including the FDC. Under the principle of strict liability, it must therefore answer for the behavior of its supporters.

167. The Panel thus concludes that FIFA was entitled to sanction the FRMF for the misconduct of its supporters. Having established that the individuals responsible were Moroccan supporters (see paras. 149–157 above) and given that Article 17 (2) of the FDC imposes liability irrespective of negligence, the Panel confirms that the FRMF is in breach of Article 17 (2) of the FDC.

C.4 Is the sanction imposed proportional to the violations committed?

168. In assessing proportionality, the Panel notes that the CAS jurisprudence has identified several guiding factors: (i) consistency of the sanction with prior comparable cases; (ii) whether the sanction exceeds what is reasonably necessary to achieve a legitimate disciplinary objective; and (iii) the presence of aggravating or mitigating circumstances

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(CAS 2022/A/8692). Ultimately, the sanction must correspond to the gravity of the offence and serve the objective of preventing re-offending (CAS 2014/A/3813).

169. The Panel further recalls that disciplinary sanctions serve both retributive and preventive purposes. It is not the Panel’s role to substitute its own discretion for that of the deciding authority where the sanction is reasoned and proportionate. A sanction will only be modified where it is shown to be arbitrary or manifestly and grossly disproportionate to the offence. The Panel will therefore examine the specific circumstances of this case against the above principles.

C.4.1 Aggravating factors:

170. The Panel is struck by the seriousness and multiplicity of the offenses committed by the Moroccan supporters. The Match Reports – whose accuracy has not been challenged – record thirty-three pyrotechnic incidents, six instances of objects being thrown, one pitch invasion, three cases of disorderly conduct, and one use of a laser pointer. These acts occurred across five separate matches, evidencing a recurrent and systemic safety issue. Such misconduct poses a serious threat to the safety of players, officials, and other spectators.

171. The Appealed Decision rightly emphasized that igniting fireworks, throwing objects, and invading the pitch rank among the most dangerous forms of stadium misconduct, as they create a high risk of injury and provoke disorder. In particular, the Match Report of Match 2 records that explosive firecrackers were thrown onto the pitch, disrupting play and damaging the field, laser pointers were directed at players, and objects were thrown into the playing area, creating a hazardous environment and obvious risks o f violence and disorder.

172. The Panel further notes that, in concurrent CAS proceedings (CAS 2025/A/11271), concerning the match Argentina v. Morocco played on 24 July 2024, Moroccan supporters were alleged to have been involved in several incidents of disorder.

173. Against this background, the Panel holds that once such incidents had occurred, it was incumbent upon the FRMF to take reasonable steps to mitigate the risk of further misconduct. As the Argentina match was the first match played by the Moroccan team in the OFT, the FRMF was on notice of the risks.

174. While the Panel accepts that the FRMF had no organizational authority over the event, a duty of care nevertheless shall be attached to it to act diligently and to proactively seek

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the assistance of the Organizing Committee and/or FIFA with a view to identifying and implementing preventive measures. The Panel finds no evidence of any such attempt or initiative by the FRMF. Verified proactive efforts could have operated as a mitigating factor, but their absence constitutes an aggravating factor by omission in the assessment and determination of the sanction.

175. The Panel therefore finds that the FRMF failed in its duty of care by not reacting to the problems that had already arisen in the first match (CAS 2025/A/11271) and by not seeking to prevent their recurrence in the subsequent matches, where further incidents of supporter misconduct occurred. This lack of proactivity and diligence constitutes, in the Panel’s view, an aggravating factor justifying the level of the fine.

C.4.2 Mitigating factors:

176. On the other side of the scale, the FRMF argued that the unique Olympic context limited its control over security and that this circumstance should be considered in mitigating the sanction.

177. The Panel acknowledges that, in a multi-organizer tournament such as the OFT, the operational control of a visiting association over stadium safety is indeed more limited than in a home match. In the present case, the Panel accepts that the FRMF had no operational authority or direct involvement in the organization of the Matches. However, under the FDC, such lack of control is irrelevant with regards to strict liability.

178. Mitigation may be considered at the sanctioning stage not only where an association is able to demonstrate preventive efforts, but also where it has taken responsible actions aimed at avoiding the incident in question or preventing its recurrence. The threshold for such mitigation is necessarily high, as ensuring safety and order is a standard obligation incumbent upon any national association in connection with the participation of its representative teams.

179. In the present case, the Panel finds no evidence of diligence or responsible actions by the FRMF that would justify any mitigation of the sanction.

180. The Panel recalls that the fine imposed related to misconduct occurring across five matches. After the incidents in the match Argentina v. Morocco, the FRMF would have been expected to assume a more active and participatory role in preventing the recurrence of such misconduct in the subsequent matches.

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181. Yet, the record reveals no proactive measures undertaken by the FRMF, notwithstanding its strict liability and corresponding duty of care. In particular: (i) no communications were addressed to supporters; (ii) no formal requests were made for stricter entry controls, (iii) no reinforcement of security personnel was sought in the Moroccan supporter sections, and (iv) no contact was established with the organizers to offer assistance in preventing further incidents. Such inaction falls manifestly short of the duty of care required under the principle of strict liability.

182. The only positive element noted by the Panel is a single instance in which security personnel removed a supporter who had lit a flare. While commendable, this isolated response cannot outweigh the broader pattern of repeated disorder. It does not amount to the “exceptional” diligence required to justify a reduction of the sanction.

183. The Panel therefore cannot accept the Olympic context or the FRMF’s limited organizational role as grounds to excuse or substantially reduce the sanction. The case does not concern an isolated incident beyond the FRMF’s control, but rather a recurring pattern of misconduct by Moroccan supporters across five matches.

184. The FRMF had both the duty and the opportunity to adopt preventive and corrective measures but failed to do so. In these circumstances, the Panel finds no mitigating factors capable of justifying the cancellation or reduction of the sanction imposed.

185. In sum, the FRMF failed to demonstrate any diligent attempt to prevent or contain the misconduct. Under the strict liability principle, it had a duty of care to take proactive measures and to coordinate with the organizers to avoid the recurrence of such incidents. The Panel emphasizes that the sanction imposed reflects the repeated and serious nature of the misconduct across five matches.

C.4.3 Appropriateness of the sanction:

186. Pursuant to Article 6 (4) of the FDC, FIFA has the discretion to impose fines of up to CHF 1,000,000 for breaches of its rules.

187. Within this legal framework, the Panel turns to the Appealed Decision, in which the FIFA Appeal Committee adopted a structured approach by assigning a monetary value to each incident, as contemplated in Annex 1 of the FDC. This itemized methodology resulted in a total fine of CHF 44,500 (please see para. 19 above).

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188. The Panel observes that this amount falls at the lower end of the range permitted by Article 6 (4) of the FDC and is broadly consistent with FIFA’s sanctioning practice in comparable cases. It must further be recalled that the sanction was imposed specifically in relation to the Matches at the Paris Olympics.

189. The Panel has identified no precedent in which a substantially lower fine was imposed for a comparable breadth of violations across multiple matches. On the contrary, when broken down per incident, the sanction appears measured and even lenient. The fine does not exceed what is reasonably necessary to achieve deterrence. By contrast, a mere reprimand or warning, as requested by the FRMF, would fail to reflect the seriousness of the offences and would be manifestly insufficient to discourage similar misconduct in the future.

190. This is precisely what the principle of proportionality, when applied together with the regime of strict liability, is designated to achieve. Sanctions must be effective, dissuasive, and commensurate with the seriousness of the incidents, while avoiding any excess. The sanction imposed in the present case meets that standard.

C.5 Conclusion

191. Having weighed all the circumstances, the Panel concludes that the FRMF is strictly liable for the improper conduct of its supporters during the Matches held as part of the OFT at the Paris Olympics, and that the fine of CHF 44,500 is neither excessive nor disproportionate.

192. Accordingly, the Panel finds no basis to review the Appealed Decision and, therefore, the Appeal must be dismissed, and the Appealed Decision shall be confirmed in its entirety.

IX. COSTS

(…)

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