The FA v Trippier (no 2)

Forum: Regulatory Commission

Decision date:

Can an FA Regulatory Commission vary the start date of a sanction in light of a FIFA ruling that the sanction's world-wide effect be stayed?

Sport:Association FootballRegulator:The FAAppellate level:First Instance

Kieran Trippier was found to have breached Rule E8(1) for betting related offences, including providing inside information in respect of his pending move from Tottenham Hotspur FC to Atletico Madrid. On 18 December 2020, the Regulatory Commission sanctioned Trippier by banning him for 10 weeks from all football and football-related effective from 21 December 2020. The FA then applied for the sanction to be given worldwide effect by FIFA, given Trippier's transfer to Atlelico in Spain, and FIFA duly acquiesced. However, on 2 January 2021, Atletico successfully applied for an interim suspension of the sanction's worldwide effect. On 5 January 2021, The FA applied to the Regulatory Commission to delay the date from which the sanction took effect until Trippier's return to the jurisdiction or the FIFA interim suspension of sanction had been lifted.



The Regulatory Commission held that it had no jurisdiction to grant The FA's application. Per regulation 55 of The FA Disciplinary Regulations, the Commission could issue "such further order, requirement or instruction as it considers appropriate for the purpose of giving effect to its decision". However, the Commission's decision was in full effect; Trippier was banned from all football and football-related activity as of 21 December 2020, within The FA's jurisdiction (ie England). That the effect of the ban could not be felt outside of The FA's jurisdiction was a matter for FIFA. If the Commission had intended the ban to apply outside of The FA's jurisdiction, then the Commission would have been acting outside of its powers when issuing the sanction. The Commission also made a costs award against The FA.


By Joel Wallace
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