The Editors of the International Sports Law Journal (ISLJ) invite you to submit abstracts for the third ISLJ Annual Conference on International Sports Law, which will take place on 24 and 25 October 2019 at the Asser Institute in The Hague. The ISLJ, published by Springer and Asser Press, is the leading academic publication in the field of international sports law. The conference is a unique occasion to discuss the main legal issues affecting international sports with renowned academic experts and practitioners.

We are delighted to announce the following confirmed keynote speakers:

• Beckie Scott (Chair of the World Anti-Doping Agency (WADA) Athlete Committee, Olympic Champion, former member of the WADA Executive Committee and the International Olympic Committee (IOC)),
• Ulrich Haas (Professor of Law at Univerzität Zürich, CAS arbitrator), and
• Kimberly Morris (Head of FIFA Transfer Matching System (TMS) Integrity and Compliance).

We welcome abstracts from academics and practitioners on any question related to international sports law. We also welcome panel proposals (including a minimum of three presenters) on a specific issue. For this year’s edition, we specifically invite submissions on the following themes:

• The role of athletes in the governance of international sports
• The evolution of sports arbitration, including the Court of Arbitration for Sport
•  The role and functioning of the FIFA transfer system, including the FIFA TMS
•  The intersection between criminal law and international sports (in particular issues of corruption, match-fixing, human trafficking, tax evasion)
• Hooliganism
• Protection of minor athletes
• Civil and criminal liability relating to injuries in sports

Please send your abstract of 300 words and CV no later than 30 April 2019 to a.duval@asser.nl. Selected speakers will be informed by 15 May.

The selected participants will be expected to submit a draft paper by 1 September 2019. All papers presented at the conference are eligible (subjected to peer-review) for publication in a special issue of the ISLJ.  To be considered for inclusion in the conference issue of the journal, the final draft must be submitted for review by 15 December 2019.  Submissions after this date will be considered for publication in later editions of the Journal.

The Asser Institute will cover one night accommodation for the speakers and will provide a limited amount of travel grants (max. 250€). If you wish to be considered for a grant please indicate it in your submission. 

Editor's note:

Daniela is a researcher at the Asser Institute in the field of sport and human rights. She has a background in public international law and human rights law and defended her PhD project entitled “Blurred Lines of Responsibility and Accountability – Human Rights Abuses at Mega-Sporting Events” in April 2021 at Tilburg University. She also works as independent consultant in the field of sport and human rights for the Centre for Sport and Human Rights, or the European Parliament among other clients from the sports ecosystem

As Head of Policy and Outreach, Guido is in charge of the Centre for Sport & Human Rights engagement with governments, international and intergovernmental organisations and sports organisations. He represents the Centre at conferences, events and bilateral dialogues to reach new audiences and partners and raise public awareness and understanding of the Centre’s work .

On February 24, 2022, the Russian military invaded Ukrainian territory. What followed was an escalation of the war, day by day, causing thousands of victims and forcing millions of people to flee. On March 2, the UN General Assembly overwhelmingly adopted a resolution deploring "in the strongest possible terms" Russia's aggression against Ukraine by a vote of 141 to 5, with 35 abstentions. On March 29, Russian and Ukrainian representatives met in Istanbul for another round of negotiations. No ceasefire has been agreed and hostilities continue.

Many states, international organizations and corporations quickly took measures in response to this invasion. Hundreds of companies decided to withdraw from Russia. Some countries decided to strengthen economic sanctions against Russia and Belarus and to provide military and economic help to Ukraine. Many civil society actors mobilised to organize and provide humanitarian support for Ukraine. Interestingly, international sports organisations like the International Olympic Committee (IOC), the Fédération Internationale de Football Association (FIFA), World Athletics and many other international federations, issued statements condemning the invasion and imposed bans and sanctions on Russian and Belarussian sports bodies and athletes.

This blog post provides an overview of the measures adopted by a number of international sports federations (IFs) that are part of the Olympic Movement since the beginning of the war and analyses how they relate to the statements issued by the IOC and other sanctions and measures taken by international sports organisations in reaction to (geo)political tensions and conflict.

Unprecedented Action: An Overview

The table (pages 9-11), updated by the Centre for Sport and Human Rights on March 30, shows that eight different kinds of measures and decisions have been taken by a number of international sports federations:

1. Condemnation of the invasion

On the day the invasion and attack started, the IOC issued a statement condemning the Russian invasion of Ukraine as a breach of the Olympic Truce. The same day, World Athletics and the Union of European Football Associations (UEFA) issued similar statements. Almost all IFs have issued such statements by now, although with notable differences in language. While most of them condemned the invasion (see World Triathlon or World Rugby), some expressed concern for the situation hoping for a rapid peaceful resolution (see International Ski Federation or International Table Tennis Federation).

2. Cancellation and relocation of events from Russia and Belarus

On the following day, February 25, the IOC published a new statement, in which it recommended to international federations to cancel or relocate sport events that were supposed to take place in Russia or Belarus. This triggered all IFs that had events planned in those countries to cancel or relocate these. Events like the International Volleyball Federation Men’s World Championship were removed from Russia. Moreover, some IFs that had no events planned yet committed to not including Russia or Belarus as candidates for any future events (see World Skate).

3. Participation of Russian and Belarussian teams and athletes

On February 28, “to protect the integrity of global sports competitions and for the safety of all the participants”, the IOC issued new recommendations, this time concerning the prevention of participation of Russian and Belarussian athletes and officials in international tournaments, and where that is not possible anymore, making clear that they can only participate if no association with their country is being made. At least 39 federations followed this recommendation and issued a ban or a partial ban of Russian and Belarussian athletes, among them the Union Cycliste Internationale, the World Curling Federation, the International Handball Federation, and the International Gymnastics Federation (FIG).

The International Paralympic Committee (IPC) had initially decided to allow Russian and Belarussian Paralympians to participate in the Beijing 2022 Winter Paralympic Games of as neutrals. Threats of boycott from other nations and escalating tension in the athletes' village in Beijing led the IPC to issue a new statement 24 hours after the first one denying entry to the Paralympic Games to Russian and Belarussian Paralympians. Similar pressures were observed in football, as a number of players and Football Associations publicly stated they would refuse to play against Russia in 2022 World Cup playoffs. Subsequently, FIFA and UEFA suspended Russian clubs and national teams from all competitions on February 28. It is also worth noting here that FIFA’s and UEFA’s statements so far have not mentioned Belarus nor Belarussian athletes.

The International Judo Federation decided to provide Russian athletes with the opportunity to participate in its events only under the IJF flag, logo and anthem. Nevertheless, the Russian Judo Federation announced its withdrawal from all international events due to safety reasons.

4. Suspension of Russian and Belarussian federations

Some IFs went beyond those recommendations and took additional actions. Five organizations, the International Tennis Federation, World Athletics, World Rugby, the International Biathlon Union and the International Bobsleigh and Skeleton Federation suspended or expressed the intention to suspend Russian and Belarussian membership, without this being recommended by the IOC. Organisations like World Triathlon had similar measures already in place due to the previous doping scandal with Russia. Even the International Paralympic Committee expressed the intention to discuss the suspension of the National Paralympic Committees of Russia and Belarus at their next general assembly.

5. Suspension of Russian and/or Belarussian leadership representation in federation’s government structures

A handful of IFs also suspended Russian individuals that held leadership positions in their governance structures, such as the International Automobile Federation, or the International Canoe Federation, whereas the International Luge Federation suspended all Russian representatives that held functions in the organization’s Executive Board, Commissions, or Working Groups. All these decisions went beyond what was recommended by the IOC. Alisher Usmanov, the Russian President of the International Fencing Federation, was added to the UK and US sanctions list and decided to suspend exercise of his duties.

6. Suspension and/or cancellation of sponsorship contracts

On February 28, UEFA decided to terminate all agreements with the state-owned Russian energy company Gazprom across all competitions, including the UEFA Champions League, UEFA national team competitions and the EURO 2024. This termination came only one year after it had renewed the sponsorship agreement. So far UEFA seems to be the only sport organization that took measures in relation to their sponsorship deals.

7. Withdrawing sport-related orders of honours

The February 28 recommendations of the IOC also included a decision to “withdraw the Olympic Order from all persons who currently have an important function in the government of the Russian Federation or other government-related high-ranking position”. Three Orders were withdrawn by the IOC, from Vladimir Putin, President of the Russian Federation, Dmitry Chernyshenko, Deputy Prime Minister of the Russian Federation, and Dmitry Kozak, Deputy Chief of Staff of the Presidential Executive Office. The International Swimming Federation and World Taekwondo immediately followed this recommendation, while the International Judo Federation and United World Wrestling had already taken these measures before the IOC issued their statement. Also, the IPC withdrew the Paralympic Honour from Vladimir Putin and the Paralympic Order from four other Russian government representatives.

      8. Fundraising/Donating for Ukraine

Finally on March 3, the IOC published a letter from the IOC’s president Thomas Bach calling upon the Olympic Movement to engage in humanitarian support for Ukraine through fundraising and donating. At least 15 federations followed this call, or had already set up such measures. The International Luge Federation set up an emergency aid fund for Ukraine and called upon its National Federations to donate. The International Biathlon Union launched a solidarity programme for Ukrainian biathlon, by hosting training camps for Ukrainian athletes and teams. The International Ice Hockey Federation is supporting efforts that were initiated from their national federations. Some of these efforts are dedicated to Ukrainian people in general, while others are focussing on Ukrainian athletes and teams.

A look at the Past

The unprecedented nature of these actions becomes clear when looking at other situations in which international sports issued similar sanctions and measures against national federations for their government’s political decisions and actions, or did not take any actions. When the apartheid system started in South Africa in 1948, it took the IOC 16 years to exclude South Africa from the Olympic Games and only in 1970 was the South African National Olympic Committee expelled. Another 18 years later the IOC adopted a declaration against apartheid in sports. During the Balkan war, what then was known as Yugoslavia was banned from all international events following a UN Security Council resolution, and consequently the Yugoslavian football team was prevented from participating in the Euro 1992 European Football Championships , while athletes from Yugoslavia could only compete as “Independent Olympic Participants” at the 1992 Summer Olympic Games and were not allowed to compete at the 1994 Winter Olympic Games. This is the precedent that comes closest to the current situation both in terms of its factual context and of the consequences faced by the athletes and sports organisations of the state concerned. However, unlike with the current actions of Russia, the UN Security Council had then adopted a binding resolution requiring states to bar athletes and clubs from Yugoslavia from international sporting competitions taking place on their territory. At the time, unlike now, the IOC negotiated (successfully) with the UN Security Council to allow the Yugoslav athletes to take part in the 1992 Olympics as neutral athletes.

Sadly, situations of war and conflict are currently happening in many areas of the world, particularly in the Middle East, Asia and Sub-Saharan Africa. The war in Yemen, for example, has been going on for seven years now, causing what has been referred to by the UN as the largest humanitarian crisis ever. To our knowledge, no action has been taken by the IOC or any other sport body in reaction to this war. While one should be cautious to compare situations of war and conflict, as they all are different and come with unique political dynamics and challenges, this brief historical overview and comparison shows that the sport bodies have acted in similar ways in some similar situations (the Yugoslav case), however not in all situations. It also shows that in the past, the IOC’s decisions took significantly longer, and were responding to a binding request from the UN. This is not the case in this specific conflict, where the decisions were taken with unprecedented speed and without an express UN resolution on the subject. Moreover, while in previous situations it was mainly national sport’s bodies directly impacted by the conflict that took certain measures individually, on this occasion international federations followed the IOC’s authoritative guidance and rapidly took decisions and issued sanctions.

What’s next?

Some commentators argued that these measures were exclusively taken in response to geopolitical and public pressure and thereby challenge the constant claim that sport is neutral and does not get involved in politics. The IOC and other sport bodies in return explained that these measures were adopted in response to the Russian violation of the Olympic truce, to protect the integrity, fairness and safety of competitions and athletes. According to Thomas Bach, “we (the IOC) will not fall into the trap of the cheap argument that this would be a politicisation of sport”.

Whatever the motivation for these actions may be, their long-term effect still remains to be observed. Some of them are currently being challenged before the Court of Arbitration for Sport, which may or may not result in the invalidation of some of these measures. At the same time, new (unprecedented) measures could follow.

INTRODUCTION

Almost a year after their announcement, the new FIFA Regulations on working with Intermediaries (“FIFA Regulations”) came into force on 1 April 2015. Their purpose is to create a more simple and transparent system of regulation of football agents. It should be noted, however, that the new FIFA rules enable every national football association to regulate their own system on players’ intermediaries, provided they respect the compulsory minimum requirements adopted. In an industry that is already cutthroat, it thus remains to be seen whether FIFA’s “deregulation” indeed creates transparency, or whether it is a Pandora’s Box to future regulatory confusion.

This blog post will provide an overview of the new FIFA Regulations on working with intermediaries and especially its minimum requirements. Provided that national associations are encouraged to “draw up regulations that shall incorporate the principles established in these provisions”[1], three different national regulations have been taken as case-studies: the English FA Regulations, the Spanish RFEF Regulations and the Brazilian CBF Regulations. After mapping their main points of convergence and principal differences, the issues that could arise from these regulatory differences shall be analyzed.  

FIFA REGULATIONS ON WORKING WITH INTERMEDIARIES

The objective of the new Regulations, as explained in a blog dated from 3 July 2014, is no longer to regulate access to the activity of players’ agents (now ‘intermediaries’), but to provide a framework for a better control of the activity itself by establishing minimum standards and requirements and by installing a transparent registration system.[2]

The most significant change is that FIFA introduced a provision recommending to cap the maximum remuneration an intermediaries should derive from an individual transfer. Article 7(3) holds that the maximum commission payable to an intermediary should be 3% of the player’s basic gross income (regarding an employment contract) or 3% of an eventual transfer fee (transfer agreement). Additionally, FIFA prohibits any payment when the player concerned is a minor. These two restrictions have triggered a complaint of the AFA (UK Association of Football Agents) before the European Commission. Moreover, in Germany, the company Rogon Sport Management challenged the new DFB regulations for intermediaries and won a partial victory in a preliminary ruling of the Regional Court of Frankfurt.[3] They argue that these regulations could lead to an infringement of the competition law. This issue will be developed in a different blog post later this week.

Another minimum requirement set by FIFA is the obligation for all intermediaries to submit an Intermediary Declaration (Annex 1 and 2 FIFA Regulations) to the relevant association. This is due each time an individual or a company wishes to be registered as an intermediary with a national association, and also in order to register a transaction in which he acts on behalf of a player or a club. By signing the Declaration, the intermediary is supposed to be bound to the FIFA Regulations, in addition to the regulations of every confederation and association to which he is contractually related.

Furthermore it is stipulated that legal persons can also be considered ‘intermediaries’ under the new Regulations.[4] However, they do not provide any criteria defining how the national associations are required to register the legal persons acting as intermediaries.

The FIFA Regulations prohibit any payment to the intermediary in connection with a transfer compensation (other than the commission established in the Article 7(3)), training compensation and solidarity contributions. Moreover, in accordance with provision 7(4) of the FIFA Regulations, no compensation can be based on the future transfer value of a player.

Another compulsory prerequisite at stake is that the intermediary ought to be registered with the association where he desires to provide his services prior to initiate any activity (Article 3(1) FIFA Regulations). As will be highlighted below, this provision has important practical consequences. Finally, FIFA no longer claims jurisdiction over disputes that could arise between intermediaries and their clients or other intermediaries. It entrusted the national associations to deal with these kind of disputes. The national associations shall establish proper dispute resolution mechanisms to hear these disputes.   

NATIONAL REGULATIONS ON WORKING WITH INTERMEDIARIES

With the objective of analysing how the different associations have implemented the new intermediaries’ system, three different national regulations will be compared: The FA Regulations on Working with Intermediaries, the RFEF (Spain) Regulations and the CBF (Brazil) Regulations. 

1. The FA (England)

The FA was the first association to publish new provisions regulating intermediaries (”FA Regulations”). It should be pointed out that the new FA Regulations are to a large extent similar to the former FA Agents Regulations. For example, the assignment or subcontracting services or duties, the definition of interest, the dual representation standards and the payment to the intermediary by the club on the player’s behalf as a taxable benefit were already included in the former FA Agents Regulations. 

Nevertheless, it is surprising that the FA Regulations do not require the intermediary to submit an Intermediary Declaration, even though it is a mandatory requirement imposed by the FIFA regulations. As stated above, national associations, such as the FA, are required to implement and enforce these minimum standards/requirements. It is not excluded that FIFA, based on Article 10 FIFA Regulations, will “take appropriate measures if the relevant principles are not complied with”.

The FA prescribes that all intermediaries are to undertake the so-called ‘Test of Good Character and Reputation for Intermediaries’. By undertaking this ‘Test’, the intermediary is asked to demonstrate his impeccable reputation and declares that he has not been convicted for any offence related to his services as an intermediary.

The individual who wishes to register himself as intermediary with the FA will have to pay a registration fee of £500 (around 690 €) for the first registration. However, this fee is waived to those who were already ‘FA Registered Agents’ on 31 March 2015. Instead, in order to remain registered as an intermediary, an annual renewal fee of £250 (around 345 €) will de be due.

Additionally, if the intermediary wishes to act on behalf of minors, he must obtain a specific authorisation from the FA. He will need to provide the FA with the ‘Disclosure and Barring Service check’ (CRB check), which enables in the UK to make better informed recruitment decisions by identifying candidates who may be unsuitable for certain work, especially involving children, or an equivalent for non-English intermediaries. Moreover, regulation B8 FA Regulations prohibits any approach to, or enter into an agreement with, a player before the start of the calendar year in which he turns 16.

Out of the three national associations analysed, the FA is the only association that has provisions regarding the existing representation contracts lodged with the FA before 1 April 2015. These contracts have to be resubmitted to the FA within 10 days of the intermediary registering with the FA.

For the purpose of the representation contracts between a player and an intermediary the maximum length will be two years (regulation B10).

With respect to legal persons, the FA Regulations impose the obligation to register the company/partnership by an individual already registered as an intermediary. Moreover, any individual carrying out intermediary activities on behalf of a legal person must be registered as well.[5]  

Lastly, the FA adopted the same wording as FIFA in relation to the 3% recommendation (C11 FA Regulations). However, the English football association also published a statement (‘Intermediaries Guidance Notes’) indicating that this ‘recommendation’ is non-binding and that clubs and players are free to remunerate intermediaries as they wish. It is clear that this provision could generate doubts regarding the amount of the compensation that the intermediary is entitled to. In fact, the 3% recommendation is significantly lower than the 5-10% commission rates that licensed agents tended to receive[6]. However, with this statement, the FA is not precluding an intermediary and his client to agree on a percentage higher than 3%.

2. RFEF (Spain)

As far as the RFEF (Spanish association) Regulations on working with Intermediaries (“RFEF Regulations”) are concerned, they are the most in line with the FIFA Regulations as compared to the FA and CBF Regulations. The Intermediary Declarations are attached as Annex 1 and 2 at the end of the Regulations.  The registration fee for the first registration as an intermediary in Spain is 861 €. Registration has to be renewed on a yearly basis. However, it is yet unknown what the exact costs will be for renewing the registration. Similar to the FA’s ‘Test of Good Character and Reputation’, the RFEF provides a ‘Code of Ethics’ (Annex 3), which has to be signed by the applicant. Furthermore, the maximum length of a representation contract between a player or a club and an intermediary is two years.[7] Although the maximum length of contracts in England is also two years, it should be kept in mind that the FA Regulations only refer to contracts between intermediaries and players, not between intermediaries and clubs.

The most controversial aspect of the Spanish Regulations is the way that the Registration Procedure (Article 4) is designed. The steps for becoming a RFEF Intermediary are summarized as follows:

1. The potential intermediary has to provide a written request addressed to the RFEF General Secretariat (“Secretaría General”).

2. After the application is declared admissible, the RFEF will grant the individual the status of “Applicant”. Subsequently, the RFEF will convoke the applicant for an interview and decides whether the Applicant is ‘suitable to advice’ clients on the football market.   

3. If the outcome of the interview is positive, the Applicant must provide the following documents: ID, VAT number (for legal persons), two pictures, CV, Intermediary Declaration, the payment of the Registration Fee, return the former agent license (if any) and the Code of Ethics. 

Another interesting point is that the Spanish Regulations do not provide any information on the intermediary’s remuneration. Bearing in mind that FIFA recommends the remuneration to be 3%, it will be interesting to see the consequences of the RFEF’s decision to disregard this recommendation.

This could be understood as an implicit challenge to the ‘3% recommendation’. In practice, this omission has similar consequences than the solution adopted by the English FA. In short, FIFA’s recommendation is treated as a soft advise rather than a binding legal standard.

3. CBF (Brazil)

The CBF (Brazilian association) Regulations on Working with Intermediaries (“CBF Regulations”), were approved on 24 April 2015. In order to be registered as an intermediary, the individual must provide the Intermediary Declaration attached in Annexes 1 and 2 to the Regulations. The registration fee has not been published yet. The applicant should also deliver a declaration stating that he has neither conflicts of interest nor a criminal record. Moreover, the potential CBF intermediary is required to take out a professional liability insurance for the amount of 200,000 ‘reais’ (around 60,000 €). Thus, the CBF, taking advantage of its right to ‘go beyond’ the minimum requirements imposed by FIFA, has introduced a feature of the former Agents Regulations that the new FIFA Regulations had abandoned, i.e. the professional liability insurance.[8]

Following the line of the FA and the RFEF, the Representation Contract shall not last more than “24 months” (Article 11(3)). Given that the Regulations do not state whether it refers to contracts with players or clubs, it can be inferred that all parties are subject to this restriction. On the other hand, the CBF prohibits in article 11(2) to extend the Representation Contract tacitly, a renewal in writing is necessary.

The remuneration of the intermediary is regulated in the same way as in the FIFA Regulations, except for one detail concerning the transfer fee: in Brazil, the remuneration, which should not exceed 3%, amount must be calculated on the basis of the “possible basic gross income for the entire duration of the relevant employment contract” (article 19.III), instead of a share of the transfer fee as envisaged by the FIFA, RFEF or FA Regulations.

Finally, Article 4 expands the scope of application of these regulations to ‘international activities’, specifically “operations regarding the negotiation of an employment contract or players’ transfer which have effect in a different national association”. By means of this Article, an operation which takes place out of the CBF jurisdiction has to be registered by the ‘CBF Intermediary’ with the CBF. As a consequence, the CBF Intermediary must register the operation with two federations: first, the national association where the operation takes place, and second, the CBF, where the only connection is the intermediary. 

Table providing an overview of the main requirements stipulated by the FIFA, FA, RFEF and CBF Regulations

 CONCLUSION

The mandatory registration requirement for intermediaries with the relevant national association, as stipulated by the FIFA Regulations, the FA Regulations, the RFEF regulations and the CBF Regulations, leave room for a wealth of legal uncertainties that will need to be clarified by football’s governing bodies and the various courts (and also the EU Commission) called to pronounce themselves on those regulations.  Specifically, should an intermediary register himself with every single association where he is supposed to act on behalf of his clients? What would happen if on 31 August (summer transfer window deadline) a Spanish club calls him to sign one of his players and he is not registered in Spain as an intermediary?

Furthermore, every association has a registration fee to satisfy prior to the registration of around 500 €. Taking into account the international dimension of football and its transfer market, it could well be necessary for an intermediary to register himself with a dozen of associations simply to carry out his profession effectively. As a result, he would have to spend roughly 6.000 € in registration fees on a yearly basis.  

Subsequently, this could lead to an increase of the number of corporations, which provide intermediary services. Indeed, the recourse to a transnational agency employing a number of intermediaries registered with different national associations would be a very efficient way to tackle this problem. Thus, at medium long-term, at least at the international level, the new system will probably not generate the chaos that some authors are predicting. In fact, rather than opening the market to everyone, these requirements could well be a barrier of entry for many intermediaries and might trigger a consolidation of the market in a smaller number of bigger players. This has bad sides, less competition, and good sides, more sophisticated players more likely to provide quality services and to care about their long-term reputation. In short, we predict that only the main ‘cowboys’ in the ‘wild west’ will be able to play by the new rules of the game for football intermediaries.

[1] Nick de Marco, “The new FA Intermediaries Regulations & disputes likely to arise”, available at lawinsport.com, 31 March 2015.

[2] Daniel Lowen, ‘A Guide To The FA’s Regulations on Working with Intermediaries’ www.lawinsport.com, 17 February 2015.

[3] Handelsblatt, “Gericht gibt Spielervermittler teils recht”, 30 April 2015.

[4] See FIFA Regulations on Working with intermediaries: Definition of an intermediary, page 4

[5] Appendix II FA Regulations

[6] UEFA ‘Club Licensing Benchmarking Report 2012’, page 54. http://www.uefa.org/MultimediaFiles/Download/Tech/uefaorg/General/02/09/18/26/2091826_DOWNLOAD.pdf

[7] Article 8(4) RFEF Regulations

[8] Article 5(e) CBF Regulations