Notes on Article 19: In pursuit of a more coherent standard

In late 2021, the Court of Arbitration for Sport denied 15-year-old American David Kelley’s[1] attempt to sign with Fehervar, one of Hungary’s top clubs.  The player had argued he fell within the “not linked to football” exception to Article 19 of FIFA’s RSTP – the rule that, in most cases, prevents clubs from signing foreign …