Malaysian Sports Lawyer Pessimistic That The FAM Naturalization Document Counterfeiting Scandal Was Brought To CAS

Facundo Garces is one of Malaysia's players who was involved in a naturalization document forgery scandal (Instagram/@facundogarces).

JAKARTA - Malaysia's famous sports lawyer, Nik Erman Nik Roseli, believes that the Malaysian Football Federation (FAM) will face a tough struggle if it continues to appeal to the Sports Arbitration Court (CAS) over the scandal over the forgery of naturalization player documents.

His assessment comes after the FIFA Appeal Committee issued a reasonable decision, which put FAM in a more difficult position on Tuesday, November 18, 2025.

FIFA upheld sanctions against FAM and seven naturalized players "Gabriel Palmero, Facundo Garces, Rodrigo Holgado, Imanol Machuca, Joao Figueiredo, Jon Irazabal, and Hector Hevel" for violating Article 22 of the FIFA Disciplinary Code on falsification and falsification of documents.

The FIFA Appeal Committee also instructed formal investigations to identify those responsible for the forgery, review the adequacy of FAM's internal compliance and governance, and determine whether further disciplinary action is needed against FAM officials.

"The FIFA Appeal Committee found that the FAM failed to show concrete improvement measures, did not identify those responsible for the manipulation, did not impose internal sanctions, and did not initiate structural reforms."

"Based on these findings, FIFA has ordered its secretariat to investigate the given authority based on Article 35(5) FIFA Disciplinary Code."

"This may be due to the assumption that the FAM failed to start a formal investigation. Article 30(7) allows FIFA to intervene if member associations do not act within 90 days," said Nik Erman.

He said the chances of FAM in CAS depend entirely on the basis of the appeal.

"FAM argues that the forgery was carried out without the knowledge or permission of the players, the Secretary General, or the Executive Committee. However, the FIFA Appeal Committee does not agree," said Nik Erman.

This is coupled with the absence of evidence that denies the forgery, weakening the position of FAM.

Both in disciplinary and appeal decisions, FAM did not deny that the documents were falsified, but they didn't notice it.

Other reasons put forward include lack of intention, lack of impact on sport, and mitigating factors are unlikely to succeed in CAS.

In September 2025, FIFA fined FAM 350,000 Swiss francs (around Rp7.3 billion). The seven players were each fined 2,000 Swiss francs (around Rp42 million) and banned from all activities related to football for 12 months.