Just a quick note on the specific charges:
Charged with breach of 6 regulations. These cover:
- Using unregistered intermediaries (2 regs covering this same offence)
- Using agents who were prohibited from acting due to (assumed) prior conflicts of interest *
- Concealing or misrepresenting intermediary services (likely stashing the costs in other companies)
- General prohibition on TPO
- Failure to disclose intermediaries involved in option agreements
Charges cover 2009 - 2022, with most of the activity between 2010 and 2016. These weren't one-off offences, but as agent payments can affect 3 seasons for a single contract, it's possible that they're charged with 3 offences for a single contract.
13 seasons x 6 offences per season = 78 charges, so presumably some of the offences don't apply in one or more seasons, but as with City the 74 charges basically relates to the same alleged offences over multiple seasons.
* On the conflict point, I have seen this in practice where a player's normal agent was barred from acting in a transaction due to services provided in the previous 2 years. If I'm being honest, I don't think there is always a conflict, but there is a specific rule there for reasons I don't quite understand. But it's a clear rule, and one which the FA tends to flag if it arises (they refuse to register the agent contract as a result). So it looks like Chelsea identified the issue and then just didn't declare the contract (where the normal process is for the conflicted agent to get a mate to take the fee and then return the favour further down the line when their mate is conflicted).