It's in this sort of area that I anticipate challenges to fines/transfer embargoes to come. Clubs that are penalised will argue the toss about the precise definitions incorporated into FFP, saying that by their interpretation of the rules what they have done is ok. I doubt that many (any?) of...
Oh, you shouldn't read anything negative in my comment; it was just a factual response. I do think that it would have been much better to spread the fines across compliant clubs (which might be as few as, say, 10), but fines going to charity are, as you say, better than nothing.