Apart from the non-cooperation charges, which go up to this financial year, that's the only information they have, as the Der Spiegel articles were published then. But the image rights arrangement appears to have ended in 2018, as Fordham stopped trading and our wage bill went up by a noticeable amount (c£50m). We also know UEFA discussed the Fordham arrangement with us in 2015.
My guess is that we weren't including it in the figures for player remuneration from 2013 to 2015 but did after that discussion with UEFA. I'd also guess that the c.£50m increase is about 3 or 4 years of the Fordham payments. That's complete speculation on my part but based on the amounts that seemed to be going through Fordham (which is difficult to see accurately as they didn't publish a P&L account). It's possible therefore that we 'transferred' the accumulated 2016-18 image rights payments back into our own books (but had reported it to UEFA after 2015 assuming we hadn't before).
That'd be my guess but, if I'm right you'd have to ask why UEFA didn't bring charges for that? On the surface failing to report around £15m a year (give or take a couple of million), might seem a pretty egregious breach of FFP. They almost certainly had us bang to rights, yet didn't charge us even after Der Spiegel had published the arrangement. It's possible that we argued it was an entirely personal payment to the players, which while clubs generally paid it directly, we'd legally assigned the rights to a third-party (Fordham), received a consideration for that and that it was a matter between Fordham and the players after that. That still begs the question, what did Fordham get out of it?
But UEFA's lawyers could have looked at it and thought that, while it was rather 'cute', it didn't actually break any rules and there was little or no prospect of successfully arguing the case (and they wouldn't have known about CAS at that point).
I've always said that the sponsorships/related party issue and the Mancini contract are red herrings, blind alleys, whatever you want ot call them but that Fordham was probably the most questionable. But if it was that questionable then I'm sure UEFA would have charged us, which is why I'd question the chances of the PL succeeding.
UEFA took 3 or 4 months from the publication of the Der Spiegel articles to the CFCB issuing the 2-season ban. The PL has taken over 4 years and come up with not very much. The haste with which they appeared to issue the charges, and the subsequent withdrawal of some because they'd completely messed up, plus the rumours that Levy was allegedly pressuring them just before they were issued, suggests to me they knew they had very little but decided to go ahead anyway, as it least it muddied the waters.