Sports lawyer James Severn claims City are facing an uphill battle to prove their innocence after being found guilty.
Speaking to BBC Sport, Severn said: “City will need to identify a material error of law, principle or fact, or serious procedural unfairness, which materially affected the Commission’s decision.
“The Appeal Board nevertheless has broad powers to allow or dismiss the appeal, vary the decision or make any other order it considers appropriate.
“The bank statements, government records and contemporaneous payment documents could be powerful evidence if they establish a clear audit trail showing the disputed funds came from the Abu Dhabi government rather than the owners.
“However, if that evidence was already before the Commission, which nevertheless concluded that the arrangements were a sham, City will face an uphill struggle to demonstrate the finding was materially wrong.”