While the Fan Club may be selling some leftovers from the cons, heres something to keep in mind:
The Fan Club had set aside a predetermined quantity of figures specifically for sale on the website, after the con season. They will be just as new as the ones available at the cons. They have a lot set aside for this soul purpose. Keep in mind though, case fresh by no means, especially with this figure, means a mint card. When I worked at GenCon, I opened up some mighty nice cases, and a few really bad ones, some with cards bent at 90 degree angles.
Any leftovers sold will be in good condition, as the Fan Club made it a point to send back any figures in poor condition. I expect there probably werent drones of leftovers though. Even then, most of the leftovers are going to be in unopened cases. Theoretically, they'd only have one open case leftover, the rest would be sealed. They only opened cases as they were needed, and just a case at a time. So if they stopped selling, you'd only have one extra open case (36 figures). Other open cases that were filled with bad figures would be sent back to Hasbro.
Does it guarantee you will get a mint figure? No, but the Fan Club will make it a strong point to try and give you the best quality merchandise possible.