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annul Council Decision (CFSP) 2022/397 (1) of 9 March 2022 in so far as it includes the applicant’s name on the list in Annex I to Council Decision (CFSP) 2014/145 of 17 March 2014;

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annul Council Implementing Regulation (EU) 2022/396 (2) of 9 March 2022 in so far as it includes the applicant’s name on the list in Annex I to Council Regulation (EU) No 2014/269 of 17 March 2014;

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order the Council to pay EUR 500 000 on a provisional basis in respect of the non-material damage suffered by the applicant;

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order the Council to pay the costs.

1.

First plea in law, alleging infringement of the right to effective judicial protection and the obligation to state reasons. The applicant submits, first of all, that the Council has not set out individual, specific and concrete reasons that would provide him with a sufficient indication of the validity of the restrictive measures taken against him. He considers that the contested decisions do not have a sufficiently solid factual basis and are based on grounds that are unsubstantiated and the cogency of which is only abstract. The applicant considers, next, that the Council has placed the burden on him to provide proof that the general facts alleged against him are not true, thus reversing the burden of proof, which is contrary to the most fundamental rights of the defence. Lastly, the applicant claims that the alleged grounds are insufficient and that there is no credible and substantive evidence in support of those grounds, and submits that that prevents an adequate judicial review of the lawfulness of the inclusion and maintenance of his name on the lists of persons subject to the restrictive measures in question.

2.

Second plea in law, alleging a manifest error of assessment, on the ground that the applicant does not exercise, and has not exercised, decisive influence over the company PJSC SIBUR Holding. Furthermore, the company PJSC SIBUR Holding is not a significant source of revenue for the Russian government and does not have close ties to it.

3.

Third plea in law, alleging infringement of the principle of proportionality and of equal treatment. The applicant submits that the grounds which allegedly justify the restrictive measures against him are discriminatory and disproportionate to the objective pursued by the Council.

4.

Fourth plea in law, alleging infringement of the applicant’s fundamental rights, namely the right to respect for property, the right to respect for his private and family life, the right of freedom to conduct a business and the right to the presumption of innocence.