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Declare the action for annulment admissible and well founded;

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Annul the Decision of the Council dated 13 June 2025 (SGS 25 / 2281) refusing to transpose into the EU legal order the Implementation Assistance Notice No 1 of 7 March 2012, issued by the UN Security Council Committee established pursuant to Resolution 1970 (2011) concerning Libya;

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In the alternative, declare that the Council has infringed the Treaties, in breach of Article 265 TFEU, by failing to adopt a measure to amend or clarify Council Regulation (EU) 2016/44 following the applicant’s formal request of 11 March 2025;

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Order the Council to pay all the legal fees and costs.

1.

First plea in law, alleging infringement of the obligation to comply with binding UN Security Council Resolutions.

2.

Second plea in law, alleging infringement of the principle of good administration.

3.

Third plea in law, alleging infringement of the principle of proportionality.

4.

Fourth plea in law, alleging infringement of the principle of legal certainty.

5.

Fifth plea in law, alleging infringement of the obligation to review restrictive measures.

6.

Sixth plea in law, alleging manifest error of assessment.

7.

Seventh plea in law, alleging infringement of the principle of equal treatment.

8.

Eighth plea in law, alleging error of law.

9.

Alternatively, alleging a failure to act under Article 265 TFEU.