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annul Council Decision (CFSP) 2023/572 of 13 March 2023 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine; (1)

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annul Council Implementing Regulation (EU) 2023/571 of 13 March 2023 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine; (2)

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annul the Decision to maintain the applicant on the list of persons and entities subject to restrictive measures under Council Decision 2014/145/CFSP, (3) as amended by the Council Decision (CFSP) 2023/572, and Council Regulation (EU) No 269/2014, (4) as implemented by Council Implementing Regulation (EU) No 2023/571, adopted by the Council of the European Union by letter to the applicant of 14 March 2023;

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order the Council of the European Union to bear the costs of the present proceedings.

1.

First plea in law, alleging infringement of the obligation to state reasons, of Article 296 TFEU and of Article 41 (2)(c) of the Charter of Fundamental Rights of the European Union, as well as breach of the right to effective judicial protection and of Article 47 of the Charter of Fundamental Rights.

2.

Second plea in law, alleging manifest error of assessment, failure to discharge the burden of proof, breach of the listing criteria set forth in article 1(1)(a) and (e) and 2(1)(a) and (g) of Council Decision 2014/145/CFSP of 17 March 2014 and in Article 3(1)(a) and (g) of Council Regulation (EU) No 269/2014 of 17 March 2014.

3.

Third plea in law, alleging breach of the principle of proportionality, breach of the applicant’s fundamental rights to property and freedom to conduct business and breach of Articles 16 and 17 of the Charter of Fundamental Rights.