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order the defendant to pay financial compensation in respect of the harm which the applicant has suffered as a result of the defendant’s decision to revoke the applicant’s license on 11 July 2016 (notified to the applicant on 13 July 2016);

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determine that the material damage amounts to at least EUR 162 million together with a compensatory interest starting at 11 July 2016 until delivery of the judgment in the present case and with corresponding default interest from the date of delivery of judgment until its payment in full; and

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order the defendant to pay the costs.

1.

First plea in law, alleging that the defendant failed to properly notify the licence withdrawal decision to the applicant’s authorized representatives.

2.

Second plea in law, alleging that the procedure leading to the licence withdrawal decision did not involve a proper representation of the applicant.

3.

Third plea in law, alleging that the licence withdrawal decision is vitiated by a number of other serious procedural irregularities.

4.

Fourth plea in law, alleging that the defendant acted outside its area of competence when issuing the licence withdrawal decision, in particular with regard to money laundering matters and the enforcement of national law.

5.

Fifth plea in law, alleging that the defendant erroneously assumed grounds for a licence withdrawal and provided an insufficient statement of reason in this regard.

6.

Sixth plea in law, alleging that defendant’s illegal conduct caused significant damage to the applicant, including as a result of the applicant’s liquidation.