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declare Decision (CFSP) 2023/891 and Regulation (EU) 2023/888 to be unlawful;

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annul Council Decision (CFSP) 2023/1047 of 30 May 2023 in so far as it lists the applicant under No 3 of the annex to that decision;

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annul Implementing Regulation (EU) 2023/1045 of 30 May 2023 in so far as it lists the applicant under No 3 of Annex I to that regulation;

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order the Council to make a provisional payment of EUR 100 000 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, alleging that Decision (CFSP) 2023/891 and Regulation (EU) 2023/888 are unlawful. Decision (CFSP) 2023/891 and Regulation (EU) 2023/888, which purport to provide the criteria on the basis of which the applicant’s name was entered on the list at issue, are unlawful and, therefore, must be declared inapplicable on the basis of Article 277 TFEU. That plea of illegality is divided into three parts, alleging infringement of Articles 2, 8 and 21(1) TEU, the principles of proportionality and legal certainty and misuse of powers.

2.

Second plea, alleging infringement of the right to effective judicial protection and of the Council’s duty to state reasons. The applicant alleges that there has been a breach of her right to effective judicial protection and of the Council’s duty to state reasons, on the ground that the information provided by the Council does not enable her to defend herself. She submits that the Council’s statement of reasons does not enable her to understand how and why those criteria apply to her.

3.

Third plea, alleging a manifest error of assessment by the Council. The applicant submits that the Council committed a manifest error of assessment in finding that she had engaged in serious financial misconduct concerning public funds and had exported capital without being authorised to do so and that she had directed and planned violent demonstrations.

4.

Fourth plea, alleging infringement of the principle of proportionality and of fundamental rights. The applicant submits that, by adopting the restrictive measures against her, the Council disregarded the principle of proportionality and excessively infringed her fundamental rights.