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annul Council Decision (CFSP) 2025/1495 (1) and Council Regulation (EU) 2025/1494 (2) (‘the contested acts’), in so far as they include the applicant’s vessel in Annex XVI of Council Decision 2014/512/CFSP (3) and in Annex XLII of Council Regulation (EU) No 833/2014 (4);

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order the Council to pay the applicant’s costs.

1.

First plea in law, alleging that the applicant’s vessel does not meet the criteria for being listed in the contested acts, and its inclusion in Annex XLII is unjustified in light of the criteria set out in Article 3s of Regulation No 833/2014.

The applicant’s vessel has not engaged in any action in contravention of the EU’s Price Cap, and Karabakh has been in compliance with IMO Resolution A.1192(33).

2.

Second plea in law, alleging that the absence of a statement of reasons and the failure to provide access to the evidence file infringe Article 296 TFEU and entail a violation of the applicant’s rights of defence.

The Council has failed to provide the applicant with the reasons and the evidence which supported the listing of Karabakh as an entity transporting Crude Oil that originate in Russia or are exported from Russia while practicing irregular and high-risk shipping practices as set out in the IMO Resolution A.1192(33), whether before the adoption of the contested acts or subsequently.

3.

Third plea in law, alleging that the listing of the applicant constitutes a disproportionate interference with the freedom to conduct a business, contrary to Articles 16 and 52 of the Charter of Fundamental Rights of the EU (‘the Charter’).

Its inclusion in the contested acts prevents Karabakh from accessing EU ports and receiving certain services from them, and has other collateral impacts on conducting business. It thus amounts to an unlawful restriction of the applicant’s freedom to conduct a business contrary to Articles 16 and 52 of the Charter.