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pursuant to Articles 263, 275(2) and 277 TFEU, declare the inapplicability of:

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either in combination with above, or alternatively, pursuant to Article 263 TFEU, annul Council Decision (CFSP) 2025/1895 amending Council Decision (CFSP) 2014/145 (1) as well as of the Council Implementing Regulation (EU) 2025/1894 implementing Regulation (EU) 269/2014, (2) in so far as those acts concern the Applicant (Listing Entry No. 174);

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order the Council to pay the costs pursuant to Article 134 of the Rules of Procedure.

1.

First plea in law, alleging that the application of EU secondary law in the case at hand infringes the Treaties and the rule of law: the contested listing criteria do not take into account a legitimate aim, they violate Article 215(3) TFEU and the principle of foreseeability.

2.

Second plea in law, alleging infringement of the applicant’s procedural rights: the Council did not notify the applicant of its decision to list it in advance. It did not give the applicant an opportunity to comment and did not review the listing.

3.

Third plea in law, alleging an error of assessment.

4.

Fourth plea in law, alleging that the applicant’s listing is inconclusive and disproportionate.

5.

Fifth plea in law, alleging infringement of the obligation to state reasons: the Council did not provide a legitimate reasoning for the listing of the applicant.