—

annul the decision of the European Central Bank of 22 April 2024 establishing prudential requirements to reduce further the risks connected with the business of UniCredit SpA in Russia (Decision No ECB-SSM-2024-ITUNI-17) in its entirety;

—

in the alternative, annul the contested decision in part as regards the following individual requirements in particular:

—

order the ECB to pay the costs.

1.

First plea in law, alleging infringement of the principle of good administration due to a failure to investigate, infringement of the law and a consequent infringement of essential procedural requirements due to a failure to state reasons;

2.

Second plea in law, alleging infringement of the principle of good administration concerning the conflicting duties of the addressee and a consequential failure to state reasons;

3.

Third plea in law, alleging that the contested requirements were impossible to implement ab origine;

4.

Fourth plea in law, alleging infringement of the principle of proportionality and infringement of the applicant’s right to property and freedom to conduct a business;

5.

Fifth plea in law, alleging that the author of the contested decision did not have the power to issue that decision both ratione loci and in practical terms and an infringement of the law.