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annul Council Decision (CFSP) 2022/429 (1) of 15 March 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, in so far as it concerns the applicant;

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annul Council Implementing Regulation (EU) 2022/427 (2) of 15 March 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of the actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine in so far as it concerns the applicant;

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order the Council to pay the costs.

1.

First plea in law, alleging lack of legal basis for the criterion of ‘leading businesspersons involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the illegal annexation of Crimea and destabilisation of Ukraine’, on the grounds that no sufficient ties have been established between the category of individuals covered by this criterion and the Russian Federation.

2.

Second plea in law, alleging that the criterion of ‘leading businesspersons involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the illegal annexation of Crimea and destabilisation of Ukraine’ is unlawful due to two breaches of the principle of proportionality. The applicant is of the view, first, that the criterion relied by the Council is manifestly inappropriate in the light of the objective pursued and secondly that there was a possibility of having recourse to less restrictive measures.

3.

Third plea in law, alleging an error of assessment. The applicant claims that, first, none of the evidence relied on by the Council meets the requirements of EU case-law regarding the standard and quality of evidence and secondly, that none of the assertions of the Council’s reasoning are established and therefore cannot be characterised by the criteria under (d) and (g) of Decision 2014/145/CFSP in the version then in force.