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annul Council Decision (CFSP) 2022/1530 (1) of 14 September 2022 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, as implemented by Council Implementing Regulation (EU) 2022/1529 (2) of 14 September 2022 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, to the extent that they concern Kesaev; cancel the extension of the individual sanctions in respect of Kesaev, and remove Kesaev from the list in Annex I to Regulation No 269/2014; (3)

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order the Council to pay the costs of the proceedings.

1.

First plea in law, alleging that the grounds for the applicant’s inclusion on the sanctions list is factually incorrect and/or irrelevant.

2.

Second plea in law, alleging that the applicant has never been heard or properly informed — violation of the right to a fair trial.

3.

Third plea in law, alleging that the inclusion of the applicant on the sanctions list is contrary to the Charter of Fundamental Rights of the European Union — infringement of Articles 6, 8, 16 and 17, in combination with Article 52 of the Charter.

4.

Fourth plea in law, alleging that the terminology used in Decision (CFSP) 2022/329 (4) is so vague that the application of the decision becomes arbitrary — breach of the principle of legal certainty.

5.

Fifth plea in law, alleging that the sanctioning is based on discrimination. People in comparable situations are not sanctioned, the applicant is sanctioned merely because he is a 1) rich, 2) politically neutral and 3) Russian businessman.

6.

Sixth plea in law, alleging that the Council must be ordered to pay the costs in any event, since the applicant felt obliged to institute the present proceedings because the Council has not yet acted on his request for review.