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annul Council Decision (CFSP) 2024/2456 of 12 September 2024 in so far as it maintains the applicant’s name on the list in the annex to Council Decision 2014/145/CFSP of 17 March 2014, as amended by Council Decision (CFSP) 2022/883 of 3 June 2022 including the applicant’s name in that annex;

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annul Council Implementing Regulation (EU) 2024/2455 of 12 September 2024 in so far as it maintains the applicant’s name on the list in Annex I to Regulation (EU) 269/2014, as amended by Regulation (EU) 2022/878 of 3 June 2022;

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in the alternative, declare unlawful the listing criterion provided for in Article 1(1)(e) and Article 2(1)(g) of Decision 2014/145/CFSP and in Article 3(1)(g) of Regulation (EU) 2014/269 as amended, respectively, by Council Decision (CFSP) 2023/1094 of 5 June 2023 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine and Council Regulation (EU) 2023/1089 of 5 June 2023 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine in so far as it concerns leading businesspersons operating in Russia or businesspersons, legal persons, entities or bodies involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine.

1.

First plea in law, alleging breach of the duty to state reasons and violation of the right to effective judicial protection.

2.

Second plea in law, alleging an error of assessment.

3.

Third plea in law, alleging breach of the principle of proportionality and violation of the fundamental rights of the applicant.

4.

In the alternative, fourth plea in law, based on the reservations made by the applicant on the legality of the first part of criterion (g) in so far as it establishes an irrebuttable presumption.