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primarily, declare unlawful the listing criterion laid down in Article 1(1)(e) and in Article 2(1)(g) of Decision 2014/145/CFSP, and in Article 3(1)(g) of Regulation (EU) 2014/269, in so far as it refers to ‘leading businesspersons operating in Russia and their immediate family members, or other natural persons, benefitting from them, or businesspersons 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’, and, consequently:

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in the alternative, as regards the other pleas in law raised by the applicant:

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order the Council to pay the costs.

1.

First plea in law, alleging illegality of criterion (g) laid down in Article 2(1) of Decision 2014/145.

2.

Second plea in law, alleging a manifest error of assessment.

3.

Third plea in law, alleging a breach of the right to effective judicial protection.

4.

Fourth plea in law, alleging failure to observe the principle of proportionality.

5.

Fifth plea in law, alleging a breach of the applicant’s fundamental rights.

6.

Sixth plea in law, alleging a breach of the right to be heard.