1.

First plea in law, alleging that the Council failed to identify a proper legal base. Article 29 TEU was not a proper legal base for the contested decision because the complaint made against the applicant did not identify him as an individual having undermined the rule of law or human rights in Ukraine (within the meaning of Articles 21(2) and 23 TEU). As the decision was invalid, the Council could not rely on Article 215(2) TFEU to enact the contested regulation. At the time that the restrictive measures were imposed, there was no charge against the applicant in the context of judicial proceedings that his activities threatened to undermine the rule of law, or violated any human rights in Ukraine. The restrictive measures in fact endorse a violation of the rule of law by the Ukrainian authorities in their treatment of the applicant.