Case T-345/25: Action brought on 26 May 2025 – Khan v Council
Date: 2025-05-26
Institutions: General Court
Subjects: EU restrictive measure, Russo-Ukrainian issue, economic sanctions, entrepreneur, holding company, international sanctions, natural person, shareholder








C_202504057EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2025/4057


28.7.2025






Action brought on 26 May 2025 – Khan v Council


(Case T-345/25)

(C/2025/4057)
Language of the case: French

Parties


Applicant: German Khan (London, United Kingdom) (represented by: T. Marembert and A. Bass, lawyers)

Defendant: Council of the European Union

Form of order sought

The applicant claims that the Court should:






—


annul Council Decision (CFSP) 2025/528 of 14 March 2025 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;










—


annul Council Implementing Regulation (EU) 2025/527 of 14 March 2025 implementing Regulation (EU) 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 the applicant;










—


ask the Council to specify the nature of the documents in its possession establishing the following facts and indicate the date on which those facts were disclosed to the Council:






—


the application of the so-called ‘ESO’ Law to the Russian holding company of ALFA BANK;










—


the application of the so-called ‘ESO’ Law to the Russian holding company of ALFASTRAKHOVANIE;










—


the breaking-off of business relations between X5 Group and the company VOENTORG RETAIL LLC; and














—


order the Council to pay the costs.





Pleas in law and main arguments

In support of the action, the applicant relies on 15 pleas in law.






1.


First plea in law, alleging infringement of essential procedural requirements and failure to comply with the obligation of periodic review.










2.


Second plea in law, alleging error of assessment in relation to criterion (d). The applicant claims, in that regard, that he does not have ‘[maintain] a close relationship with President Putin, similarly to his business partners, Mikhail Fridman [and] Petr Aven’’, and that at no time did he ‘[exchange] favours with … Vladimir Putin, in return for political support to his business and financial gains’.’.










3.


Third plea in law, alleging error of assessment in relation to criterion (d). The applicant claims that his presence at a conference in March 2023 cannot constitute, a fortiori two years later, material or financial support for Russian decision-makers.










4.


Fourth plea in law, alleging error of assessment in relation to criterion (d). According to the applicant, all of the claims relating to the company AlfaStrakhovanie are incorrect, since the applicant no longer has any ties to that company.










5.


Fifth plea in law, alleging error of assessment in relation to criterion (d). The applicant submits that the claim that ‘the insurance company AlfaStrakhovanie, which is part of Alfa Group Consortium, provides insurance to the vehicles of the Federal Service of the National Guard of the Russian Federation (Rosgvardia), whose units operate in the occupied regions of Ukraine under Russian control’ is incorrect.










6.


Sixth plea in law, alleging error of assessment in relation to criterion (a). The applicant submits that the claim that ‘AlfaStrakhovanie has also provided insurance to companies such as the JSC Kalashnikov Concern and the Central Scientific-Research Institute for Precision Machine Engineering (TsNIITochMash), whose weapons are widely used by the Russian military in Ukraine, including during the atrocities in Bucha’ is incorrect.










7.


Seventh plea in law, alleging error of assessment in relation to criterion (d). The applicant submits that the claim that ‘the insurance company AlfaStrakhovanie … provides insurance … for the bodyguard vehicles of the President of the Russian Federation, Vladimir Putin’ is incorrect.










8.


Eighth plea in law, alleging error of assessment in relation to criterion (a). The applicant submits that the claim that ‘X5 Retail Group, another subsidiary of Alfa Group Consortium, cooperates with JSC Voentorg’ is incorrect.










9.


Ninth plea in law, alleging error of assessment in relation to criterion (g) (leading businessperson). According to the applicant, the Council has failed to establish that he is a ‘leading’ businessperson.










10.


Tenth plea in law, alleging error of assessment in relation to criterion (g). The applicant submits that the claim that ‘[since] [this] transfer [of the applicant’s shares in the Luxembourg company ABHH] was … declared by the National Bank of Ukraine to be null and void, he continues to be regarded as one of the main shareholders in ABH Holdings’ is incorrect.










11.


Eleventh plea in law, alleging error of assessment in relation to criteria (d) and (g). The applicant submits that the claim in relation to the company A1 is incorrect and can in no way justify the application of the criteria referred to.










12.


Twelfth plea in law, alleging error of assessment in relation to criterion (g) (leading businessperson and businessperson involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation). The applicant submits that the claim that ‘Khan also has a significant shareholding in Rosvodokanal …’ is incorrect.










13.


Thirteenth plea in law, alleging error of assessment in relation to criterion (g). According to the applicant, his past shareholding in the company LetterOne is irrelevant.










14.


Fourteenth plea in law, alleging error of assessment in relation to criterion (g). The applicant submits that the claim that the applicant ‘continued to manage the Russia-based assets of Alfa Group’ is incorrect.










15.


Fifteenth plea in law, alleging error of assessment in relation to criterion (g) (leading businessperson). The applicant submits that the claim that the applicant is ‘one of the most influential persons in Russia’ is incorrect.






ELI: http://data.europa.eu/eli/C/2025/4057/oj
ISSN 1977-091X (electronic edition)