JUDGMENT OF THE GENERAL COURT (Fifth Chamber)

24 September 2025 (*)

( Common foreign and security policy – Restrictive measures taken in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine – Freezing of funds – Restrictions on admission to the territory of the Member States – List of persons, entities and bodies subject to the freezing of funds and economic resources or to restrictions on admission to the territory of the Member States – Maintenance of the applicant’s name on the list – Obligation to state reasons – Error of assessment )

In Case T‑238/24,

Bogoljub Karić, residing in Belgrade (Serbia), represented by W. Julié, A. Beauchemin, T. Marembert and A. Bass, lawyers,

applicant,

v

Council of the European Union, represented by L. Berger and T. Haas, acting as Agents, and by B. Maingain, lawyer,

defendant,

THE GENERAL COURT (Fifth Chamber),

composed, at the time of the deliberations, of J. Svenningsen, President, J. Laitenberger and M. Stancu (Rapporteur), Judges,

Registrar: I. Kurme, Administrator,

having regard to the written part of the procedure,

further to the hearing on 25 March 2025,

gives the following

Judgment

1        By his action under Article 263 TFEU, the applicant, Mr Bogoljub Karić, seeks the annulment, in so far as those acts concern him, of Council Decision (CFSP) 2024/769 of 26 February 2024 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (OJ L, 2024/769) and of Council Implementing Regulation (EU) 2024/768 of 26 February 2024 implementing Article 8a of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (OJ L, 2024/768) (together, ‘the contested acts’).

 Background to the dispute

2        The applicant is a Serbian businessman and politician.

3        The present case has been brought in the context of the restrictive measures adopted by the European Union, since 2004, in view of the situation in Belarus with regard to democracy, the rule of law and human rights and also, since 2022, in view of the involvement of Belarus in the Russian aggression against Ukraine. As is apparent from the recitals of Council Implementing Decision (CFSP) 2022/881 of 3 June 2022 implementing Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (OJ 2022 L 153, p. 77) and of Council Implementing Regulation (EU) 2022/876 of 3 June 2022 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (OJ 2022 L 153, p. 1) (together, ‘the initial acts’), and the recitals of the contested acts, the case is more specifically linked to the gravity of the situation in Belarus and to the involvement of Belarus in Russia’s aggression against Ukraine, which was deemed a blatant violation of the territorial integrity, sovereignty and independence of that State.

4        On 18 May 2006, the Council of the European Union adopted, under Articles 75 and 215 TFEU, Regulation (EC) No 765/2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus (OJ 2006 L 134, p. 1). On 15 October 2012, under Article 29 TEU, it adopted Decision 2012/642/CFSP concerning restrictive measures against Belarus (OJ 2012 L 285, p. 1).

5        The criterion on the basis of which the restrictive measures were taken against the applicant (‘the listing criterion at issue’) is laid down in Article 3(1)(b) and Article 4(1)(b) of Decision 2012/642 and in Article 2(5) of Regulation No 765/2006, in the versions thereof in force at the time when the contested acts were adopted.

6        Article 3(1)(b) of Decision 2012/642 provides for the prohibition on entry into, and transit through, the territory of the European Union for persons benefitting from or supporting the regime of President Lukashenko.

7        Article 4(1)(b) of Decision 2012/642 and Article 2(5) of Regulation No 765/2006 – the latter provision referring to the former – provide for the freezing of all funds and economic resources of natural or legal persons, entities or bodies benefitting from or supporting the regime of President Lukashenko, and of legal persons, entities or bodies owned or controlled by them.

8        By the initial acts, the applicant’s name was included on the lists of persons, entities and bodies subject to the restrictive measures set out in the annex to Decision 2012/642 and in Annex I to Regulation No 765/2006 (together, ‘the lists at issue’).

9        In those acts, the Council justified the adoption of restrictive measures against the applicant by identifying him as a ‘Serbian businessman and politician, associated with the company Dana Holdings’ and giving the following reasons:

‘Bogoljub Karić is a Serbian businessman and politician. Together with his family members, he developed a network of real estate companies in Belarus and has cultivated a network of contacts with the family of [President Lukashenko].

In particular, he has been closely associated with Dana Holdings and its former subsidiary Dana Astra, and he reportedly represented those entities during meetings with [President Lukashenko].

The Minsk World project, which was developed by a company associated with Karić, was described by [President Lukashenko] as “an example of cooperation of the Slavonic world”.

Thanks to those close relationships with [President Lukashenko] and his entourage, companies associated with Karić received preferential treatment from the [regime of President Lukashenko], including tax breaks and plots of land for real estate development.

He is therefore benefitting from and supporting the [regime of President Lukashenko].’

10      The evidence in support of the grounds for including the applicant’s name on the lists at issue was, moreover, set out in documents WK 5817/2022 INIT, WK 5817/2022 ADD 1, WK 6656/2022 EXT 1 and WK 6656/2022 ADD 1.

11      On 24 February 2023, the Council adopted Decision (CFSP) 2023/421 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (OJ 2023 L 61, p. 41) and Implementing Regulation (EU) 2023/419 implementing Article 8a of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (OJ 2023 L 61, p. 20), (together, ‘the first set of maintaining acts’), by which the inclusion of the applicant’s name on the lists at issue was maintained until 28 February 2024 on the same grounds as those justifying the adoption of the initial acts, referred to in paragraph 9 above. Additional evidence was set out in document WK 17511/2022 INIT.

12      The applicant brought an action, registered as Case T‑520/22, against the initial acts and the first set of maintaining acts, in so far as those acts concerned him. That action was dismissed by judgment of 6 November 2024, Karić v Council (T‑520/22, not published, under appeal, EU:T:2024:774).

13      By letter of 21 December 2023, the Council notified the applicant of its intention to maintain his name on the lists at issue and sent him document WK 16887/2023 INIT. The Council also gave the applicant the opportunity to submit observations by 12 January 2024.

14      By letter of 12 January 2024, the applicant submitted his observations, challenging the merits of maintaining his name on the lists at issue, and asked the Council to reconsider its decision.

15      By letter of 26 January 2024, the Council forwarded additional evidence to the applicant, set out in Documents WK 16887/2023 ADD 1, WK 735/2024 INIT and WK 735/2024 ADD 1.

16      By letter of 8 February 2024, the applicant submitted his observations.

17      On 26 February 2024, the Council adopted the contested acts, by way of which the restrictive measures against the applicant were extended to 28 February 2025. In those acts, the Council justified the extension of those measures by reproducing all the reasons contained in the initial acts and the first set of maintaining acts (see paragraphs 9 and 11 above).

18      By letter of 29 February 2024, the Council informed the applicant of its decision to maintain his name on the lists at issue pursuant to the contested acts and replied to his observations.

 Forms of order sought

19      The applicant claims that the Court should:

–        annul the contested acts in so far as they concern him;

–        order the Council to pay the costs.

20      The Council contends that the Court should:

–        dismiss the action as unfounded;

–        order the applicant to pay the costs;

–        in the alternative, should the Court annul the contested acts in so far as they concern the applicant, order that the effects of Decision 2024/769 be maintained until the annulment in part of Implementing Regulation 2024/768 takes effect.

 Law

21      In support of his action, the applicant raises two pleas in law alleging, first, infringement of the right to effective judicial protection and of the obligation to state reasons and, secondly, errors of assessment.

 First plea in law: infringement of the right to effective judicial protection and of the obligation to state reasons

22      By means of his first plea, the applicant claims that the Council infringed his right to effective judicial protection and the obligation to state reasons, since the statement of reasons for the contested acts does not allow him to determine which listing criterion the Council relied on to justify maintaining the restrictive measures against him or to understand the actual and specific reasons for which his name was maintained on the lists at issue.

23      Concerning the applicable listing criterion, the applicant argues, first, that the statement of reasons for the contested acts is confusing inasmuch as, on the one hand, it expressly refers to the listing criterion at issue laid down in Article 3(1)(b) and Article 4(1)(b) of Decision 2012/642, by stating that the applicant is benefitting from and supporting the regime of President Lukashenko, but, on the other, it mirrors the language used by the Council when deciding to sanction individuals or entities on the basis of their association with sanctioned persons, under the listing criterion laid down in Article 3(1)(a) and Article 4(1)(a) of Decision 2012/642, by also referring to his association with companies, in particular Dana Holdings and its former subsidiary Dana Astra, which are themselves subject to restrictive measures. At the hearing, the applicant also relied on the introduction, with effect from June 2024, of a new listing criterion, first of all in Article 4(1)(f) of Decision 2012/642 and then in Article 3(1)(e) thereof, targeting, inter alia, persons associated with persons, entities or bodies subject to restrictive measures on the ground that they benefit from or support the regime of President Lukashenko (‘the new listing criterion’). He maintains that the factual elements referred to in the reasons for the contested acts are more closely related to such a criterion than to the listing criterion at issue on which the Council relied in order to adopt the contested acts.

24      Secondly, the applicant takes issue with the Council for having referred, in the statement of reasons for the contested acts, to the listing criterion at issue laid down in Article 3(1)(b) and Article 4(1)(b) of Decision 2012/642, by stating that he benefits from and supports the regime of President Lukashenko, without however specifying to which part of that criterion – relating to the ‘benefit’ derived from and the ‘support’ provided to that regime – each of the factual elements set out in that statement of reasons related.

25      As regards the actual and specific reasons for including his name on the lists at issue, the applicant submits that the statement of reasons for the contested acts consists of vague assertions that continue to generate confusion as to the reasons for including his name on the lists at issue.

26      Thus, first, the applicant maintains that the Council has not specifically identified the companies with which he is allegedly associated, the nature of his association with those companies, or how he benefits from or supports the regime of President Lukashenko personally through those companies.

27      Secondly, as regards the Minsk World project, aimed at developing the Minsk-City multifunctional centre in Minsk (Belarus), and the preferential treatment which the entities tasked with the development of that project allegedly received from the regime of President Lukashenko, the Council does not, it is argued, name the company involved in the project or state whether the applicant is personally involved in that project.

28      Thirdly, the applicant complains that the nature of the relationships through which or the identity of the persons through whom he allegedly benefitted from or supported the regime of President Lukashenko are not apparent from the statement of reasons.

29      The Council disputes that line of argument.

30      According to settled case-law, the right to effective judicial protection, enshrined in Article 47 of the Charter of Fundamental Rights of the European Union, requires that the person concerned must be able to ascertain the reasons upon which the decision taken in relation to him or her is based, either by reading the decision itself or by requesting and obtaining disclosure of those reasons (see judgment of 18 July 2013, Commission and Others v Kadi, C‑584/10 P, C‑593/10 P and C‑595/10 P, EU:C:2013:518, paragraph 100 and the case-law cited).

31      It should be recalled that, according to settled case-law, the purpose of the obligation to state the reasons on which an act adversely affecting an individual is based, which is a corollary of the principle of respect for the rights of the defence, is, first, to provide the person concerned with sufficient information to make it possible to ascertain whether the act is well founded or whether it is vitiated by a defect which may permit its legality to be contested before the Courts of the European Union and, secondly, to enable those Courts to review the legality of that act (see judgment of 16 December 2020, Haswani v Council, T‑521/19, not published, EU:T:2020:608, paragraph 109 and the case-law cited).

32      In addition, the statement of reasons required by Article 296 TFEU must be appropriate to the act at issue and must disclose in a clear and unequivocal fashion the reasoning followed by the institution which adopted the act in such a way as to enable the person concerned to ascertain the reasons for the act and to enable the court having jurisdiction to exercise its power of review (see judgment of 16 December 2020, Haswani v Council, T‑521/19, not published, EU:T:2020:608, paragraph 110 and the case-law cited).

33      The statement of reasons for an act of the Council which imposes a measure freezing funds must identify the actual and specific reasons why the Council considers, in the exercise of its discretion, that that measure must be adopted in respect of the person concerned (see judgment of 16 December 2020, Haswani v Council, T‑521/19, not published, EU:T:2020:608, paragraph 111 and the case-law cited).

34      However, the requirement that reasons be given must be assessed in the light of the circumstances of the case, and in particular the content of the act in question, the nature of the reasons relied on and the interest which addressees will have in obtaining explanations. It is not necessary for the reasoning to go into all the relevant facts and points of law, since the question whether the statement of reasons for an act meets the requirements of Article 296 TFEU must be assessed with regard not only to its wording but also to its context and to all the legal rules governing the matter in question. In particular, the reasons given for an act adversely affecting a person are sufficient if that act was adopted in circumstances known to that person which enable him or her to understand the scope of the measure concerning him or her (see judgment of 16 December 2020, Haswani v Council, T‑521/19, not published, EU:T:2020:608, paragraphs 112 to 114 and the case-law cited).

35      Lastly, it must be borne in mind that the obligation to state reasons provided for in Article 296 TFEU is an essential procedural requirement, as distinct from the question whether the reasons given are well founded, which goes to the substantive legality of the act at issue. The reasoning for a decision consists in a formal statement of the grounds on which that decision is based. If those grounds are vitiated by errors, those errors will vitiate the substantive legality of the decision, but not the statement of reasons in it, which may be adequate even though it sets out reasons which are incorrect (see judgment of 11 September 2024, Mordashova v Council, T‑497/22, not published, EU:T:2024:604, paragraph 52 and the case-law cited).

36      In the present case, in the first place, it must be noted that the general context surrounding the adoption of the contested acts was known to the applicant.

37      In that regard, it should be pointed out that the contested acts merely renewed, as regards the applicant, restrictive measures previously imposed by the initial acts and the first set of maintaining acts and that the reasons underlying the adoption of those measures were not amended by the contested acts (see paragraph 17 above). Moreover, the general context that prompted the Council to adopt the contested acts is clearly set out in the recitals of those acts, which refer to the ‘persistent gravity of the situation in Belarus’ and the ‘involvement of Belarus in the illegal aggression of the Russian Federation against Ukraine’, which resulted in the restrictive measures imposed on that country being extended to cover persons and entities benefitting from or supporting the regime of President Lukashenko.

38      In the second place, it should be observed that, contrary to what the applicant claims, the statement of reasons for the contested acts, as set out in paragraph 9 above, clearly and unequivocally specifies the criterion relied on to maintain his name on the lists at issue and the actual and specific reasons justifying such maintenance.

39      In that statement of reasons, the conclusion that the applicant ‘is benefitting from and supporting the regime of [President Lukashenko]’ refers explicitly to the listing criterion at issue, referred to in paragraphs 5 to 7 above, from which it is clear that natural or legal persons, entities or bodies that have been identified by the Council as benefitting from or supporting the regime of President Lukashenko are included on the lists at issue. As for the relevance and appropriateness of that criterion in the light of the factual elements set out in the statement of reasons for the contested acts, in particular those relating to his association with companies subject to restrictive measures, it must be found that, in accordance with the case-law cited in paragraph 35 above, that question goes to the merits of the restrictive measures adopted against the applicant and not to the formal statement of reasons for those measures. As such, it will be dealt with in the second plea, alleging errors of assessment.

40      Furthermore, such a statement of reasons sets out the actual and specific reasons why the applicant is considered to be a person benefitting from and supporting the regime of President Lukashenko. Thus, it is claimed that the applicant, together with his family members, developed a network of real estate companies in Belarus and cultivated a network of contacts with President Lukashenko, enabling companies with which the applicant is associated to receive preferential treatment from the regime of President Lukashenko, such as tax breaks and plots of land for real estate development. It is stated to that effect that the applicant is closely associated with Dana Holdings and its former subsidiary Dana Astra, that he represented those companies during meetings with President Lukashenko, and that the Minsk World project, in which those companies are involved, was described by President Lukashenko as ‘an example of cooperation of the Slavonic world’. Such a statement of reasons enables the applicant sufficiently to understand that his name was maintained on the lists at issue not on the ground that the companies with which he was associated were already included on the lists at issue, but rather on account of his own conduct and activities as a businessman in Belarus, in particular in the real estate sector, and of his contacts with the family of President Lukashenko. The findings set out in the statement of reasons on which the Council relies vis-à-vis the applicant are intended to describe the latter’s actual situation and are consequently sufficient (see judgment of 2 December 2020, Kalai v Council, T‑178/19, not published, EU:T:2020:580, paragraph 64 and the case-law cited).

41      In addition, it must be stated that the applicant was in a position effectively to challenge the merits of maintaining his name on the lists at issue by way of the contested acts, as demonstrated by his arguments in support of the second plea, alleging errors of assessment.

42      In those circumstances, it must be concluded that the reasons for the contested acts are stated to the requisite legal standard.

43      That finding is not called into question by the other arguments put forward by the applicant.

44      In the first place, as regards the applicant’s argument that the Council failed to fulfil its obligation to specify to which part of the listing criterion at issue – relating to the ‘benefit’ derived from and the ‘support’ provided to the regime of President Lukashenko – each of the factual elements set out in the statement of reasons related, it must be observed that, admittedly, the maintenance of the applicant’s name on the lists at issue is based, first, on the ‘benefit’ derived from the regime of President Lukashenko and, secondly, on the ‘support’ provided to it, which constitute two separate criteria for inclusion on the lists at issue, as is apparent from Article 3(1)(b) and Article 4(1)(b) of Decision 2012/642 (see, to that effect, judgment of 27 September 2017, BelTechExport v Council, T‑765/15, not published, EU:T:2017:669, paragraph 92). It should also be noted that the Council did not identify which of the factual elements mentioned in the statement of reasons related specifically to the ‘benefit’ derived from the regime of President Lukashenko or to the ‘support’ provided to it.

45      However, in that connection, it must be borne in mind that it cannot be ruled out that, for a specific person, the grounds for listing may overlap to a certain extent and may be used to substantiate several separate criteria (see, by analogy, judgment of 18 May 2022, Foz v Council, T‑296/20, EU:T:2022:298, paragraphs 82 and 84).

46      Accordingly, the Council was therefore entitled to rely, in the reasons for the contested acts, on the same factual elements in order to substantiate each of the two parts of the listing criterion at issue relating to the ‘benefit’ derived from the regime of President Lukashenko, on the one hand, and to the ‘support’ provided to it, on the other.

47      As for whether those factual elements are actually relevant to both parts of the listing criterion at issue, suffice it to note that, in accordance with the case-law cited in paragraph 35 above, that question goes to the merits of the reasons relied on against the applicant and will be dealt with in the second plea, alleging errors of assessment.

48      In the second place, in so far as concerns the applicant’s argument that, in the statement of reasons for the contested acts, the Council failed to provide sufficient information about the identity of the companies with which he is allegedly associated or the nature of the ties between him and those companies, it should be observed, first of all, that the reasons for the contested acts specifically identify the applicant as a businessman associated with, inter alia, Dana Holdings and its former subsidiary Dana Astra. Furthermore, it is easy to understand from an overall reading of those reasons, set out in paragraph 9 above, that the companies referred to as those with which the applicant is associated are, inter alia, Dana Holdings and its former subsidiary Dana Astra, both of which are repeatedly referred to by name. Finally, and in any event, even if those reasons were to be understood as meaning that the network of real estate companies in Belarus which the applicant, it is claimed, developed with his family members and with which he is associated is not confined to Dana Holdings and Dana Astra, the fact that those reasons do not contain an exhaustive list of the companies with which the applicant is said to be associated is not sufficient to support the finding that the contested acts are vitiated by an inadequate statement of reasons such as to lead to the annulment of those acts, since the elements relating to Dana Holdings and Dana Astra and the applicant’s close association with those companies have been put forward in a sufficiently specific and precise manner in the statement of reasons for the contested acts (see, by analogy, judgment of 22 June 2022, Haswani v Council, T‑479/21, not published, EU:T:2022:383, paragraph 73 and the case-law cited).

49      As regards the nature of the ties between the applicant and those companies, it should be noted, next, that the Council states, in the reasons for the contested acts, that the applicant is ‘closely associated with Dana Holdings and its former subsidiary Dana Astra’. It is true that the Council does not specifically state whether the network of real estate companies in Belarus which the applicant purportedly developed with his family members and with which he is said to be associated goes beyond Dana Holdings and Dana Astra, nor does it explain in detail the nature of his association with those companies. However, as stated in paragraph 34 above, according to the case-law, it is not necessary for the reasoning to go into all the relevant facts and points of law or to provide a detailed answer to the considerations set out by the person concerned when consulted prior to the adoption of the act. In any event, it is clear from an overall reading of the reasons for the contested acts that the Council claims that the applicant is associated with Dana Holdings and its former subsidiary Dana Astra in a way that goes beyond a mere family relationship with the directors of those entities. In that regard, it should be borne in mind that the concept of ‘association’ is often used in acts of the Council relating to restrictive measures, including in the reasons underlying the adoption of those acts, and that it has been recognised in the case-law that such a concept makes it possible to target natural or legal persons who are, generally, linked by common interests (see, to that effect and by analogy, judgment of 8 March 2023, Prigozhina v Council, T‑212/22, not published, EU:T:2023:104, paragraph 93 and the case-law cited).

50      In the third place, concerning the applicant’s argument that, in the statement of reasons for the contested acts, the Council did not specify, as regards the Minsk World project and the preferential treatment which the entities tasked with the development of that project allegedly received from the regime of President Lukashenko, either the name of the company involved in that project or whether the applicant was personally involved in it, suffice it to note that the reasons for the contested acts state that ‘the Minsk World project [is] developed by a company associated with [the applicant]’. As stated in paragraph 48 above, the applicant was able – from an overall reading of the reasons for the contested acts – to ascertain that the companies with which he is associated are, in particular, Dana Holdings and its former subsidiary Dana Astra, so that the applicant was in a position to identify the entity tasked with developing the Minsk World project. In addition, since the applicant is associated, in the reasons for the contested acts, with the companies tasked with the development of that project, there is no doubt that he is also considered to be involved, on account of that association, in the conduct of the project.

51      In the fourth place, regarding the applicant’s argument that the statement of reasons for the contested acts does not explain the nature of the relationships through which or the identity of the persons through whom the applicant allegedly benefitted from and supported the regime of President Lukashenko, it should be observed, first of all, that the reasons for the contested acts expressly refer to relationships between the applicant himself and several members of his family, on the one hand, and President Lukashenko and his entourage, on the other, which enabled companies with which he is closely associated, in particular Dana Holdings and Dana Astra, to receive preferential treatment from that regime (see paragraph 9 above).

52      Such reasons enable the applicant to ascertain that the relationships through which he allegedly benefitted from and supported the regime of President Lukashenko, first, are not limited to the ties which he personally forged with President Lukashenko but also include the ties established by members of his family, who also helped cultivate a network of contacts with President Lukashenko himself and his entourage, and, secondly, concern his involvement in a number of companies engaged in real estate development in Belarus and therefore his status as a businessman in Belarus and his activities in the real estate sector.

53      It is true that, in the reasons for the contested acts, the Council does not specify the identity of the applicant’s family members involved in dealings with the regime of President Lukashenko or the identity of the persons in President Lukashenko’s entourage who took part in such dealings.

54      However, in that regard, it must be borne in mind that, according to the case-law, it is not necessary for the reasoning to go into all the relevant facts and points of law (see paragraph 34 above).

55      In addition, it must be pointed out that, in his written pleadings, the applicant himself states that members of his family, in particular his children, were involved in a number of companies engaged in real estate development in Belarus. He also does not deny the existence of certain ties between his brother and his wife, on the one hand, and President Lukashenko and his family, including President Lukashenko’s daughter-in-law, on the other.

56      Given the diverse and multifaceted nature of the relationships and the persons concerned, the Council was entitled to refer in the contested acts, in a general manner, to the applicant’s family members and to President Lukashenko’s family and entourage, so as to cover the entire network of contacts between the applicant and his family, on the one hand, and President Lukashenko and his entourage, on the other.

57      In the light of the foregoing, the first plea in law must be rejected as unfounded.

 Second plea in law: errors of assessment

58      In his second plea in law, the applicant claims that the reasons for the contested acts, in so far as they concern him, are vitiated by errors of assessment and cannot justify maintaining his name on the lists at issue.

59      In the first place, the applicant argues that, since the initial inclusion of his name on the lists at issue, the reasons underlying the adoption of the restrictive measures against him have not changed, nor has the evidence used to support the adoption of such measures. In particular, the evidence adduced by the Council in support of the adoption of the contested acts does not include a single new or recent factual element, but instead continues to refer, in essence, to the same allegations concerning past events. The applicant also disputes the relevance of the new items of evidence submitted by the Council to demonstrate that the maintenance of his name on the lists at issue is still justified, in so far as that evidence does not mention him by name.

60      In the second place, the applicant submits that the Council erred in its assessment of the facts by considering that he benefits from or supports the regime of President Lukashenko.

61      First, the applicant disputes the assessment that he is and remains associated with companies in Belarus, in particular Dana Holdings and its former subsidiary Dana Astra, which are expressly mentioned in the statement of reasons for the contested acts.

62      In that connection, he maintains, first of all, that he has never been and is not currently involved in any company in Belarus. With regard to Dana Holdings and its subsidiaries, including Dana Astra, the applicant states that he does not own, hold or manage any of the entities mentioned in the reasons for the contested acts. The applicant submits that those companies were owned and managed by his children until the end of 2020, at which point they were sold, their current owner being a company established in the United Arab Emirates. The only link between him and those companies is therefore his parent-child relationship with the owners of those entities. Although the applicant acknowledges having publicly supported Dana Holdings and its subsidiaries, in particular through his social media accounts, he argues that that is not sufficient to establish any involvement in or association with those entities, since it does not prove anything other than his pride in the business endeavours of his children.

63      Next, the applicant denies having represented such companies during meetings with President Lukashenko. The applicant thus argues that the evidence produced by the Council refers to only one meeting with President Lukashenko, on 22 June 2015, in which he is said to have participated personally. Furthermore, he denies that he met with President Lukashenko that same day as a representative of Dana Holdings and submits that he was involved in that meeting in his capacity as a member of an official delegation of Serbian businesspersons and politicians. As for the other meetings with President Lukashenko, to which several items of evidence produced by the Council refer, the applicant states that he did not take part in those meetings, unlike his brother.

64      Secondly, the applicant disputes the Council’s claims that he developed a network of contacts with the family of President Lukashenko.

65      In that connection, the applicant states, first of all, that he participated in only one meeting, on 22 June 2015, in which President Lukashenko also took part.

66      With regard, next, to the alleged ties with persons close to President Lukashenko, in particular the latter’s daughter-in-law, the applicant asserts that neither the trips claimed by the Council nor the fact that President Lukashenko’s daughter-in-law was employed by Dana Astra and continues to manage an art gallery located in a shopping centre serve to establish that the applicant supported or benefitted from the regime of President Lukashenko. Such circumstances relate to past and outdated events and, at most, demonstrate a degree of proximity to persons close to President Lukashenko; they are certainly not proof of a benefit derived from or of support provided to the latter’s regime. The applicant states that, according to the case-law, neither friendly ties nor the hiring of someone close to President Lukashenko are sufficient to demonstrate the existence of a benefit derived from or of support provided to the regime.

67      Thirdly, the applicant argues that the Council cannot validly take the view that he personally benefitted from and personally supported the regime of President Lukashenko, in the light of the preferential treatment and advantages granted to companies with which he is said to be associated. In that connection, the applicant asserts that the listing criterion at issue allows restrictive measures to be taken against a natural person only if that person personally benefits from or personally supports the regime of President Lukashenko, and that that criterion does not allow such measures to be taken against a person on the ground that he or she is in some way associated with another person or entity already subject to restrictive measures. The applicant states that the Council has not sufficiently explained how, even indirectly, he personally benefits from or personally supports the regime of President Lukashenko. In particular, given that he has never been involved in the companies mentioned in the reasons for the contested acts or exerted any influence over those companies, he cannot be regarded, on the basis of the advantages granted to those entities, as someone who personally benefitted from or personally supported the regime of President Lukashenko. At the hearing, the applicant also relied on the recent introduction of the new listing criterion, referred to in paragraph 23 above, and states that the factual elements set out in the reasons for the contested acts are more closely related to such a criterion than to the listing criterion at issue on which the Council relied in order to adopt the contested acts.

68      The Council disputes the applicant’s arguments.

 Preliminary observations

69      It should be borne in mind, in the first place, that the effectiveness of the judicial review guaranteed by Article 47 of the Charter of Fundamental Rights requires inter alia that, as part of the review of the lawfulness of the grounds which are the basis of the decision to include or to maintain the name of a person or entity on the lists of persons subject to restrictive measures, the Courts of the European Union are to ensure that that decision, which affects that person or entity individually, is taken on a sufficiently solid factual basis. That entails a verification of the factual allegations in the statement of reasons underpinning that decision, with the consequence that judicial review cannot be restricted to an assessment of the cogency in the abstract of the reasons relied on, but must concern whether those reasons, or, at the very least, one of those reasons, deemed sufficient in itself to support that decision, are substantiated (see, to that effect, judgment of 18 July 2013, Commission and Others v Kadi, C‑584/10 P, C‑593/10 P and C‑595/10 P, EU:C:2013:518, paragraph 119).

70      It is the task of the competent EU authority to establish, in the event of challenge, that the reasons relied on against the person or entity concerned are well founded, and not the task of that person or entity to adduce evidence of the negative, that those reasons are not well founded (see, to that effect, judgment of 18 July 2013, Commission and Others v Kadi, C‑584/10 P, C‑593/10 P and C‑595/10 P, EU:C:2013:518, paragraph 121).

71      If the competent EU authority provides relevant information or evidence, the Courts of the European Union must then determine whether the facts alleged are made out in the light of that information or evidence and assess the probative value of that information or evidence in the circumstances of the particular case and in the light of any observations submitted in relation to them by, among others, the person or entity concerned (see, to that effect, judgment of 18 July 2013, Commission and Others v Kadi, C‑584/10 P, C‑593/10 P and C‑595/10 P, EU:C:2013:518, paragraph 124).

72      That assessment must be carried out by examining the evidence and information not in isolation but in their context. The Council discharges its burden of proof if it presents to the Courts of the European Union a sufficiently specific, precise and consistent body of evidence to establish that there is a sufficient link between the entity subject to a measure freezing its funds and the regime or, in general, the situations, being combated (see judgment of 12 February 2020, Kanyama v Council, T‑167/18, not published, EU:T:2020:49, paragraph 93 and the case-law cited).

73      As regards the reliability and probative value of evidence, including that from digital sources, it should be borne in mind that the activity of the Court of Justice and of the General Court is governed by the principle of the unfettered evaluation of evidence, and that it is only the reliability of the evidence produced which is decisive when it comes to the assessment of its value. In addition, in order to assess the probative value of a document, regard should be had to the credibility of the account it contains, and in particular to the person from whom the document originates, the circumstances in which it came into being, the person to whom it was addressed and whether, on its face, the document appears to be sound and reliable (see, to that effect, judgments of 14 March 2018, Kim and Others v Council and Commission, T‑533/15 and T‑264/16, EU:T:2018:138, paragraph 224, and of 12 February 2020, Kande Mupompa v Council, T‑170/18, EU:T:2020:60, paragraph 107 (not published)).

74      In the second place, having regard to the preventive nature of the restrictive measures at issue, if, in the course of its review of the lawfulness of the contested decision, the Courts of the European Union consider that, at the very least, one of the grounds for listing is sufficiently detailed and specific, that it is substantiated and that it constitutes in itself sufficient basis to support that decision, the fact that the same cannot be said of other such reasons cannot justify the annulment of that decision (see, to that effect, judgment of 18 July 2013, Commission and Others v Kadi, C‑584/10 P, C‑593/10 P and C‑595/10 P, EU:C:2013:518, paragraph 130).

75      In the third place, it should be borne in mind that restrictive measures are measures of a precautionary and, by definition, provisional nature, the validity of which always depends on whether the factual and legal circumstances which led to their adoption continue to apply and on the need to persist with them in order to achieve their objective. It is thus for the Council, in the course of its periodic review of those restrictive measures, to conduct an updated assessment of the situation and to appraise the impact of such measures, in order to determine whether they have made it possible to attain the objectives pursued by the initial inclusion of the names of the persons and entities concerned on the list at issue or whether the same conclusion in respect of those persons and entities can still be drawn (see, to that effect, judgments of 12 February 2020, Amisi Kumba v Council, T‑163/18, EU:T:2020:57, paragraphs 58 and 59, and of 26 October 2022, Ovsyannikov v Council, T‑714/20, not published, EU:T:2022:674, paragraph 67 and the case-law cited).

76      It is in the light of those principles that the Court must determine whether the Council committed an error of assessment in finding that, in the present case, there was a sufficiently solid factual basis capable of justifying the maintenance of the applicant’s name on the lists at issue on the ground that he benefits from and supports the regime of President Lukashenko.

 The relevance of the evidence produced by the Council for the purpose of adopting the contested acts

77      In order to justify maintaining the applicant’s name on the lists at issue, the Council provided, in addition to the evidence previously taken into account for the adoption of the initial acts and the first set of maintaining acts, new items of evidence set out in documents WK 16887/2023 INIT, WK 16887/2023 ADD 1, WK 735/2024 INIT and WK 735/2024 ADD 1. Those documents contain information concerning both the applicant’s specific situation (WK 16887/2023 INIT, WK 16887/2023 ADD 1) and the general business environment and economic reality in Belarus (WK 735/2024 INIT and WK 735/2024 ADD 1).

78      However, the applicant disputes the relevance of the new items of evidence submitted by the Council to demonstrate that the maintenance of his name on the lists at issue is still well founded, arguing that such evidence does not refer to him by name and does not include any recent factual elements, continuing to be based on essentially the same past factual circumstances already documented by the Council in order to adopt the initial acts and the first set of maintaining acts.

79      That line of argument cannot succeed.

80      In the first place, as regards the applicant’s argument that the new items of evidence produced by the Council are not relevant because, for the most part, they do not refer to him by name, it must be stated first of all that that argument has no basis in fact since, contrary to what the applicant maintains, many of the new items of evidence contained in documents WK 16887/2023 INIT and WK 16887/2023 ADD 1 specifically refer to the applicant or to the undertakings with which he is said to be associated, including Dana Holding and its former subsidiary Dana Astra.

81      In that connection, the article of 6 August 2022, published on the websites ‘charter97.org’ and ‘belsat.eu’ and produced as exhibit 2 in document WK 16887/2023 INIT, and the articles of 21 May 2021 and 19 October 2022, published on the websites ‘objektiv.rs’ and ‘bankingnews.gr’ and produced, respectively, as exhibits 5 and 10 in document WK 16887/2023 ADD 1 identify the applicant by name on several occasions. Exhibits 11 and 13 in document WK 16887/2023 ADD 1 also concern the applicant specifically, since they reproduce statements made by him and by his wife on several social networking sites.

82      Similarly, the articles of 21 May 2021, 13 December 2021, 28 December 2021, 19 October 2022 and 26 June 2023 and the article which the Council accessed on 9 January 2024, published on the websites ‘objektiv.rs’, ‘web.tvr.by’, ‘web.archive.org’, ‘bankingnews.gr’, ‘news.zerkalo.io’ and ‘hatamatata.ru’ and produced, respectively, as exhibits 5, 7, 6, 10, 8 and 4 in document WK 16887/2023 ADD 1, expressly refer to Dana Holdings and Dana Astra, with which the applicant is said to be associated. The articles of 3 February 2023, 23 February 2023, 30 November 2023 and 8 December 2023, published on the website ‘belta.by’ and ‘realt.onliner.by’ and produced, respectively, as exhibits 3, 5, 4 and 6 in document WK 16887/2023 INIT, mention Dana Astra and the continued development of the Minsk World project by that undertaking, with which the applicant is said to be associated.

83      As for the items of evidence contained in documents WK 735/2024 INIT and WK 735/2024 ADD 1, it must be conceded that, as the applicant maintains, those documents do not specifically refer to the particular situation of the applicant or to that of the undertakings to which he is allegedly linked, since they are more concerned with describing the general business environment and economic reality in Belarus.

84      However, in that regard, it must be borne in mind that, in accordance with the case-law cited in paragraph 72 above, the assessment as to whether a listing is well founded must be carried out by examining the evidence not in isolation but in its context. Thus, although those items of evidence, taken individually, are insufficient in themselves to justify the maintenance of the applicant’s name on the lists at issue as well founded, that fact does not mean that they are entirely irrelevant for the purpose of examining the lawfulness of the contested acts, to the extent that they may provide contextual information to supplement and support the other items of evidence that mention the applicant specifically.

85      It follows that the applicant’s argument that most of the new items of evidence produced are irrelevant because they do not refer to him by name or do not expressly refer to his situation must therefore be rejected.

86      In the second place, concerning the applicant’s argument that the new items of evidence produced by the Council do not include any recent factual elements and continue to be based on essentially the same past factual circumstances already documented by the Council in order to adopt the initial acts and the first set of maintaining acts, it should be observed that, contrary to what the applicant claims, several new items of evidence contained in documents WK 16887/2023 INIT and WK 16887/2023 ADD 1 refer to factual elements contemporaneous with the adoption of the contested acts.

87      In that connection, suffice it to note, in particular, that of the articles referred to in paragraph 82 above, the article of 30 November 2023 published on the website of the official Belarusian news agency (‘belta.by’) and the article of 8 December 2023 published on the website ‘realt.onliner.by’, produced, respectively, as exhibits 4 and 6 in document WK 16887/2023 INIT, post-date the adoption of the first set of maintaining acts and attest to Dana Astra’s continued development of the Minsk World project on the date of adoption of the contested acts. The same is true of the article of 18 August 2023 published on the website ‘serbia.mfa.gov’, produced as exhibit 1 in document WK 16887/2023 INIT, and the article of 26 June 2023 published on the website ‘news.zerkalo.io’, produced as exhibit 8 in document WK 16887/23 ADD 1, which refer to recent events contemporaneous with the adoption of the contested acts. As for the items of evidence contained in documents WK 735/2024 INIT and WK 735/2024 ADD 1, relating to the general business environment and economic reality in Belarus, suffice it to note that the article of 3 March 2023 published on the website ‘sceeus.se’, the article of 18 October 2023 appearing on the website of the media outlet ‘Deutsche Welle’ (‘dw.com’), the articles of 20 November 2023 taken from the websites ‘udf.by’ and ‘zerkalo.io’ and the article published on the official website of the United States Department of State (‘state.gov’), produced, respectively, as exhibits 1, 5, 6, 7 and 2 in document WK 735/2024 INIT, illustrate – as of the date of adoption of the contested acts – the extent of the economic interventionism practised by the regime of President Lukashenko in Belarus and the penalties incurred in the event of non-compliance with the regulatory measures implemented.

88      Admittedly, as the applicant claims, some of the new items of evidence set out in documents WK 16887/2023 INIT, WK 16887/2023 ADD 1, WK 735/2024 INIT and WK 735/2024 ADD 1 refer to past factual circumstances already documented in the evidence files relied on by the Council to adopt the initial acts and the first set of maintaining acts against him. That is particularly true of the articles referring to facts dating back to the mid-2000s, when the relationship between the applicant and his brother, on the one hand, and President Lukashenko and his entourage, on the other, began.

89      However, in that regard, it must be stated, in the first place, that the reference in the reasons for the contested acts and in the evidence produced by the Council to past events which occurred before the adoption of those acts cannot, as a matter of principle, be regarded as irrelevant solely because certain conduct dates from the more or less distant past (see, to that effect, judgment of 7 June 2023, Shakutin v Council, T‑141/21, not published, EU:T:2023:303, paragraph 163 and the case-law cited).

90      That interpretation is supported by Article 8 of Decision 2012/642, under which that decision is to be kept under constant review and is to be renewed or amended, as appropriate, if the Council deems that its objectives have not been met, and by Article 8a(4) of Regulation No 765/2006, pursuant to which the list in Annex I to that regulation is to be reviewed at regular intervals and at least every 12 months. To avoid those provisions being rendered redundant, they must be considered to allow the maintenance on that list of the names of persons and entities not having committed any new act which shows that they benefit from or support the regime of President Lukashenko during the period preceding the review, if that maintenance is still justified in the light of all the relevant circumstances and, in particular, of the fact that the objectives pursued by the restrictive measures have not been achieved and that the continuation of the factual and legal circumstances which led to the adoption of those restrictive measures still indicates that that person or entity benefits from or supports the regime of President Lukashenko (see, to that effect, judgment of 7 June 2023, Shakutin v Council, T‑141/21, not published, EU:T:2023:303, paragraph 164 and the case-law cited).

91      Consequently, contrary to what the applicant claims, past events cannot be ruled out as a matter of principle. Those events must be assessed on a case-by-case basis, in the context of all the relevant circumstances, in order to determine whether they show that the applicant is one of the persons benefitting from or supporting the regime of President Lukashenko.

92      In the second place, it should be borne in mind that, according to the case-law, in order to justify maintaining a person’s name on the lists at issue, the Council is not prohibited from basing its decision on the same items of evidence and, therefore, a fortiori on the same factual elements and circumstances as those which justified the initial inclusion, re-inclusion or prior maintenance of the applicant’s name on the lists at issue, provided that (i) the grounds for listing remain unchanged and (ii) the context has not changed in such a way that that evidence is now out of date. That context includes not only the situation of the country in respect of which the system of restrictive measures has been established, but also the particular situation of the applicant (see, to that effect and by analogy, judgment of 29 May 2024, Belavia v Council, T‑116/22, EU:T:2024:334, paragraph 77 and the case-law cited).

93      It follows that, in adopting the contested acts, the Council was entitled, without committing any error, to continue to refer to the same factual circumstances as those which justified the initial inclusion and the first maintenance of the applicant’s name on the lists at issue if it considered that, in the context in which the grounds for maintenance remained unchanged (see paragraph 17 above), such circumstances were not then out of date. The question whether the items of evidence produced by the Council and the factual circumstances referred to therein actually serve to demonstrate that, when the contested acts were adopted, the grounds for maintaining the applicant’s name on the lists at issue were well founded goes to the substantive legality of those acts and must be examined as part of the analysis of the arguments relating to the merits of those acts.

94      In the light of the foregoing, it must be found that all the evidence produced by the Council to justify maintaining the applicant’s name on the lists at issue by way of the contested acts is relevant.

 Whether the maintenance of the applicant’s name on the lists at issue by way of the contested acts is well founded

95      As a preliminary point, it should be recalled that, as stated in paragraph 17 above, the grounds for including the applicant’s name on the lists at issue have not changed since the adoption of the initial acts and the first set of maintaining acts.

96      Furthermore, it must be stated that the general context of the situation in Belarus and the individual situation of the applicant have not changed either.

97      Thus, the general context of the situation in Belarus as regards the persistent violation of human rights, the crackdown on opponents of the regime of President Lukashenko and the involvement of that country in Russia’s aggression against Ukraine has not improved since the adoption of those acts.

98      In that connection, the article published on the website of the International Labour Organisation (ILO) of 21 April 2022 and two articles published on the website of the International Trade Union Confederation (ITUC) of 6 April and 10 June 2022, produced, respectively, as exhibits 5, 6 and 4 in document WK 735/2024 ADD 1, refer to the arrests of trade union leaders and the crackdown on trade unions in Belarus following the presidential elections of 9 August 2020 and to serious violations of workers’ rights, including freedom of association and the right to strike. Similarly, the article of 2 August 2021 published on the website ‘amnesty.nl’, produced as exhibit 9 in document WK 16887/2023 ADD 1, attests to the regime’s policy of repression of civil society and opponents of the regime, including in the field of sport, targeting athletes regarded as opponents of the regime.

99      Furthermore, among the materials contained in document WK 735/2024 INIT, the article of 3 March 2023 published on the website ‘sceeus.se’, the article of 18 October 2023 appearing on the website ‘dw.com’, the articles of 20 November 2023 taken from the websites ‘udf.by’ and ‘zerkalo.io’ and the article published on the official website of the United States Department of State (‘state.gov’), produced, respectively, as exhibits 1, 5, 6, 7 and 2 in document WK 735/2024 INIT, illustrate the extent of the economic interventionism practised by the regime of President Lukashenko and the penalties incurred in the event of non-compliance with the regulatory measures implemented. Such articles corroborate the fact that, in a country like Belarus, the pursuit of significant economic activities is possible only with the endorsement of the regime of President Lukashenko.

100    Against that background, it remains to be examined whether the factual circumstances concerning the applicant’s situation and on which the Council relied in order to adopt the initial acts and the first set of maintaining acts continued to support the conclusion – on the date of adoption of the contested acts – that the applicant could be regarded as a person benefitting from and supporting the regime of President Lukashenko.

–       The assessments that the applicant, together with his family members, developed a network of real estate companies in Belarus and, in particular, is closely associated with Dana Holdings and its former subsidiary Dana Astra and represented those companies during meetings with President Lukashenko

101    Concerning the assessments contained in the reasons for the contested acts relating to the ties between the applicant and members of his family, on the one hand, and real estate companies in Belarus, in particular Dana Holdings and its former subsidiary Dana Astra, on the other, it should be noted that the applicant does not deny that members of his family were involved in several companies engaged in real estate development in Belarus and even admits that, until the end of 2020, Dana Holdings and its subsidiaries, including Dana Astra, were owned by his children. By contrast, he denies owning, holding or managing those entities and claims that the only link between him and those companies is his parent-child relationship with the owners of Dana Holdings and its subsidiaries and that, in any event, at the end of 2020, Dana Holdings and its former subsidiary Dana Astra were sold, their current owner being a company established in the United Arab Emirates, with the result that he cannot be regarded as being closely associated with such companies.

102    However, in that connection, it should be recalled at the outset that, contrary to what the applicant claims, the reasons for the contested acts do not take issue with him for being the shareholder or officially the director of Dana Holdings or its subsidiaries, including Dana Astra. It is clear from the reasons for the contested acts, recalled in paragraph 9 above, that the applicant’s name was instead included and then maintained on the lists at issue on account of his status as a businessman in Belarus and his activities in the real estate sector, as well as his contacts with the family of President Lukashenko, which enabled companies with which he is closely associated, in particular Dana Holdings and Dana Astra, to receive preferential treatment from the regime of President Lukashenko.

103    Therefore, the applicant’s argument that he does not own, hold or manage any of the entities mentioned in the contested acts must be rejected as ineffective and the various extracts from the Belarusian Unified State Register of Legal Entities and Sole Traders, as well as the shareholder certificates and registers produced in support in the annexes to the application in the present action, must be regarded as irrelevant.

104    Next, it should be noted that several documents in the file contain information corroborating the fact that, contrary to what the applicant claims, the ties between him, Dana Holdings and its subsidiaries, including Dana Astra, do not consist merely of a parent-child relationship with the persons involved in officially managing those entities, but that the applicant is connected to those entities by common economic interests. In addition, those ties enable him to exert an influence over those entities and over the activities pursued by them.

105    More specifically, the applicant’s ties with several companies active in the real estate sector in Belarus, in particular Dana Holdings and its subsidiaries, including Dana Astra, emerge from the fact that, in the first place, Dana Holdings and its subsidiaries, including Dana Astra, are part of a larger entity, BK Group, the founder, co-owner and director of which is the applicant, and, in the second place, the applicant has publicly and repeatedly conducted himself like the director or, at the very least, the representative with the ability to exert influence over the activities of the companies involved in the Minsk World project, in particular Dana Holdings and its subsidiaries, both in discussions with President Lukashenko and in the press and on his own social media channels.

106    Thus, in the first place, several media sources, some of which rely on statements made by the applicant himself and by members of his family, identify him not only as the founder, but also as the co-owner and director of BK Group, which is described in turn as an international company encompassing all of the Karić family’s undertakings and also as one of the largest construction firms in Europe. Dana Holdings, for its part, is referred to as being part of BK Group and is described as the entity tasked with developing the Minsk World project, which is presented as one of the largest construction projects in the world, valued at several billion United States dollars (USD).

107    Such considerations are apparent in particular from a number of press articles produced by the Council. Thus, the article of 6 November 2020, taken from the website ‘balkanist.ru’ and produced as exhibit 4 in document WK 5817/2022 INIT, refers to a public statement made by the applicant’s brother in January 2020 upon receiving, on behalf of BK Group, an award given to Dana Holdings at the 50th anniversary of the World Economic Forum in Davos (Switzerland), in which he expressly states that BK Group is a company founded by the applicant. Similarly, the article of 13 January 2017 published on the website ‘europaproperty.com’ and produced as exhibit 4 in document WK 5817/2022 ADD 1, which is a feature piece on the applicant and his activities to mark his being named ‘Man of the Year’ in 2016, refers to a statement made by him in which he not only makes reference to BK Group and Dana Holdings, but also associates himself with the activities carried out by them, in particular the development of the Minsk World project.

108    In addition, several exculpatory documents produced by the applicant himself in the present action as annexes to the application and which may be relied on against him to support the merits of the grounds underlying the restrictive measures affecting him (see, to that effect, judgment of 12 February 2020, Ilunga Luyoyo v Council, T‑166/18, not published, EU:T:2020:50, paragraph 124 and the case-law cited) confirm his ties with the construction sector and, in particular, with BK Group as well as Dana Holdings and its subsidiaries, including Dana Astra.

109    Thus, in a press article of 30 November 2023 written by the applicant and produced as Annex A.25 to the application, the applicant is described as having founded, in 1971, the entity ‘Braća Karić’, which is depicted as a large-scale family business whose activities span various sectors worldwide, including telecommunications, construction, finance, education, media, commerce and others.

110    The report on the applicant’s reputation and public profile of 12 January 2024, produced by the applicant as Annex A.21 to the application, also attests to the close ties between the applicant and BK Group, on the one hand, and BK Group and Dana Holdings, on the other. In that report, BK Group is thus portrayed as an entity representing the commercial interests of the Karić family worldwide. In addition, the close ties between BK Group and Dana Holdings are attested to in that report by the applicant’s children, who maintain that those entities headed up similar projects and shared a similar office address in Minsk. It is also apparent from that report that BK Group and Dana Holdings continue to have a common office address in Minsk.

111    Although that report indeed states that BK Group is not actually a legal person and does not, moreover, have any ownership interest in Dana Holdings, suffice it to note that those statements are contradicted by the evidence produced by the Council, such as that referred to in paragraph 107 above, and by the applicant himself, such as that referred to in paragraphs 109 and 110 above.

112    In the second place, it should be observed that the applicant has publicly and repeatedly conducted himself like the director or, at the very least, the representative with the ability to exert influence over the activities of the companies involved in the construction and real estate sectors in Belarus, specifically those involved in the Minsk World project, in particular Dana Holdings and its subsidiaries, both in discussions with President Lukashenko and in the press and on his own social media channels.

113    In that connection, first of all, it should be pointed out that the applicant conducted himself like the director of the companies involved in the Minsk World project in discussions with President Lukashenko. It is thus apparent from a press release dated 22 June 2015 published on the official website of the President of Belarus (‘president.gov.by’) and produced as exhibit 2 in document WK 5817/2022 INIT that, on that day, the applicant, together with his brother, met with President Lukashenko to discuss the development of the Minsk World project. The press release states that the applicant participated in that meeting with President Lukashenko on account of his dual capacity as co-owner and director of the international company involved in the development of the Minsk World project.

114    Next, it is clear that, in statements to the press, the applicant similarly behaved as though he were the director of Dana Holdings and its subsidiaries or, at any rate, the representative with ability to exert influence over the activities of those entities. In a video investigation into the activities of Dana Holdings and the preferential treatment that it allegedly received from the regime of President Lukashenko in Belarus, posted on 12 September 2019 on the website of Belsat – an independent Belarusian television station – and produced as exhibit 7 in document WK 5817/2022 INIT, the applicant is portrayed as one of the co-owners of Dana Holdings and answers questions from journalists on behalf of that company.

115    Lastly, it should be noted that, in the application, the applicant acknowledges that he publicly mentioned Dana Holdings and its subsidiaries – companies involved in the Minsk World project – on his own social media channels. In that regard, the article of 1 November 2019, published on the website ‘the-village.me’ and produced as exhibit 6 in document WK 5817/2022 INIT, reproduces a number of posts from the applicant’s Instagram account in which he not only portrayed himself as an associate in the BK Group, with which Dana Holdings is allegedly linked, but also appeared before the Minsk World real estate project and associated himself with that project through the use of pronouns and possessive adjectives such as ‘we’ or ‘our buildings’ without any mention of his children’s involvement in the companies developing that project.

116    It follows that, in contrast to the applicant’s claims, he did not confine himself to mere public support for the efforts of the members of his family, in this case his children, but was himself involved on several occasions in the projects and activities carried out by them. That, on the contrary, attests to a commitment on the part of the applicant and to the influence which he exerts vis-à-vis the projects and activities carried out by his children, in particular the development and implementation of the Minsk World project.

117    As for the applicant’s claim that, at the end of 2020, Dana Holdings and its former subsidiary Dana Astra were sold, their current owner being a company established in the United Arab Emirates, it must be found that the evidence produced is not capable of establishing that the alleged transfer was made to a third party independent of the applicant (see, by analogy, judgment of 20 September 2023, Mordashov v Council, T‑248/22, not published, EU:T:2023:573, paragraph 101). Several items of evidence provided by the Council support the conclusion that that change of ownership was in fact intended to create the appearance of distance between the applicant and a number of his family members, on the one hand, and Dana Holdings and its former subsidiary Dana Astra, on the other.

118    In that regard, first, it is apparent from the articles of 21 May 2021 and 19 October 2022, produced as exhibits 5 and 10 in document WK 16887/2023 ADD 1, that, in order to protect their interests, the ownership of Dana Holdings and its subsidiaries was transferred to friends close to the Karić family.

119    Secondly, the alleged changes in the ownership structure of Dana Holdings and its subsidiaries did not ostensibly alter the influence that the members of the Karić family, in particular the applicant, exerted over those entities.

120    Various public statements and actions of a number of the applicant’s family members – including his wife, his brother and his son – corroborate the fact that the alleged change in the ownership of those entities in December 2020 did not affect the ties between the applicant and those entities as well as the projects carried out by them, including the Minsk World project.

121    Thus, even after that sale, the article of 6 October 2021, published on the website ‘republika.rs’ and produced as exhibit 2 in document WK 5817/2022 ADD 1, shows that the applicant’s wife told the Belarusian press that her husband’s companies operated in Belarus, while referring, inter alia, to the further development of the Minsk World project, thus continuing to demonstrate the applicant’s involvement in the development of that project and, therefore, in the companies tasked with such development.

122    In addition, as is apparent from the article published on the website ‘nashaniva.com’ and produced as exhibit 10 in document WK 5817/2022 INIT, the applicant’s brother – in his capacity as co-owner of Dana Holdings – participated in a meeting with President Lukashenko to discuss the effects of the sanctions adopted in 2021 by the United States against Dana Holdings, a meeting that was held on 7 December 2021, that is, one year after the change of ownership referred to in paragraph 117 above.

123    Lastly, it follows from the statement of the applicant’s son of 9 May 2023 that, despite the alleged change in the owners of Dana Holdings, the applicant’s son was still the beneficial owner of that company.

124    Thirdly, it must be noted that the ongoing ties between the applicant and the entities referred to in the contested acts as well as the projects carried out by those entities, including the Minsk World project, even after the alleged change in ownership of those entities in December 2020, is confirmed by evidence produced by the applicant himself which may be relied on against him to support the merits of the reasons underlying the restrictive measures affecting him (see, to that effect, judgment of 12 February 2020, Ilunga Luyoyo v Council, T‑166/18, not published, EU:T:2020:50, paragraph 124 and the case-law cited). As stated in paragraph 109 above, in a press article of 30 November 2023, written by the applicant and produced as Annex A.25 to the application, the applicant describes himself as the founder of a major undertaking belonging to the Karić family, which has been in business since 1971 and whose activities span various sectors worldwide, including telecommunications, construction, finance, education, media, commerce and others.

125    Those elements constitute a sufficiently solid demonstration that the alleged changes in the ownership structure of Dana Holdings and its subsidiaries did not affect the ties between the members of the Karić family, in particular the applicant, and those entities.

126    Since then – and particularly on the date of adoption of the contested acts – there has been nothing to show that such circumstances no longer apply.

127    Although the applicant maintains, in the application, that he terminated all of his business relationships, it must be stated that, on the contrary, it is apparent from several items of evidence adduced by the applicant himself as Annexes A.24 and A.25 to the application, which may be relied on against him to support the merits of the reasons underlying the restrictive measures affecting him (see, to that effect, judgment of 12 February 2020, Ilunga Luyoyo v Council, T‑166/18, not published, EU:T:2020:50, paragraph 124 and the case-law cited), that, in contrast to his claims, he was still an active businessman at the time when the contested acts were adopted.

128    It follows from the foregoing that the Council did not err in its assessment by considering, at the time when the contested acts were adopted, that the applicant, together with his family members, had developed a network of real estate companies in Belarus and, in particular, was closely associated with Dana Holdings and its former subsidiary Dana Astra, and that he had repeatedly represented those companies, including during meetings with President Lukashenko.

–       The assessment that the applicant, together with his family members, cultivated a network of contacts with President Lukashenko and his entourage

129    The applicant disputes the claim that, together with his family members, he developed a network of contacts with the family of President Lukashenko. In that connection, the applicant states in particular that he took part in only one meeting, on 22 June 2015, in which President Lukashenko also participated. The Council cannot, it is argued, rely on that single meeting, which took place nearly 10 years ago, in an attempt to demonstrate support provided to the regime or a benefit derived from it.

130    However, in that regard, it must be stated that it is apparent from the file that, contrary to what the applicant claims, there are close, long-standing ties between him and members of his family, in particular his brother, on the one hand, and President Lukashenko and his entourage, on the other.

131    Thus, first, a number of journalistic investigations into leading businesspersons operating in Belarus and their ties with the regime of President Lukashenko, published in March, May and June 2021 on the websites ‘occrp.org’, ‘belsat.eu’ and ‘rferl.org’ and produced, respectively, as exhibits 5, 9 and 15 in document WK 5817/2022 INIT, show that members of the Karić family, particularly the applicant and his brother, started to forge ties with President Lukashenko in the mid-2000s, after their political rivals in Serbia began investigating their businesses in that country, and those ties subsequently became closer and contact more frequent. Similarly, of the new items of evidence provided by the Council to demonstrate that the maintenance of the applicant’s name on the lists at issue was well founded, the article published on 6 August 2022 on the website ‘charter97.org’ – a grassroots human rights organisation – and on the website of Belsat – an independent Belarusian television station – and produced as exhibit 2 in document WK 16887/2023 INIT also confirms the applicant and his family’s long-standing relationship with President Lukashenko and his entourage. More specifically, that article draws attention to the personal relationships forged by the applicant and several members of his family with President Lukashenko and his entourage by means of, inter alia, numerous joint trips made in the mid-2000s. It also shows that, thanks to the benefits brought about by their proximity to the regime, resulting in privileges and advantages being granted to several companies with which they are closely associated, the applicant and his family became Belarus’s foremost property developers, responsible, inter alia, for the development of the Minsk World project.

132    Secondly, it is apparent from the file that the applicant and other members of his family, including his brother, met President Lukashenko on several occasions in the context of their activities in the real estate sector, in particular with a view to developing the Minsk World project, and therefore had a direct link with President Lukashenko.

133    Thus, the applicant admits in the application that he and his brother took part in a meeting on 22 June 2015 attended by President Lukashenko. The applicant argues, however, that the Council cannot rely on that single meeting, which took place nearly 10 years ago and which he took part in as a member of an official delegation of Serbian businesspersons and politicians, in an attempt to demonstrate support provided to the regime or a benefit derived from it.

134    Nonetheless, concerning the applicant’s claim that he took part in that meeting as a member of an official delegation of Serbian businesspersons and politicians, it should be noted at the outset that that claim is contradicted by the very content of the press release published on 22 June 2015 on the official website of the President of Belarus (‘president.gov.by’) and produced as exhibit 2 in document WK 5817/2022 INIT, which states that, on that day, the applicant, accompanied by his brother, met with President Lukashenko to discuss the development of the Minsk World project in his capacity as co-owner and director of the international company involved in the development of that project (see paragraph 113 above).

135    Furthermore, contrary to what the applicant claims, the network of contacts developed with President Lukashenko and his entourage is not confined to that single meeting held on 22 June 2015. Thus, it is apparent from the article of 25 May 2021 published on the website ‘occrp.org’ – belonging to the global network of investigative journalists known as the ‘Organized Crime and Corruption Reporting Project’ (OCCRP) – and headed ‘Lukashenko doles out prime Belarus real estate to Serbian cronies’, produced as exhibit 5 in document WK 5817/2022 INIT, that, in 2019, another meeting involving, inter alia, the applicant’s brother and President Lukashenko took place when the latter travelled to Serbia and met with the President of the Republic of Serbia. In addition, the article published on 7 December 2021 on the website ‘nashaniva.com’ – an independent Belarusian news portal – and produced as exhibit 10 in document WK 5817/2022 INIT recounts a meeting that took place that same day between the applicant’s brother and President Lukashenko on the effects of the sanctions adopted in 2021 by the United States of America against Dana Holdings.

136    At such meetings, President Lukashenko gave his backing and also confirmed the support which the applicant, his family and the companies with which he is associated receive from the regime, in particular in the context of the development of the Minsk World project. Thus, at the meeting of 22 June 2015 (see paragraphs 133 and 134 above), which the applicant and his brother took part in to discuss the development of the Minsk World project, President Lukashenko publicly declared that ‘the Belarusian side will do its utmost to lift all the brakes and use additional reserves if necessary’ for the implementation of the Minsk World project. Similarly in 2019, at the press conference organised following his meeting with the President of the Republic of Serbia, in which the applicant’s brother had also participated, President Lukashenko drew attention to his long-standing ties with the applicant and his family, including his brother, recalling that he had welcomed the Karić brothers to Belarus after they had fled charges brought against them in Serbia. At the same press conference, President Lukashenko also praised the success of Dana Astra, with which the applicant is said to be associated, stating that it was ‘one of the most successful and one of the richest companies on the planet, which is creating miracles in construction’.

137    Such evidence shows that, contrary to what the applicant claims, the ties with President Lukashenko are not confined to a single meeting or to occasional proximity in the past, but are more akin to a genuine relationship of a close and long-standing nature.

138    It is true that, as the applicant maintains, the Council has not adduced evidence of recent meetings with President Lukashenko in which the applicant allegedly participated in person.

139    However, in that regard, it should be recalled first of all that, in the reasons for the contested acts, it is not claimed that the applicant, alone, met and cultivated close relations with the regime of President Lukashenko. It is clear from the reasons for the contested acts, referred to in paragraph 9 above, that the applicant’s name was instead included and then maintained on those lists on account of the network of contacts he had developed and cultivated alongside members of his family and, therefore, the close relationship he and several members of his family had established with the regime of President Lukashenko, which, among other things, enabled the companies with which he is associated to receive preferential treatment and advantages from the regime. Thus, the various meetings referred to in paragraph 135 above, attended by President Lukashenko, in which the applicant’s brother in particular took part, are also evidence of the network of contacts developed by the applicant and his family, especially his brother, with President Lukashenko and his entourage.

140    In addition, apart from the meetings in which the applicant participated in person, it must be observed that the close ties cultivated by the applicant and members of his family with President Lukashenko are also substantiated by the public statements of President Lukashenko, who, on several occasions, gave his backing and confirmed the support which the applicant, his family and the companies with which the applicant is associated receive from the regime, in particular in the context of the development of the Minsk World project (see paragraph 136 above). Such statements by President Lukashenko attest to the support which the applicant, his family and the companies with which the applicant is associated receive from the regime, in particular in the context of the development of the Minsk World project.

141    Lastly, as regards the applicant’s argument that the elements on which the Council relies are out of date, it should be borne in mind that, in accordance with the case-law cited in paragraph 89 above, the reference in the reasons for the contested acts and in the evidence produced by the Council to events which occurred before the adoption of the contested acts and which belong in the more or less distant past does not necessarily mean that the restrictive measures adopted against the applicant by way of those acts are outdated.

142    In the present case, it cannot be inferred from the lack of evidence of a recent meeting between the applicant and President Lukashenko that they are no longer in contact. On the contrary, as stated in paragraphs 130 to 137 above, the applicant and his family maintain long-standing, close relationships with the regime of President Lukashenko which have endured for almost 20 years and there is no evidence that those relationships have deteriorated; President Lukashenko has praised the applicant and reiterated, on several occasions, his support for the undertakings linked to the applicant and involved in the development of the Minsk World project.

143    In addition, the Council adduced new items of evidence demonstrating that, on the date of adoption of the contested acts, the applicant and his family’s proximity to the regime of President Lukashenko continued and had not ended, allowing the companies with which he is associated to keep on receiving preferential treatment and advantages from the regime. Thus, the article published on 18 August 2023 on the official website of the Belarusian embassy in Serbia, produced as exhibit 1 in document WK 16887/2023 INIT, describes the applicant’s brother not only as a member of the Serbian parliament but also as the honorary consul of Belarus in Belgrade, responsible for dialogue and relations between Serbia and Belarus. That article refers to a meeting which took place on 17 August 2023 between the applicant’s brother and the Belarusian ambassador to Serbia, in which both expressed their willingness to continue to strengthen bilateral relations between Belarus and Serbia. Such a meeting and the position currently held by the applicant’s brother are proof, at the time of adoption of the contested acts, of the trust and confidence still enjoyed by the Karić family and of their willingness to cultivate close relationships with the regime of President Lukashenko. Similarly, the article of 26 June 2023 published on the website ‘news.zerkalo.io’ and produced as exhibit 8 in document WK 16887/2023 ADD 1 shows that, when the contested acts were adopted, Dana Holdings, which is one of the companies referred to in the reasons for the contested acts and with which the applicant is associated, continues to be described as an undertaking favourable to the regime of President Lukashenko. Thus, Dana Holdings is described as currently being one of the main sponsors of the Belarusian National Olympic Committee, which is headed by President Lukashenko’s eldest son.

144    Such elements confirm that the network of contacts and the applicant and his family’s proximity to the regime of President Lukashenko had not come to an end when the contested acts were adopted.

145    Lastly, it does not appear that the applicant dissociated himself at any time from President Lukashenko’s actions, or that he expressed the slightest protest, reservation or nuance regarding the work carried out by President Lukashenko (see, by analogy, judgments of 24 May 2023, Lyubetskaya v Council, T‑556/21, not published, EU:T:2023:283, paragraph 46 and the case-law cited, and of 27 April 2022, Ilunga Luyoyo v Council, T‑108/21, EU:T:2022:253, paragraph 77).

146    It follows that the Council did not err in its assessment by considering that the applicant, along with his family members, cultivated a network of contacts with President Lukashenko.

–       The assessment that the entities with which the applicant is associated received preferential treatment from the regime of President Lukashenko, including tax breaks and plots of land for real estate development

147    As a preliminary point, it should be recalled that, as stated in paragraph 48 above, the companies referred to in the reasons for the contested acts and with which the applicant is associated are, in particular, Dana Holdings and its former subsidiary Dana Astra.

148    Concerning the determination made by the Council in the reasons for the contested acts that entities with which the applicant is associated received preferential treatment from the regime of President Lukashenko, including tax breaks and plots of land for real estate development, suffice it to note that, in the present action, the applicant does not deny either that Dana Holdings and Dana Astra received, in particular in the context of the development of the Minsk World project, preferential treatment from the regime of President Lukashenko, or, moreover, that the development of the Minsk World project by those companies was ongoing when the contested acts were adopted.

149    In that connection, it is clear, first, that the preferential treatment which the regime of President Lukashenko gave to the entities developing the Minsk World project was confirmed by the judgment of 28 June 2023, Dana Astra v Council (T‑239/21, not published, EU:T:2023:364). In that judgment, the Court held that Dana Astra had received, in the context of the Minsk World project, advantages and privileges, granted by presidential decrees, from the regime of President Lukashenko, by means, inter alia, of tax breaks and the grant of plots of land owned by the Belarusian State, the objective of which was to facilitate the implementation of a very large project of particular importance to the regime. Thus, by Presidential Decree No 456 of 22 September 2014 on the implementation of the investment project for the Minsk-City multifunctional centre, the applicant received, inter alia, tax advantages in the field of property tax, profit tax and customs duties which were not provided for by general legislation (see, to that effect, judgment of 28 June 2023, Dana Astra v Council, T‑239/21, not published, EU:T:2023:364, paragraph 57).

150    Secondly, several items of evidence produced by the Council show that, at the time of the adoption of the contested acts, Dana Astra was continuing to develop the Minsk World project, considered to be the largest investment in Europe and a major project for that regime.

151    Thus, the article of 3 February 2023 published on the website of the official Belarusian news agency and produced as exhibit 3 in document WK 16887/2023 INIT states that the development of the Minsk World project is being carried out in accordance with Presidential Decree No 456 of 22 September 2014 on the implementation of the investment project for the Minsk-City multifunctional centre. Similarly, the article of 23 February 2023 published on the website of the official Belarusian news agency (‘belta.by’) and produced as exhibit 5 in document WK 16887/2023 INIT refers to the progress of the Minsk World project and Dana Astra’s achievements in the development of that centre. The success of Dana Astra in developing the Minsk World project is also underscored by its director who, in several statements referred to in those articles, welcomes the latest achievements and the progress made in relation to that centre.

152    It is also apparent from the article of 30 November 2023 published on the website of the official Belarusian news agency (‘belta.by’) and the article of 8 December 2023 published on the website ‘realt.onliner.by’, produced, respectively, as exhibits 4 and 6 in document WK 16887/2023 INIT, that the development of the Minsk World project by Dana Astra was progressing successfully on the date of adoption of the contested acts, with its completion being announced for the end of 2027. Such articles also highlight the particular importance of that project for Belarus, a project that is intended to host a real international financial hub and numerous administrative, commercial, socio-cultural, sporting and residential facilities.

153    It follows that the Council did not err in its assessment by considering, in the contested acts, that the circumstance that Dana Holdings and its former subsidiary Dana Astra, with which the applicant is closely associated, received preferential treatment from the regime of President Lukashenko, with the aim, inter alia, of facilitating the development of the Minsk World project, still applied.

–       Whether the facts established by the Council demonstrate that the applicant benefits from and supports the regime of President Lukashenko

154    It follows from paragraphs 128, 146 and 153 above that the Council did not err in its assessment by finding that, on the date of adoption of the contested acts, (i) the applicant was a businessman who, together with his family members, had developed a network of real estate companies in Belarus and, in particular, was closely associated with Dana Holdings and its former subsidiary Dana Astra and had represented those companies during meetings with President Lukashenko; (ii) the applicant, together with his family members, had cultivated a network of contacts with President Lukashenko and his entourage; and (iii) the companies Dana Holdings and Dana Astra, with which the applicant is closely associated, had received preferential treatment from the regime of President Lukashenko, including tax breaks and plots of land for real estate development, in particular in the context of the development of the Minsk World project.

155    The applicant nonetheless maintains that those factors do not demonstrate that he benefits from or supports the regime of President Lukashenko.

156    In that regard, the applicant submits that the factual elements set out in the reasons for the contested acts, in particular those relating to his association with Dana Holdings or its subsidiaries, including Dana Astra, did not support the adoption of restrictive measures against him on the basis of the listing criterion at issue. According to the applicant, the recent introduction of the new listing criterion, referred to in paragraph 23 above, attests to the fact that, when the contested acts were adopted, situations such as his, namely that of natural persons linked to companies which are themselves subject to restrictive measures on account of the benefit derived from and support provided to the regime of President Lukashenko, were not covered by the scope of the listing criterion at issue.

157    In addition, the applicant claims that he cannot be regarded as someone who personally benefits from or personally supports the regime of President Lukashenko under the listing criterion at issue due to alleged shareholdings in companies or an alleged advantage obtained by companies with which he is said to be associated. More specifically, the applicant submits that the Council cannot penalise him, under the listing criterion at issue, on the basis of the preferential treatment and advantages granted to Dana Holdings or its subsidiaries, including Dana Astra, with which he is said to be associated, unless it can demonstrate that he was in a position to influence their decision-making process when he was listed. The applicant maintains that he has never been the owner or director of Dana Holdings or of its subsidiaries, including Dana Astra.

158    However, it should be observed at the outset that the applicant’s line of argument rests, in essence, on the premiss that his name was maintained on the lists at issue because he is said to be associated with entities which are themselves subject to restrictive measures on account of the benefit derived from and support provided to the regime of President Lukashenko. That premiss is incorrect. As stated in paragraph 40 above, it is clear from the reasons for the contested acts that the applicant’s name was maintained on the lists at issue not on the ground that the companies with which he was associated were already included on the lists at issue, but on account of his own conduct and activities as a businessman in Belarus, in particular in the real estate sector, and his contacts with President Lukashenko’s family, which enabled entities with which he is closely associated to receive preferential treatment from the regime of President Lukashenko, and, as a result of his close association with those entities, made it possible for the applicant himself personally to benefit from and support the regime of President Lukashenko.

159    Conduct and activities such as those described above are undoubtedly covered by the listing criterion at issue since they demonstrate a sufficient link between the applicant and the regime of President Lukashenko (see, to that effect, judgment of 6 September 2023, Gutseriev v Council, T‑526/21, not published, EU:T:2023:512, paragraph 45), irrespective of whether the entities with which he is associated are also subject to restrictive measures under the same listing criterion. Such a link exists in a situation where, as here, the person subject to restrictive measures has close ties with an entity which has received preferential treatment from the regime of President Lukashenko, if those ties make it possible for that person himself or herself to benefit from that treatment and, as such, to benefit from and support the regime of President Lukashenko.

160    As is apparent from paragraphs 104 to 127 above, the material in the Council’s evidence files constitutes a sufficiently specific, precise and consistent body of evidence supporting the conclusion that, on the date of adoption of the contested acts and despite the fact that the applicant was not officially the owner or director of Dana Holdings and Dana Astra, he had close ties with those entities, ties which do not consist merely of a parent-child relationship with the persons involved in managing those entities, and that he is connected by common economic interests to a number of companies active in the real estate sector in Belarus, in particular Dana Holdings and its subsidiaries, including Dana Astra, and that those ties enable him to exert influence over those companies.

161    In addition, it is clear that, contrary to the applicant’s claims, the factors referred to in paragraph 154 above, taken as a whole, indicate that the applicant personally benefitted from and personally supported the regime of President Lukashenko, in the light of (i) his involvement as a businessman both in establishing and maintaining a close relationship with President Lukashenko and in implementing the Minsk World project, which is of particular importance to the regime, and (ii) the common economic interests between him and the entities referred to in the contested acts tasked with the development of the Minsk World project.

162    More specifically, a number of items of evidence demonstrate, to the requisite legal standard, that the close relationships which the applicant and his brother forged, from the mid-2000s onwards, with President Lukashenko have been decisive for the position of the companies owned by members of the Karić family, which companies are active in the real estate sector in Belarus, and in particular for Dana Holdings and its former subsidiary Dana Astra, as well as for the development of the Minsk World project in Belarus, the importance of which for the Belarusian economy was publicly highlighted by President Lukashenko.

163    Having regard to the size and prestigious nature of the Minsk World project for the regime, confirmed by the public statements made by President Lukashenko, and the particular importance of that project for the Belarusian economy, those factors demonstrate support to the regime of President Lukashenko (judgment of 28 June 2023, Dana Astra v Council, T‑239/21, not published, EU:T:2023:364, paragraph 77).

164    In that regard, it should be borne in mind, in particular, that the concept of ‘support to the regime’ in terms of the listing criterion at issue does not encompass only financial or material support to the regime of President Lukashenko, but refers to any form of support to that regime (judgment of 28 June 2023, Dana Astra v Council, T‑239/21, not published, EU:T:2023:364, paragraph 76).

165    Lastly, of the new items of evidence provided by the Council in support of the adoption of the contested acts, the article published on 19 October 2022 on the website ‘bankingnews.gr’ and produced as exhibit 10 in document WK 16887/2023 ADD 1 highlights the personal benefit which the applicant derived from the regime of President Lukashenko as a result of his personal involvement in establishing and maintaining a close relationship with President Lukashenko. In particular, that article refers to the numerous properties acquired by the applicant and several members of his family, thanks to the benefits brought about by their proximity to the regime.

166    In the light of all of the foregoing considerations, the second plea in law must be rejected and, consequently, the action must be dismissed in its entirety.

 Costs

167    Under Article 134(1) of the Rules of Procedure of the General Court, the unsuccessful party is to be ordered to pay the costs if they have been applied for in the successful party’s pleadings.

168    In the present case, since the applicant has been unsuccessful, he must be ordered to pay the costs in accordance with the form of order sought by the Council.

On those grounds,

THE GENERAL COURT (Fifth Chamber)

hereby:

1.      Dismisses the action;

2.      Orders Mr Bogoljub Karić to pay the costs.

Svenningsen Laitenberger Stancu

Delivered in open court in Luxembourg on 24 September 2025.

V. Di Bucci S. Papasavvas

Registrar President

*      Language of the case: English.