JUDGMENT OF THE GENERAL COURT (First Chamber)

30 September 2026 (*)

( Common foreign and security policy – Restrictive measures taken in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region – Freezing of funds and economic resources – List of persons, entities and bodies subject to the freezing of funds and economic resources – Inclusion and maintenance of the applicant’s name on the list – Effective judicial protection – Rights of the defence – Error of law – Error of assessment – Right to property – Freedom to conduct a business )

In Case T‑94/25,

Mohammad Reza Khiabani, residing in Tehran (Iran), represented by V. Ostrovskis and C. Cauvin, lawyers,

applicant,

Council of the European Union, represented by M. Di Gaetano, E. Kübler and A. Boggio-Tomasaz, acting as Agents,

defendant,

THE GENERAL COURT (First Chamber),

composed of E. Buttigieg, President, M. Kancheva (Rapporteur) and F. Bestagno, Judges,

Registrar: M. Zwozdziak-Carbonne, Administrator,

having regard to the written part of the procedure,

having regard to the decision of 16 March 2026 joining Cases T‑94/25 and T‑93/25 for the purposes of the oral part of the procedure,

further to the hearing on 29 April 2026,

gives the following

Judgment

1 By his action under Article 263 TFEU, the applicant, Mr Mohammad Reza Khiabani, seeks the annulment, in the first place, of Council Decision (CFSP) 2024/2894 of 18 November 2024 amending Decision (CFSP) 2023/1532 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region (OJ L, 2024/2894) and of Council Implementing Regulation (EU) 2024/2896 of 18 November 2024 implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region (OJ L, 2024/2896) (together, ‘the November 2024 listing acts’), and, in the second place, of Council Decision (CFSP) 2025/1547 of 25 July 2025 amending Decision (CFSP) 2023/1532 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region (OJ L, 2025/1547) and of Council Implementing Regulation (EU) 2025/1548 of 25 July 2025 implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region (OJ L, 2025/1548) (together, ‘the July 2025 maintaining acts’), in so far as the November 2024 listing acts and the July 2025 maintaining acts (together, ‘the contested acts’) concern the applicant.

I. Background to the dispute and events subsequent to the bringing of the action

2 On 20 July 2023, the Council of the European Union adopted Decision (CFSP) 2023/1532 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine (OJ 2023 L 186, p. 20) and Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran’s military support of Russia’s war of aggression against Ukraine (OJ 2023 L 186, p. 1).

3 On 14 May 2024, the Council adopted Decision (CFSP) 2024/1336 amending Decision 2023/1532 (OJ L, 2024/1336), introducing new restrictive measures in response to Iran’s military support to Russia’s war of aggression against Ukraine as well as Iran’s supplying of unmanned aerial vehicles (‘UAVs’) and missiles to armed groups and entities in the Middle East and the Red Sea region, which undermines peace and security, as well as the sovereignty of states.

4 Article 1(1) of Decision 2024/1336 thus replaced the title of Decision 2023/1532 with the following text:

‘Council Decision (CFSP) 2023/1532 of 20 July 2023 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region.’

5 Article 3(1) of Decision 2023/1532, as amended by Article 1(3) of Decision 2024/1336, provided for the following restrictive measures:

‘1. All funds and economic resources belonging to, or owned, held or controlled by natural or legal persons, entities or bodies:

(a) responsible for, supporting or involved in Iran’s UAV or missile programme;

(b) supplying, selling or otherwise involved in transferring Iran’s UAVs or missiles or related technologies:

(i) to Russia in support of its war of aggression against Ukraine;

(ii) to armed groups and entities undermining peace and security in the Middle East and the Red Sea region;

(iii) to natural or legal persons, entities or bodies acting in breach of United Nations Security Council Resolution 2216 (2015); or

as listed in the Annex, shall be frozen.’

6 On the same day, the Council adopted Regulation (EU) 2024/1338 amending Regulation 2023/1529 (OJ L, 2024/1338). Article 1(1) of Regulation 2024/1338 replaced the title of Regulation 2023/1529 with the following text:

‘Council Regulation (EU) 2023/1529 of 20 July 2023 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region.’

7 Article 1(2) of Regulation 2024/1338 replaced the text of Article 3(1) of Regulation 2023/1529, reproducing mutatis mutandis the wording set out in paragraph 5 above.

8 On 18 November 2024, the Council adopted Decision 2024/2894 and Regulation (EU) 2024/2897 of 18 November 2024 amending Regulation 2023/1529 (OJ L, 2024/2897), by which it amended, respectively, Article 3(1) of Decision 2023/1532 and Annex I to that decision as well as Article 3(1) of Regulation 2023/1529. On the same day, it also adopted, on the basis of Article 7(1) of Regulation 2023/1529, Implementing Regulation 2024/2896, by which it amended Annex III to Regulation 2023/1529.

9 Article 3(1) of Decision 2023/1532, as amended by Article 1(4) of Decision 2024/2894, and Article 3(1) of Regulation 2023/1529, as amended by Article 1(3) of Regulation 2024/2897, provided for the following restrictive measures:

‘1. All funds and economic resources belonging to, or owned, held or controlled by natural or legal persons, entities or bodies:

(a) responsible for, supporting or involved in Iran’s UAV or missile programme;

(b) supplying, selling or otherwise involved in transferring Iran’s UAVs or missiles or related technologies or components thereof:

(i) to Russia in support of its war of aggression against Ukraine;

(ii) to armed groups and entities undermining peace and security in the Middle East and the Red Sea region;

(iii) to natural or legal persons, entities or bodies acting in breach of United Nations Security Council Resolution 2216 (2015); or,

as listed in Annex I, shall be frozen.’

10 Annex I to Decision 2023/1532, as amended by Article 1(5) of Decision 2024/2894, contains the list of natural and legal persons, entities and bodies referred to in Articles 2 and 3 of Decision 2023/1532.

11 Under entry 20 of Part A, entitled ‘Natural persons’, of the list of natural and legal persons, entities and bodies, referred to in paragraph 10 above, the applicant’s name and the grounds for the inclusion thereof were set out, inter alia, as follows:

‘[The applicant] is the director of the EU-listed Islamic Republic of Iran Shipping Lines (IRISL), Iran’s national maritime carrier.

For years, IRISL ships have been involved in shipping military related cargo. The EU-listed Iran’s Islamic Revolutionary Guard Corps Navy (IRGCN) converts container ships owned by IRISL Group into drone carriers.

The IRGCN is part of the IRGC, and includes an unmanned aerial vehicle (UAV) division and a missiles division. The IRGCN is involved in Iran’s UAV and missile programmes, as well as in transferring Iran’s missiles to armed groups and entities undermining peace and security in the Middle East and the Red Sea region.

Therefore, in his position as director of IRISL, [the applicant] is associated with the IRGCN.’

12 Under entry 20 of Part A, entitled ‘Natural persons’, of the list of natural and legal persons, entities and bodies set out in Annex III to Regulation 2023/1529, as amended by Article 1 of Implementing Regulation 2024/2896, the applicant’s name and the grounds for the inclusion thereof were set out, inter alia, in terms identical to those referred to in paragraph 11 above.

13 On 19 November 2024, the Council published in the Official Journal of the European Union a notice for the attention of the persons, entities and ports subject to the restrictive measures provided for in [the November 2024 listing acts] (OJ C, C/2024/7047).

14 By letter of 13 January 2025, following a request from the applicant to that end, the Council sent him the evidence files bearing the reference WK 12709/2024 DCL1 of 9 January 2025 (‘the evidence file WK 12709/2024 DCL1’) and WK 12325/2024 DCL1 of 9 January 2025 (‘the evidence file WK 12325/2024 DCL1’), which included the documents supporting the inclusion of the name of the applicant and of the Islamic Republic of Iran Shipping Lines (IRISL) on the list set out in Annex I to Decision 2023/1532 and on the list set out in Annex III to Regulation 2023/1529 (‘the lists at issue’).

15 On 13 May 2025, the Council informed the applicant of its intention to maintain his name on the lists at issue on grounds that partly differed from the previous grounds. It also sent him the evidence files bearing the references WK 5620/2025 and WK 5850/2025 of 5 May 2025 (‘the evidence file WK 5620/2025’ and ‘the evidence file WK 5850/2025’), which included the documents supporting the proposed amendment of the grounds for maintaining his name as compared to the previous grounds, and requested him to submit observations in that regard.

16 The grounds for maintaining the applicant’s name on the lists at issue communicated to him on 13 May 2025 were as follows:

‘[The applicant] is the director of the EU-listed Islamic Republic of Iran Shipping Lines (IRISL), which is a major Iranian maritime carrier.

For years, IRISL’s vessels have been implicated in shipping military-related cargo, in particular for the Islamic Revolutionary Guard Corps (IRGC) and some of its branches, notably the (EU-listed) Islamic Revolutionary Guard Corps Navy (IRGCN) and the (EU-listed) Islamic Revolutionary Guard Corps Research and Self-Sufficiency Jihad Organisation (IRGC/SSJO).

The IRGCN converts container ships owned or previously owned by IRISL Group into drone carriers. The IRGCN is part of the IRGC, and includes [a] UAVs division and a missiles division. The IRGCN is involved in Iran’s UAV and missile programmes and involved in transferring Iran’s missiles to armed groups and entities undermining peace and security in the Middle East and the Red Sea region.

The IRGC/SSJO is a research and development unit part of the IRGC that develops and manufactures ground penetrating radar, communication systems, weaponry, combat vehicles and electronic cyberwarfare equipment. The IRGC/SSJO is involved in Iran’s UAV and missile programmes and in transferring Iranian UAVs to [the Russian Federation] in support of its war of aggression against Ukraine.

Therefore, in his principal managerial position as director of IRISL, [the applicant] is involved in transferring Iran’s UAVs or missiles or related technologies to [the Russian Federation] in support of its war of aggression against Ukraine and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region, and is associated with branches of the IRGC, in particular the (EU-listed) IRGC/SSJO and the (EU-listed) IRGCN.’

17 By letter of 27 May 2025, the applicant sent the Council his observations on the grounds for maintaining his name on the lists at issue and on the evidence files bearing the references WK 5620/2025 and WK 5850/2025 that had been communicated to him on 13 May 2025, as well as new supporting documents.

18 By letter of 30 June 2025, the Council sent the applicant a new version of the grounds for maintaining his name on the lists at issue and the evidence file bearing the reference WK 8622/2025 of 23 June 2025 (‘the evidence file WK 8622/2025’), which included documents in support of those grounds for maintaining his name, and requested him to submit his observations in that regard.

19 The new version of the grounds for maintaining the applicant’s name on the lists at issue, sent to him on 30 June 2025, was worded as follows:

‘[The applicant] is the director of the EU-listed Islamic Republic of Iran Shipping Lines (IRISL), which is a major Iranian maritime carrier.

For years, ships belonging to or managed by IRISL or its affiliated companies have been implicated in shipping military-related cargo and other activities aimed at providing support to [the Russian Federation] in support of its war of aggression against Ukraine and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region, in particular in relation with the Islamic Revolutionary Guard Corps (IRGC) and some of its branches, notably the (EU-listed) Islamic Revolutionary Guard Corps Navy (IRGCN) and the (EU-listed) Islamic Revolutionary Guard Corps Research and Self-Sufficiency Jihad Organisation (IRGC/SSJO).

The IRGCN converts container ships owned or previously owned by IRISL Group into drone carriers. The IRGCN is part of the IRGC, and includes [a] UAVs division and a missiles division.

The IRGCN is involved in Iran’s UAV and missile programmes and involved in transferring Iran’s missiles to armed groups and entities undermining peace and security in the Middle East and the Red Sea region.

20 By letter of 10 July 2025, the applicant sent the Council his observations on the new version of the grounds for maintaining his name on the lists at issue and on the evidence file WK 8622/2025 that had been communicated to him on 30 June 2025.

21 On 25 July 2025, the Council adopted the July 2025 maintaining acts.

22 The grounds for maintaining the applicant’s name on the lists at issue were worded as follows:

‘[The applicant] is the director of the EU-listed Islamic Republic of Iran Shipping Lines (IRISL), which is a major Iranian maritime carrier.

For years, ships belonging to or managed by IRISL or its affiliated companies, have been implicated in shipping military related cargo and other activities aimed at providing support to [the Russian Federation] in support of its war of aggression against Ukraine and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region, in particular in relation with the Islamic Revolutionary Guard Corps (IRGC) and some of its branches, notably the (EU-listed) Islamic Revolutionary Guard Corps Navy (IRGCN) and the (EU-listed) Islamic Revolutionary Guard Corps Research and Self-Sufficiency Jihad Organisation (IRGC/SSJO).

The (EU-listed) Islamic Revolutionary Guard Corps Navy (IRGCN) converts container ships owned or previously owned by IRISL Group into drone carriers. The IRGCN is part of the IRGC, and includes an unmanned aerial vehicle (UAV) division and a missiles division. The IRGCN is involved in Iran’s UAV and missile programmes and involved in transferring Iran’s missiles to armed groups and entities undermining peace and security in the Middle East and the Red Sea region.

The IRGC/SSJO is a research and development unit that is part of the IRGC that develops and manufactures ground penetrating radar, communication systems, weaponry, combat vehicles and electronic cyberwarfare equipment. The IRGC/SSJO is involved in Iran’s UAV and missile programmes and in transferring Iranian UAVs to [the Russian Federation] in support of its war of aggression against Ukraine.

Therefore, in his principal managerial position as director of IRISL, Mohammad Reza Khiabani is involved in transferring Iran’s UAVs or missiles or related technologies to [the Russian Federation] in support of its war of aggression against Ukraine and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region, and is associated with branches of the IRGC, in particular the (EU-listed) IRGC/SSJO and the (EU-listed) IRGCN.’

23 By document of 6 October 2025, on the basis of Article 86 of the Rules of Procedure of the General Court, the applicant lodged a statement of modification, seeking also the annulment of the July 2025 maintaining acts, in so far as they concerned him.

24 On 6 November 2025, the Council lodged its observations on the statement of modification of the application.

II. Forms of order sought

25 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.

26 The Council contends that the Court should:

– dismiss the action as unfounded;

– order the applicant to pay the costs;

– in the alternative:

– in the event that it annuls in part Decision 2024/2894 and Implementing Regulation 2024/2896, in so far as they concern the applicant, order that the effects of Decision 2024/2894 be maintained until the partial annulment of Implementing Regulation 2024/2896 takes effect;

– in the event that it annuls in part Decision 2025/1547 and Implementing Regulation 2025/1548, in so far as they concern the applicant, order that the effects of Decision 2025/1547 be maintained until the partial annulment of Implementing Regulation 2025/1548 takes effect.

III. Law

27 The applicant raises five pleas in law in support of his action. The first plea alleges a failure to discharge the burden of proof. The second plea alleges an error of law. The third plea alleges a breach of the right to effective judicial protection and of the rights of the defence. The fourth plea alleges an error of assessment. The fifth plea alleges an infringement of Article 17 of the Charter of Fundamental Rights of the European Union (‘the Charter’) and a failure to observe the principle of proportionality.

28 It is appropriate to examine, first of all, the third plea, then the second plea, then the first and fourth pleas together, and, lastly, the fifth plea.

A. The third plea in law, alleging a breach of the right to effective judicial protection and of the rights of the defence

29 The applicant claims that, in the context of the adoption of the November 2024 listing acts and the July 2025 maintaining acts, the Council infringed his right to effective judicial protection and his rights of defence.

1. Whether there was a breach of the right to effective judicial protection and of the rights of the defence in the context of the adoption of the November 2024 listing acts

30 The applicant submits that, since the Council has not demonstrated that it based the inclusion of his name on the lists at issue solely on the evidence in the evidence file WK 12709/2024 DCL1, which post-dates the adoption of the November 2024 listing acts, he was deprived of the ability to exercise fully his rights of defence, in particular to verify, challenge and respond effectively to the evidence forming the basis of that listing.

31 In addition, the applicant claims that the fact that the Council did not grant him access to the evidence on which the inclusion of IRISL’s name on the lists at issue was based in so far as it is associated with the Islamic Revolutionary Guard Corps Navy (IRGCN), whereas his name is itself included on those lists on the ground that he is associated with the IRGCN in his capacity as director of IRISL, infringed his rights of defence and his right to effective judicial protection.

32 The Council disputes the applicant’s line of argument.

33 In the first place, as regards the applicant’s complaint that, in essence, he did not have access to all of the documents, contained in the evidence file WK 12709/2024 DCL1 on which the Council based its assessment, which infringed his right to be properly heard on those documents, it should be noted that respect for the rights of the defence, which is enshrined in Article 41(2) of the Charter, consists of the right to be heard and the right to have access to the file, subject to legitimate interests in maintaining confidentiality (judgments 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, paragraphs 98 and 99, and of 16 July 2014, Hassan v Council, T‑572/11, EU:T:2014:682, paragraph 48).

34 The right to be heard in all proceedings, laid down in Article 41(2)(a) of the Charter, guarantees every person the opportunity to make known his or her views effectively during an administrative procedure and before the adoption of a decision in relation to that person that is liable to affect his or her interests adversely (see, to that effect, judgment of 27 July 2022, RT France v Council, T‑125/22, EU:T:2022:483, paragraph 75 and the case-law cited).

35 In proceedings relating to the adoption of the decision to list the name of an individual in the annex to an act imposing restrictive measures, respect for the rights of the defence requires that the competent EU authority disclose to the individual concerned the grounds and the evidence against that person on which that authority proposes to base its decision. When that disclosure takes place, the competent EU authority must ensure that that individual is placed in a position in which he or she may effectively make known his or her views on the grounds advanced against him or her (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, paragraphs 111 and 112).

36 Article 52(1) of the Charter nevertheless allows limitations on the exercise of the rights enshrined in the Charter, subject to the conditions that the limitation concerned respects the essence of the fundamental right in question and, subject to the principle of proportionality, that it is necessary and genuinely meets objectives of general interest recognised by the European Union (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 101 and the case-law cited). In that regard, the Court of Justice has on many occasions held that the rights of the defence may be subject to limitations or derogations, both in the area of restrictive measures adopted in the context of the common foreign and security policy (CFSP) (see, to that effect, judgment of 21 December 2011, France v People’s Mojahedin Organization of Iran, C‑27/09 P, EU:C:2011:853, paragraph 67 and the case-law cited) and in other areas (see, to that effect, judgments of 15 June 2006, Dokter and Others, C‑28/05, EU:C:2006:408, paragraphs 75 and 76, and of 10 September 2013, G. and R., C‑383/13 PPU, EU:C:2013:533, paragraph 33).

37 It thus follows from the case-law that, where there is an initial decision to include the name of a person or an entity on the list of persons and entities whose funds are frozen, the Council is not obliged to inform the person or entity concerned beforehand of the grounds on which that institution intends to rely for the inclusion of that name on the list. So that its effectiveness may not be jeopardised, such a measure must be able to take advantage of a surprise effect and to apply immediately (see, to that effect, judgment of 21 December 2011, France v People’s Mojahedin Organization of Iran, C‑27/09 P, EU:C:2011:853, paragraph 61). Upon application to the Council, the person or entity concerned also has the right to make known their view on that evidence after the measure has been adopted (judgment of 20 February 2013, Melli Bank v Council, T‑492/10, EU:T:2013:80, paragraph 72).

38 Furthermore, it should be noted that, as regards the right of access to the file, it is only on the request of the party concerned that the Council is required to provide access to all non-confidential official documents concerning the measure at issue (judgment of 16 September 2013, Bank Kargoshaei and Others v Council, T‑8/11, not published, EU:T:2013:470, paragraph 68).

39 Overriding considerations to do with the security of the European Union or of its Member States or with the conduct of their international relations may preclude the disclosure of some information or some evidence to the person concerned. In such circumstances, it is nonetheless the task of the EU Courts, before whom the secrecy or confidentiality of that information or evidence is no valid objection, to apply, in the course of the judicial review to be carried out, techniques which accommodate, on the one hand, legitimate security considerations about the nature and sources of information taken into account in the adoption of the act concerned and, on the other, the need sufficiently to guarantee to an individual respect for his or her procedural rights, such as the right to be heard and the requirement for an adversarial process (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 125).

40 In the present case, it should be noted that the applicant does not dispute that the evidence file WK 12709/2024 DCL1, which was sent to him by the Council at his request, constitutes the declassified version of the evidence file WK 12709/2024 on which the Council based its assessment before the adoption of the November 2024 listing acts. He submits, however, that there is nothing to demonstrate that the latter evidence file did not contain any additional evidence on which the Council based its assessment. The applicant claims in particular that the evidence file WK 12709/2024 DCL1 contains only the first page of the documents referred to therein.

41 In that regard, it should be noted that the evidence file WK 12709/2024 DCL1 contains the following nine items of evidence:

– a press article by the Israeli online media i24 News, which appeared on 15 January 2021, accessed on 9 August 2024, concerning the decision of the United States of America to impose sanctions on the applicant, in view of his role as ‘IRISL chief’ and, therefore, his involvement in the proliferation of weapons of mass destruction (exhibit 1);

– a press article by the Iranian daily newspaper Tehran Times, which was published online on 28 July 2019, accessed on 9 August 2024, concerning the appointment of the applicant as the ‘new head of IRISL’, following his role as a member of the board of directors of that company (exhibit 2);

– an article from the website Intelligence Online, which was published on 17 December 2021, accessed on 9 August 2024, concerning the increase in IRISL’s annual turnover, despite the United States sanctions, and the appointment of the applicant as director of IRISL in 2019 (exhibit 3);

– a press article by the Iranian daily newspaper Tehran Times, which was published online on 30 August 2023, accessed on 9 August 2024, concerning the applicant’s role as director of IRISL and the success of his managerial choices, which made it possible to register new historical records in the transportation of goods and to activate the North-South corridor to promote trade with northern neighbours and the Caspian Sea coastal nations (exhibit 4);

– an article from the website Trade Wings, which specialises in global maritime transport, which was published on 8 November 2023, accessed on 9 August 2024, referring to the applicant as the ‘Head of IRISL’ and ‘Managing Director of IRISL’, as well as his concerns about the ageing nature of the Iranian commercial fleet (exhibit 5);

– an article by the Iran Chamber of Commerce, Industries, Mines and Agriculture, which was published online on 17 September 2020, accessed on 9 August 2024, referring to the high turnover achieved by IRISL in 2021 (778 million United States dollars), despite the United States sanctions, and referring to the applicant as the ‘IRISL CEO’; according to him, that turnover is achieved despite the sanctions and the coronavirus pandemic (exhibit 6);

– an article by the Middle East Institute (MEI), which was published online on 7 March 2023, accessed on 23 September 2024, concerning the IRGCN’s conversion of merchant container ships owned by the IRISL Group into drone carriers, namely the Shahid Mahdavi and the Shahid Begheri (exhibit 7);

– a press article from the website Malta ship photos & Action photos, which was published on 14 February 2024, accessed on 23 September 2024, reporting the fact that the IRGCN claimed the successful launch of two ballistic missiles from the Shahid Mahdavi, which was a commercial vessel converted into an aircraft carrier and identified as an IRISL vessel (exhibit 8);

– an article from the website Military Watch Magazine, which was published on 21 August 2024, accessed on 23 September 2024, referring to the IRGCN’s successful conversion of the merchant container ship Shahid Bagheri into an aircraft carrier and referring to the forthcoming completion of the conversion of the vessel Shahid Mahdavi into a drone carrier (exhibit 9).

42 It should be noted that the first page in the evidence file WK 12709/2024 DCL1 sent by the European External Action Service (EEAS) to the Member States’ delegations refers to the fact that that declassified version of the evidence file WK 12709/2024 is identical to the classified version.

43 It should also be noted that none of the items of evidence referred to in paragraph 41 above gives any indication that it contains information that is still confidential.

44 It should also be noted that the nine items of evidence in question come from open sources and that, although it is true that exhibits 5, 6, 8 and 9 in the evidence file WK 12709/2024 DCL1 contain only partial screenshots of articles, they nevertheless mention the internet addresses where those articles are accessible in their entirety.

45 In those circumstances, it must be held that the evidence file WK 12709/2024 DCL1, in itself, contains no indication that the Council based its assessment, as regards the inclusion of the applicant’s name on the lists at issue, on evidence other than that set out in that evidence file. That mere finding is sufficient to reject the applicant’s line of argument that the fact that that evidence file post-dates the adoption of the November 2024 listing acts means that the Council infringed his rights of defence, with the result that it is not necessary to ask the Council to produce the classified version of the evidence file WK 12709/2024 DCL1.

46 Furthermore, it should be noted that, in the context of the present plea, the applicant cites Article 48 of the Charter, entitled ‘Presumption of innocence and right of defence’, but without relying on specific arguments. In that regard, it should be noted that the applicant has failed to explain in what respect he could rely on Article 48(2) of the Charter or derive from that provision a protection differing from, or greater than, the protection he could derive from the application of Article 41(2)(a) of the Charter. In those circumstances, there is no need to examine independently a complaint alleging infringement of Article 48 of the Charter (see, to that effect, judgments of 22 September 2015, First Islamic Investment Bank v Council, T‑161/13, EU:T:2015:667, paragraph 68; of 27 July 2022, RT France v Council, T‑125/22, EU:T:2022:483, paragraph 101; and of 22 January 2025, Norddeutsche Landesbank – Girozentrale v SRB (2022 ex ante contributions), T‑407/22, EU:T:2025:56, paragraph 259).

47 In the second place, as regards the applicant’s complaint that, in breach of his rights of defence and his right to effective judicial protection, the Council did not grant him access to the evidence forming the basis of the inclusion of IRISL’s name on the lists at issue in so far as IRISL is associated with the IRGCN, it should be noted that it is apparent from Annex B2 to the defence that, on 7 January 2025, two separate letters were sent to the Council by Mr Valerijus Ostrovskis, namely a lawyer instructed, in one case by IRISL, which was represented by the applicant acting as director of IRISL and, in the other case, by the applicant himself. In the first letter, access to the file was requested in the light of the restrictive measures adopted against IRISL pursuant to the November 2024 listing acts. In the second letter, access to the file was requested in the light of the restrictive measures adopted against the applicant pursuant to those acts.

48 They were therefore formally two separate requests for access concerning two separate administrative procedures.

49 However, it should be noted that the Council responded to those requests by letter of 13 January 2025 sent to the lawyer of the applicant and of IRISL, in which the Council stated that the relevant information concerning the applicant was contained in the evidence file WK 12709/2024 DCL1, whereas the relevant information concerning IRISL was contained in the evidence file WK 12325/2024 DCL1; those evidence files were annexed to that letter.

50 It follows that, by the letter of 13 January 2025, the Council intended to give the applicant access both to the evidence directly concerning him and to the evidence regarding IRISL.

51 Accordingly, the applicant is not justified in claiming that his rights of defence were impeded by a failure to disclose the evidence relied on by the Council against IRISL.

52 Furthermore, it should be noted that the applicant’s argument is, moreover, unrelated to any breach of his right to effective judicial protection provided for in Article 47 of the Charter.

53 It must be noted that the effectiveness of the judicial review guaranteed by Article 47 of the Charter requires 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 an entity on the list of persons and entities subject to restrictive measures, the EU Courts are to ensure that that decision, which affects that person or that entity individually, is taken on a sufficiently solid factual basis. That entails a verification of the factual allegations in the summary 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 judgment of 16 October 2024, CRA v Council, T‑201/23, EU:T:2024:697, paragraph 61 and the case-law cited).

54 In that context, it is the task of the competent EU authority, in the event of challenge, to establish 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 judgment of 16 October 2024, CRA v Council, T‑201/23, EU:T:2024:697, paragraph 62 and the case-law cited).

55 It follows that, although a failure to communicate to the person concerned the evidence on which the Council based the adoption of restrictive measures against that person in the context of the administrative procedure is capable of leading to a breach of that person’s rights of defence in the context of that procedure, it cannot warrant a presumption that there has been a breach of that person’s right to effective judicial protection in the context of an action brought before the General Court.

56 In the light of the foregoing considerations, the third plea in law must be rejected as unfounded in so far as it concerns the November 2024 listing acts.

2. The breach of the right to effective judicial protection and of the rights of the defence in the context of the adoption of the July 2025 maintaining acts

57 The applicant submits that the statement of reasons for the July 2025 maintaining acts asserts that he is involved in the alleged activities ‘in his principal managerial position as director of IRISL’, yet it fails to demonstrate how his personal conduct meets the requirements of the relevant listing criteria, namely that he maintains association links, understood as common interests, with the IRGCN or the IRGC/SSJO. In his view, no such individual evidence has been provided.

58 The applicant adds that the Council’s approach also undermines the Court’s ability to carry out an effective judicial review, since the Council relies on evidence concerning IRISL which is unrelated to the applicant. In his view, the contested acts are not based on specific evidence concerning him, but rather on separate proceedings involving a separate legal entity.

59 The Council disputes the applicant’s line of argument.

60 It should be noted that the applicant claims that the evidence produced by the Council does not concern his personal conduct, but only IRISL, and does not demonstrate that he is associated with the IRGCN or the IRCG/SSJO.

61 In that regard, it must be held that such a line of argument does not relate to respect for the applicant’s rights of defence or right to effective judicial protection, but relates to whether the factual basis on which the Council relied in the light of the allegations contained in the July 2025 maintaining acts is sufficient, in so far as the applicant is concerned.

62 Accordingly, the third plea in law must be rejected in its entirety as unfounded.

B. The second plea in law, alleging an error of law

63 The applicant submits that the Council erred in law in its interpretation of the association criterion laid down in Article 3(1)(c) of Decision 2023/1532.

1. Error of law relating to the November 2024 listing acts

64 The applicant submits that the Council erred in law in justifying the inclusion of his name on the lists at issue, under the criterion set out in Article 3(1)(c) of Decision 2023/1532 and Regulation 2023/1529, by relying on his role as director of IRISL, whose name was included on those lists because of its association with the IRGCN.

65 The applicant states that the name of a person or entity may be included on the lists at issue, under the criterion set out in Article 3(1)(c) of Decision 2023/1532 and Regulation 2023/1529, only if that person or entity is associated with a person or entity who or which itself is included on those lists under one of the criteria set out in Article 3(1)(a) and (b) of that decision and of that regulation.

66 The applicant submits that, in the present case, it is apparent both from the draft statement of reasons contained in the evidence file WK 12709/2024 DCL1, which states that the applicant ‘is associated with IRISL as the Director of [that] entity’, and from the documents in that evidence file, which do not establish any link between him and the IRGCN, that the Council included his name on the lists at issue on account of his association with IRISL.

67 The applicant argues that, in so far as the Council submits that his name was included on the lists at issue on the ground that he is the director of IRISL and that he can, consequently, be held responsible for IRISL’s conduct, such an approach amounts to the use of a ‘second degree’ association. In his view, such an association is not, however, capable of demonstrating a personal association between him and the IRGCN and has been rejected by the General Court, on account of such an association being too broad in nature, in the judgment of 11 September 2024, Tokareva v Council (T‑744/22, EU:T:2024:608).

68 Furthermore, the Council cannot, the applicant argues, justify that approach by referring to the case which gave rise to the judgment of 12 December 2013, Nabipour and Others v Council (T‑58/12, not published, EU:T:2013:640), since that judgment concerned a different regime of restrictive measures and a specific situation in which the names of certain persons had been included on lists because of their direct links with IRISL and due to the allegedly unlawful conduct of IRISL in connection with the nuclear proliferation programme in which IRISL was itself accused. It is in that specific scenario, which differs from the present case, where IRISL’s name is listed because of its association with the IRGCN, that a management function was considered sufficient to list the individual because that function implied direct responsibility for the entity’s own activities, which were directly liable to be subject to sanctions.

69 The Council disputes the applicant’s line of argument.

70 It should be noted that the criterion set out in Article 3(1)(c) of Decision 2023/1532 and of Regulation 2023/1529 covers only natural or legal persons, entities or bodies associated with natural or legal persons, entities or bodies referred to in Article 3(1)(a) and (b) of that decision and of that regulation.

71 It follows that the very wording of Article 3(1)(c) of Decision 2023/1532 and of Regulation 2023/1529 excludes the possibility that the name of a natural or legal person, entity or body may be included on the lists at issue on the ground of his, her or its association with a natural or legal person, entity or body whose name is included on those lists solely on the basis of that provision.

72 In the present case, it must be noted at the outset that the fact that the draft statement of reasons proposed by the EEAS stated that the applicant was ‘associated with IRISL as the Director of [that] entity’ is not such as to demonstrate that the Council erred in law in that regard.

73 As the Council correctly submits, it follows from the statement of reasons for the November 2024 listing acts that, on the basis of the evidence that had been submitted to it by the EEAS, the Council justified the inclusion of the applicant’s name on the lists at issue by the fact that, in his capacity as director of IRISL, he was associated with the IRGCN.

74 It should be noted that the name of the IRGCN was, at the time of the adoption of the November 2024 listing acts, included on the lists at issue under the criterion set out in Article 3(1)(b)(ii) of Decision 2023/1532 and of Regulation 2023/1529.

75 It follows that, contrary to what the applicant claims, the circumstances of the present case differ from those which gave rise to the judgment of 11 September 2024, Tokareva v Council (T‑744/22, EU:T:2024:608), in which the Court found that the Council had erred in law in justifying the adoption of restrictive measures against a natural person by her association with another natural person who himself was subject to those restrictive measures on account of his association with his own father.

76 Furthermore, contrary to what the applicant claims, it does not follow from the case-law that the Council cannot justify the adoption of restrictive measures against a natural person by imputing to him or her the conduct of a legal person or entity within which that natural person carries out the main management function.

77 As the Council submits, in the case which gave rise to the judgment of 12 December 2013, Nabipour and Others v Council (T‑58/12, not published, EU:T:2013:640), the Court was seised in respect of the legality of restrictive measures in connection with the fight against nuclear proliferation; those measures had been adopted against persons having professional or capital ties with IRISL, pursuant to Council Decision 2010/413/CFSP of 26 July 2010 concerning restrictive measures against Iran and repealing Common Position 2007/140/CFSP (OJ 2010 L 195, p. 39).

78 It was in that context that the General Court held that, as a general rule, where the natural person in question holds a post within either an entity that is directly involved in nuclear proliferation activities, or a company acting on behalf of such an entity or a company assisting a designated person in evading sanctions, it is sufficient, for the purposes of demonstrating that that individual is involved in unlawful conduct, that the Council establishes that he or she holds the principal managerial position in that entity or company, and thus assumes responsibility for the activities of the entity or company which he or she manages. If, on the other hand, the individual in question, holding a managerial, senior or executive position, is linked to the entity concerned or to the company by a relationship of subordination, it is incumbent on the Council to establish, on the basis of a body of precise and consistent evidence, that that person is capable of influencing the activities alleged against the company or the entity employing him or her (judgment of 12 December 2013, Nabipour and Others v Council, T‑58/12, not published, EU:T:2013:640, paragraph 110).

79 It should be noted that, as the Council correctly submits, the fact that that institution may justify the adoption of restrictive measures against a natural person by attributing to him or her the conduct of a legal person or entity has also been recognised by the Court where the person concerned owned a newspaper and was in a position to influence its editorial line (judgment of 7 February 2024, Usmanov v Council, T‑237/22, not published, under appeal, EU:T:2024:56, paragraph 151) or was a shareholder capable of exercising control over the entity in question and had not distanced themself from the actions of that entity (see, to that effect, judgments of 6 September 2023, Timchenko v Council, T‑252/22, not published, EU:T:2023:496, paragraphs 120 and 121, and of 20 September 2023, Mordashov v Council, T‑248/22, not published, EU:T:2023:573, paragraphs 112 to 121).

80 Similarly, contrary to what the applicant claims, the fact that his name is included on the lists at issue under the criterion set out in Article 3(1)(c) of Decision 2023/1532 and of Regulation 2023/1529, and not under the criteria set out in Article 3(1)(a) and (b) of that decision and of that regulation, is irrelevant to the question of whether IRISL’s conduct could be attributed to him in so far as he is its director.

81 In the light of the foregoing considerations, the Council did not err in law in justifying the inclusion of the applicant’s name on the lists at issue under the criterion set out in Article 3(1)(c) of Decision 2023/1532 and of Regulation 2023/1529 in so far as he is the director of IRISL.

82 Accordingly, the second plea in law must be rejected as unfounded in so far as it concerns the November 2024 listing acts.

2. Error of law relating to the July 2025 maintaining acts

83 The applicant submits that, as was the case with the November 2024 listing acts, the Council erred in law in justifying the maintenance of his name on the lists at issue, both under the criterion set out in Article 3(1)(c) of Decision 2023/1532 and under the criterion set out in Article 3(1)(b) of that decision, by the fact that he is the director of IRISL and by therefore attributing to him the conduct of IRISL.

84 In addition, the applicant submits that the Council unlawfully merged the criteria set out in Article 3(1)(b) and (c) of Decision 2023/1532 by justifying the maintenance of his name on the lists at issue in both cases as arising from his role as director of IRISL, even though the case-law requires that each reason for inclusion on those lists be substantiated independently on the basis of concrete and specific evidence.

85 The Council disputes the applicant’s line of argument.

86 It should be noted that it is apparent from the statement of reasons for the July 2025 maintaining acts that the Council justified the maintenance of the applicant’s name on the lists at issue by the fact that ‘in his principal managerial position as director of IRISL, [the applicant] is involved in transferring Iran’s UAVs or missiles or related technologies to [the Russian Federation] in support of its war of aggression against Ukraine and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region, and is associated with branches of the IRGC, in particular the (EU-listed) IRGC/SSJO and the (EU-listed) IRGCN.’

87 At the outset, it is necessary to reject the applicant’s argument that the Council erred in law in justifying the maintenance of his name on the lists at issue under the criteria set out in Article 3(1)(b)(i) and (ii) and (c) of Decision 2023/1532 and of Regulation 2023/1529 by the fact that he held the position of director of IRISL, for the same reasons as those set out in paragraphs 76 to 79 above.

88 Furthermore, it should be noted that, contrary to what the applicant claims, it does not follow from the judgments of 25 January 2017, Almaz-Antey Air and Space Defence v Council (T‑255/15, not published, EU:T:2017:25, paragraph 59), and of 15 June 2017, Kiselev v Council (T‑262/15, EU:T:2017:392, paragraph 43), that the specific conduct of a person, entity or body cannot justify, as a matter of principle, the adoption of restrictive measures against that person on the basis of separate criteria.

89 In the judgments of 25 January 2017, Almaz-Antey Air and Space Defence v Council (T‑255/15, not published, EU:T:2017:25, paragraph 59), and of 15 June 2017, Kiselev v Council (T‑262/15, EU:T:2017:392, paragraph 43), the Court merely found that, although the statement of reasons for the acts by which restrictive measures had been adopted or maintained did not explicitly state the criteria on which the Council had relied in order to adopt or maintain those measures, the criteria applied were sufficiently clear from that statement of reasons.

90 However, in the present case, it must be noted that the last sentence of the statement of reasons for the July 2025 maintaining acts reproduces the wording of the criteria set out in Article 3(1)(b)(i) and (ii) and (c) of Decision 2023/1532 and of Regulation 2023/1529.

91 In those circumstances, the Council did not err in law in justifying the maintenance of the applicant’s name on the lists at issue on the basis of the criteria set out in Article 3(1)(b)(i) and (ii) and (c) of Decision 2023/1532 and of Regulation 2023/1529 by the fact that he held the principal position of director of IRISL.

92 The second plea in law must therefore also be rejected as unfounded in so far as it concerns the July 2025 maintaining acts.

C. The first and fourth pleas in law, alleging a lack of a sufficient factual basis and an error of assessment

93 In the context of the first and fourth pleas in law, the applicant disputes that the inclusion and maintenance of his name on the lists at issue by the November 2024 listing acts and the July 2025 maintaining acts were well founded.

94 It must be recalled that the effectiveness of the judicial review guaranteed by Article 47 of the Charter requires, in particular, that the EU Courts ensure that the decision by which restrictive measures were adopted or maintained, which affects the person or entity concerned individually, is taken on a sufficiently solid factual basis. That entails a verification of the factual allegations in the summary 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, is 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).

95 Such an assessment must be carried out by examining the evidence and information not in isolation but in its context. The Council discharges the burden of proof borne by it if it presents to the EU Courts a body of evidence sufficiently specific, precise and consistent to establish that there is a sufficient link between the person or entity subject to a measure freezing its funds and the regime or, in general, the situations being combated (see, to that effect, judgment of 20 July 2017, Badica and Kardiam v Council, T‑619/15, EU:T:2017:532, paragraph 99 and the case-law cited).

96 It is for the EU Courts, in order to carry out that examination, to request the competent EU authority, when necessary, to produce information or evidence, confidential or not, relevant to such an examination (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 120 and the case-law cited).

97 That is because 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).

98 For that purpose, there is no requirement that that authority produce before the EU Courts all the information and evidence underlying the reasons alleged in the act whose annulment is sought. It is however necessary that the information or evidence produced should support the reasons relied on against 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 122).

99 If the competent EU authority provides relevant information or evidence, the EU Courts 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).

100 In that regard, it is important to recall that, in the absence of investigative powers in third countries, the assessment of the EU authorities must rely on publicly available sources of information, reports, articles in the press, intelligence reports or other similar sources of information (judgments of 14 March 2018, Kim and Others v Council and Commission, T‑533/15 and T‑264/16, EU:T:2018:138, paragraph 107, and of 1 June 2022, Prigozhin v Council, T‑723/20, not published, EU:T:2022:317, paragraph 59).

101 It would be excessive and disproportionate to require the Council itself to investigate on the ground the accuracy of facts which are relayed by numerous media (judgments of 1 June 2022, Prigozhin v Council, T‑723/20, not published, EU:T:2022:317, paragraph 59, and of 7 May 2025, Anwar Akkad v Council, T‑502/23, not published, EU:T:2025:445, paragraph 58).

102 Press articles may thus be used in order to support the existence of certain facts if they come from several different sources and are sufficiently specific, precise and consistent as regards the facts described therein (see judgment of 11 September 2019, Topor-Gilka and WO Technopromexport v Council, T‑721/17 and T‑722/17, not published, EU:T:2019:579, paragraph 137 and the case-law cited).

103 It is in the light of those considerations that it must be examined whether the inclusion and maintenance of the applicant’s name on the lists at issue were well founded.

1. Whether the inclusion of the applicant’s name on the lists at issue by the November 2024 listing acts was well founded

104 The applicant submits, in essence, that the allegations set out in the statement of reasons for the November 2024 listing acts are not supported to the requisite legal standard by the documents contained in the evidence file WK 12709/2024 DCL1 and that the Council made an error of assessment in finding that those allegations justified the inclusion of his name on the lists at issue under the criterion laid down in Article 3(1)(c) of Decision 2023/1532.

(a) Whether the allegations contained in the statement of reasons for the November 2024 listing acts are materially accurate

105 The applicant calls into question the material accuracy of the allegations contained in the statement of reasons for the November 2024 listing acts. In particular, he denies that he is associated with the IRGCN, within the meaning of the criterion laid down in Article 3(1)(c) of Decision 2023/1532.

106 It is apparent from the grounds of the November 2024 listing acts, set out in paragraph 11 above, that the Council justified the inclusion of the applicant’s name on the lists at issue by the contention, based on Article 3(1)(c) of Decision 2023/1532, that he was associated with an entity, namely the IRGCN, whose conduct is covered by Article 3(1)(a) and Article 3(1)(b)(ii) of that decision.

107 According to the Council, first, the applicant was the director of IRISL, the name of which is included on the lists at issue, and, second, IRISL vessels have, for years, been involved in shipping military-related cargo and the IRGCN converts container ships owned by IRISL into drone carriers.

108 In order to justify the inclusion of the applicant’s name on the lists at issue by the November 2024 listing acts, the Council provided the documents contained in the evidence file WK 12709/2024 DCL1 comprising the nine documents referred to in paragraph 41 above, concerning the applicant, and provided the evidence file WK 12325/2024 DCL1, concerning IRISL.

109 The evidence file WK 12325/2024 DCL1 contains the following 20 documents:

– an article which appeared on 20 June 2020 on the website Iran Watch, accessed on 9 August 2024 (exhibit 1);

– an article in Russian which appeared on 30 April 2019 on the website ‘dzen.ru’, accessed on 9 August 2024, together with a translation thereof, concerning the vessel Shahr E Kord (exhibit 2);

– a screenshot of a page dated 7 June 2023 from the website ‘balticshipping.com’, accessed on 9 August 2024, concerning the vessel Shahr E Kord (exhibit 3);

– an article in Hebrew which appeared on 13 March 2024 on the website Intelli Times, accessed on 9 August 2024, concerning the transport of military equipment by the vessels Azargoun, Arezoo, Shiba, Kashan and Daisy since 2022, between the port of Bandar Abbas in Iran and the port of Latakia in Syria (exhibit 4);

– an article which appeared on 19 January 2021 on the website ‘sayari.com’, accessed on 9 August 2024, concerning the way in which IRISL used front companies established in third countries to hide the fact that it was the owner and manager of four vessels subject to sanctions adopted by the United States of America (exhibit 5);

– a screenshot of the website Maritime Informed, accessed on 9 August 2024, concerning the assistance provided by IRISL to Iran’s Ministry of Defence and Armed Forces Logistics, as well as to subordinates thereof, including the Aerospace Industries Organization, Defense Industries Organization, and the Shahid Hemmat Industrial Group (exhibit 6);

– an extract from a report of the panel of experts set up in accordance with United Nations Security Council Resolution 1874 (2009) of 12 June 2009, published on 4 March 2021, accessed on 23 September 2024, concerning a request for information addressed to the Islamic Republic of Iran by that panel in relation to information received by it concerning the involvement of the Korea Mining Development Trading Corporation (KOMID) and the Shahid Haj Ali Movaeh Research Center (SHIG) in shipments to the Islamic Republic of Iran, using vessels belonging to IRISL, of materials related to the cooperation between the Islamic Republic of Iran and the Democratic People’s Republic of Korea in the field of ballistic missiles (exhibit 7);

– an article which appeared on 4 January 2023 on the website The Maritime Executive, accessed on 23 September 2024, concerning the IRGC’s project of converting container ships, from vessels of IRISL, into warships (exhibit 8);

– an article which appeared on 7 March 2023 on the website The Middle East Institute, accessed on 23 September 2024, concerning the creation by the IRGCN, from two container ships owned by IRISL, of its first aircraft carriers, namely the Shahid Mahdavi and the Shahid Bagheri (exhibit 9);

– an article which appeared on 14 February 2024 on the website Malta ship photos & Action photos, accessed on 23 August 2024, concerning the announcement by the IRGC of a test that had fired two ballistic missiles from the deck of the warship Shahid Mahdavi (exhibit 10);

– an article which appeared on 21 August 2024 on the website Military Watch Magazine, accessed on 23 September 2024, concerning the publication by Iranian media of the first clear footage of the first Iranian aircraft carrier, namely the Shahid Mahdavi (exhibit 11);

– an article which appeared on 21 August 2024 on the website Foundation for Defense of Democracies, accessed on 23 September 2024, concerning a ceremony held to mark the addition to the IRGCN of two new, Chinese-inspired patrol ships, namely the Shahid Sayad Shirazi and the Shahid Bagheri (exhibit 12);

– an article which appeared on the website Institute for the Study of War, accessed on 23 September 2024, concerning the use by the Islamic Republic of Iran of its navy, of the IRGCN and of IRISL to pursue a naval and maritime strategy in support of its objectives of regional power and influence (exhibit 13);

– an article which appeared on 18 July 2024 on the website Lowy Institute, accessed on 23 September 2024, concerning the long-range threat capability provided to the IRGCN by the warship Shahid Mahdavi (exhibit 14);

– a report published in February 2024 by the United States Defense Intelligence Agency, accessed on 19 April 2024, concerning the use by armed Houthi groups of Iranian missiles and drones to conduct attacks throughout the Middle East (exhibit 15);

– a press release from the United States Navy, which appeared on 15 February 2024 on its website, accessed on 19 April 2024, concerning the interception of a vessel containing weapons, including components of ballistic missiles and underwater drones, shipped by the Islamic Republic of Iran to Houthi groups in breach of United States sanctions (exhibit 16);

– a post from the account SprinterFactory, which appeared on 4 May 2024 on the social network X, accessed on 6 May 2024, concerning the presentation by the Islamic Republic of Iran of the new drone-carrying vessel Shahid Bahman Bagheri, formerly called Sarveen, accompanied by photographs of the vessel in question (exhibit 17);

– a post from the account mhmiranusa, attributed to the journalist Mehdi H., which appeared on 13 March 2023 on the social network X, concerning the launch of an IRGCN drone from the deck of the vessel Shahid Mahdavi (exhibit 18);

– a post from the account IranObserver, which appeared on 24 September 2023 on the social network X, accessed on 6 May 2024, concerning a statement by an IRGCN commander that the IRGC was developing naval drones capable of landing on water and of carrying missiles and bombs (exhibit 19);

– a post from the account IranObserver, which appeared on 5 August 2023 on the social network X, accessed on 6 May 2024, concerning the delivery to the IRGC of hundreds of new strategic systems and equipment in the field of, inter alia, UAVs and missiles, showcased by video screenshots (exhibit 20).

110 It is therefore necessary to ascertain whether the documents referred to in paragraphs 40 and 109 above support to the requisite legal standard the two factual allegations on which the inclusion of the applicant’s name on the lists at issue is based, under the criterion laid down in Article 3(1)(c) of Decision 2023/1532, as set out in the statement of reasons for the November 2024 listing acts.

(1) The allegation that ‘[the IRGCN] converts container ships owned by IRISL Group into drone carriers’

111 The applicant submits that exhibits 1 to 6 in the evidence file WK 12709/2024 DCL1 refer to his role as director of IRISL Group, but do not establish any association between him and the IRGCN. He adds that his role as director does not mean that he played a role in an alleged transfer of vessels to the IRGCN.

112 The applicant disputes the Council’s assertion that ‘[the IRGCN] converts container ships owned by IRISL Group into drone carriers.’ He submits in that regard that IRISL transferred the two vessels, namely the Perarin and the Sarvin, referred to in the evidence file WK 12325/2024 DCL1, to a private buyer with no known affiliation with the IRGCN or other military entities, on 16 February 2022, that is, more than a year before the adoption of Decision 2023/1532, as evidenced by the deeds of sale for those vessels. He states that it is apparent from the extracts from the database of the International Maritime Organization (IMO) that the Shahid Mahdavi is owned by the Iranian Government and that the Shahid Bagheri is owned by the IRGC. He states in that regard that the fact that the IMO register identification number (‘the IMO number’) of each of those vessels was amended following their sale on 16 February 2022 and that those IMO numbers no longer correspond to those under which the vessels belonging to IRISL had been registered confirms that IRISL no longer exercised any control over those vessels after their sale. In the reply, the applicant submits that, contrary to what the Council claims, exhibit 8 in that evidence file is not capable of demonstrating that IRISL owned another container ship converted by the IRGCN into a drone carrier.

113 The Council disputes the applicant’s line of argument.

114 The Council thus submits that exhibits 1 to 6 in the evidence file WK 12325/2024 DCL1 show that the applicant is the director of IRISL and that, in that respect, he is responsible for its strategic choices. Furthermore, it follows, the Council argues, from exhibits 7 to 9 in that evidence file that IRISL owned two merchant ships, namely the Shahid Mahdavi and the Shahid Bagheri, which are currently being, or have been, repurposed by the IRGCN into aircraft carriers capable of carrying and launching ballistic missiles and drones.

115 In response to the applicant’s argument that the vessels Sarvin and Perarin were sold to a third party with no known affiliation with the IRGCN, prior to the adoption of Decision 2023/1532 and Regulation 2023/1529, the Council submits that the applicant has not provided any information concerning the third party in question and has not dispelled the doubts as to the possibility that IRISL used front companies to conceal the fact that it was still the ‘effective’ owner of those vessels at least until they were transferred to the IRGCN for conversion into warships. In the Council’s view, it follows from exhibit 5 in the evidence file WK 12325/2024 DCL1 that IRISL had experience in using front companies to conceal the ownership and management of vessels and to circumvent sanctions.

116 Furthermore, exhibits 8 to 10 in the evidence file WK 12325/2024 DCL1 refer to the vessel Sarvin, renamed the Shahid Bagheri, and the vessel Perarin, renamed the Shahid Mahdavi, as vessels belonging to IRISL before they were transferred to the IRGCN. The Council submits, in that regard, that it did not maintain that IRISL was involved in the conversion of the vessels in question into warships, but, as is clear from the statement of reasons for the November 2024 listing acts, that those vessels were converted into warships by the IRGCN.

117 In addition, the Council submits that the extracts from the IMO register, which are produced by the applicant and post-date the adoption of the November 2024 listing acts, do not provide any information on the change of ownership of the vessels in question over the course of time or when those acts were adopted. Furthermore, the IMO numbers referred to in those extracts do not correspond to the IMO numbers of the vessels Sarvin and Perarin stated in the notarial deeds also produced by the applicant. Moreover, the applicant himself acknowledged in the reply that IMO numbers are irrelevant for the determination of the ownership of vessels.

118 Lastly, the Council submits that, in any event, exhibit 8 in the evidence file WK 12325/2024 DCL1 refers not only to the conversion of the container ships Sarvin and Perarin into warships, but also of another Panamax container ship owned by IRISL, the lines of which were identical to a new IRGC warship, the deck and hull of which had been painted in a coat of haze grey, with gun emplacements on the stern.

119 As a preliminary point, it should be noted that it is apparent from exhibits 1 to 6 in the evidence file WK 12325/2024 DCL1, the content of which is recalled in paragraph 41 above, that the applicant is the ‘Chief Executive Officer (CEO)’ (Director) of IRISL and that he is, on that basis, responsible for the strategic decisions of IRISL, and therefore his argument that that function does not mean that he can necessarily be held responsible for any transfer of vessels owned by IRISL with a view to their conversion into drone carriers by the IRGCN cannot succeed.

120 It is thus inconceivable that, even if such an operation had taken place, it could have been carried out without the agreement, even tacit, of the director of the company that allegedly owned the vessels in question.

121 However, it should be pointed out that the Council’s position as regards the vessels Shahid Mahdavi and Shahid Bagheri, according to which it is apparent from exhibits 7 to 9 in the evidence file WK 12325/2024 DCL1 that those vessels were owned by IRISL until they were transferred to the IRGCN, differs from the allegation set out in the statement of reasons for the November 2024 listing acts.

122 The French-language version of the statement of reasons for the November 2024 listing acts clearly states that ‘l’IRGCN transforme des porte-conteneurs appartenant au groupe IRISL en transporteurs de drones’, that is to say, container ships which are the property of IRISL Group. That is, moreover, borne out by the other language versions of those acts. Thus, the English-language version of that statement of reasons states that ‘the EU-listed Iran’s Islamic Revolutionary Guard Corps Navy (IRGCN) converts container ships owned by IRISL Group into drone carriers’, the Italian-language version of that statement of reasons states that ‘Islamic Revolutionary Guard Corps Navy (IRGCN), inserita nell’elenco dell’UE, converte le navi portacontainer di proprietà dell Gruppo IRISL in navi porta-droni’, and the German-language version of that statement of reasons indicates that ‘die von der EU mit Sanktionen belegte Islamic Revolutionary Guard Corps Navy (IRGCN) wandelt Containerschiffe im Eigentum der IRISL Gruppe in Drohnenträger um.’

123 Nevertheless, in accordance with the case-law, the legality of contested acts may be assessed only on the basis of the elements of fact and law on which they were adopted. The General Court cannot, therefore, substitute the grounds on which those acts are based (see, to that effect, judgment of 12 November 2013, North Drilling v Council, T‑552/12, not published, EU:T:2013:590, paragraph 25).

124 It must be stated that to allow the Council to put forward new individual grounds distinct from those set out in the November 2024 listing acts in order to remedy the absence or inaccuracy of facts in the grounds of those acts would infringe the applicant’s rights of defence and his right to effective judicial protection. Thus, since the applicant did not receive any communication about the new grounds in a timely manner, first, he would be deprived of the possibility effectively to present his views on those grounds in the context of the administrative procedure. Second, he would not be in a position to assess the merits of the listing of his name or the appropriateness of bringing an action. The principle of equality of the parties before the EU Courts would thus be undermined (see, to that effect, judgment of 12 November 2013, North Drilling v Council, T‑552/12, not published, EU:T:2013:590, paragraph 26).

125 It follows that, for that reason alone, the Council’s argument that IRISL retained ownership of the vessels Shahid Mahdavi and Shahid Bagheri until they were transferred to the IRGCN must be rejected.

126 In any event, it must be noted that the documents contained in the evidence file WK 12325/2024 DCL1 and the evidence file WK 12709/2024 DCL1 do not support the allegation at issue before the Court.

127 Thus, exhibit 8 in the evidence file WK 12325/2024 DCL1 is an article, published on 4 January 2023, from which it is apparent that two commercial container ships, namely the vessels Perarin and Sarvin, were about to be converted by the IRGC into drone carriers. That article also contains a photograph of a vessel presented as the future drone carrier Shahid Mahdavi, which is claimed to be the former vessel Perarin or its sister ship Sarvin. Nevertheless, the article in question does not contain any information as to the identity of the owner of the vessels Perarin and Sarvin until their transfer to the IRGCN.

128 Exhibit 11 in the evidence file WK 12325/2024 DCL1 is an article which appeared on 21 August 2024 on the website Military Watch Magazine, presenting the vessel Shahid Bagheri as the first Iranian aircraft carrier, converted from a container ship previously called the Perarin, and referring to the fact that a second container ship was to be converted into an aircraft carrier and that it would be called the Shahid Mahdavi. Nevertheless, that document also does not contain any information as to the identity of the owner of the vessels Perarin and Sarvin until their transfer to the IRGCN.

129 Exhibit 12 in the evidence file WK 12325/2024 DCL1 is an article which appeared on 21 August 2024 on the website Foundation for Defense of Democracies, referring to a ceremony held to mark the addition to the IRGCN of two vessels, namely the Shahid Shirazi and the Shahid Bagheri. Nevertheless, apart from the fact that that article does not state that those vessels were converted from container ships owned or previously owned by IRISL, its description of the vessels in question does not correspond to that of drone carriers or aircraft carriers. The vessels Shahid Shirazi and Shahid Bagheri are described as patrol ships designed as catamarans with a futuristic look and two independent hulls.

130 Exhibit 14 in the evidence file WK 12325/2024 DCL1 is an article which appeared on 18 July 2024 on the website Lowy Institute, describing the additional capabilities which the vessel Shahid Mahdavi and its sister ship Shahid Bagheri give to the IRGCN. That article states that those vessels were converted from container ships, but does not contain any information as to those vessels or the identity of their owner.

131 Exhibit 17 in the evidence file WK 12325/2024 DCL1 is a post from the account SprinterFactory, which appeared on 4 May 2024 on the social network X, stating that the Islamic Republic of Iran presented the new drone carrier of the IRGCN, namely the vessel Shahid Bahman Bagheri, which had been converted from a container ship previously known as the vessel Sarvin. Nevertheless, that article also does not contain any information as to the identity of the owner of that vessel until its transfer to the IRGCN.

132 It is true that exhibit 10 in the evidence file WK 12325/2024 DCL1, identical to exhibit 8 in the evidence file WK 12709/2024 DCL1, which is an article that appeared on 14 February 2024 on the website Malta ship photos & Action photos, refers to the fact that a container ship was renamed the Perarin by IRISL in 2012 and that that vessel was again renamed, as the Shahid Mahdavi, in 2022, and was then drydocked at a shipyard close to Bandar Abbas (Iran) to be converted into an ‘expeditionary base’. Nevertheless, that article does not specify whether the vessel in question, namely the Perarin, still belonged to IRISL Group when it was transferred to the IRGCN.

133 Similarly, although exhibit 9 in the evidence file WK 12325/2024 DCL1, which is identical to exhibit 7 in the evidence file WK 12709/2024 DCL1, states, inter alia, that the IRGCN was in the process of converting two container ships belonging to the IRISL Group, to make its first aircraft carriers, called the Shahid Mahdavi and the Shahid Bagheri, that assertion appears to be implausible, since that implies that IRISL remained the owner of those vessels after their transfer to the IRGCN, which the Council itself does not maintain.

134 Furthermore, the content of exhibit 9 in the evidence file WK 12325/2024 DCL1 is directly contradicted by the notarial deeds produced in Annex A.14 to the application, which are not disputed by the Council, and from which it is clear that, on 16 February 2022, an Iranian company, identified by the Council as being a subsidiary of IRISL, sold to another Iranian company two container ships, namely the Perarin, bearing IMO number 9209350, and the Sarvin, bearing IMO number 9209348.

135 Moreover, the Council has not referred to any item in the evidence file WK 12325/2024 DCL1 in support of the allegation that IRISL retained control, through front companies, over the vessels Shahid Mahdavi and Shahid Bagheri until they were transferred to the IRGCN. It contends, on the contrary, that it was for the applicant to demonstrate that IRISL had no connection with the buyers of the vessels in question. Nevertheless, in accordance with the case-law referred to in paragraph 97 above, it is indeed for the Council to establish that the reasons relied on against the applicant are well founded, and not the task of the applicant to adduce evidence of the negative, that those reasons are not well founded.

136 Furthermore, as regards the Council’s argument that exhibit 8 in the evidence file WK 12325/2024 DCL1 refers to the conversion of another Panamax container ship owned by IRISL, it is not clear from the article in question that the vessel to which reference is made is different from the Shahid Mahdavi or the Shahid Bagheri. In any event, since, first, the Panamax container ship referred to in that article is not identified and, second, that information is not supported by any other item in the evidence file, that item cannot enable the Council to substantiate the allegation that ‘[the IRGCN] converts container ships owned by IRISL Group into drone carriers.’

137 In the light of the foregoing considerations, it must be stated that the Council has not substantiated to the requisite legal standard the allegation that ‘[the IRGCN] converts container ships owned by IRISL Group into drone carriers.’

(2) The allegation that, ‘for years, IRISL ships have been involved in shipping military related cargo’

138 The applicant merely submits that the allegation that, for years, IRISL ships have been involved in shipping military-related cargo is not substantiated to the requisite legal standard. The Council has not put forward any specific argument in that regard. However, in the light of the case-law referred to in paragraph 94 above, it is for the Court to ensure that the decision by which restrictive measures were adopted or maintained, which affects the person or entity concerned individually, is taken on a sufficiently solid factual basis; that entails a verification of the factual allegations in the statement of reasons for the November 2024 listing acts.

139 In that regard, it should be noted that the documents in the evidence file WK 12709/2024 DCL1 do not contain any evidence capable of demonstrating that, ‘for years, IRISL ships have been involved in shipping military related cargo’.

140 However, it should also be noted that exhibits 1, 2, 6 and 7 in the evidence file WK 12325/2024 DCL1 refer to shipping military-related cargo and refer to IRISL.

141 In that regard, first, it must be noted that exhibit 1 in the evidence file WK 12325/2024 DCL1 states:

‘Iran’s national maritime carrier has transported prohibited military-related cargo and facilitated shipments on behalf of and destined for Iran’s Ministry of [Defence] and Armed Forces Logistics (MODAFL) and MODAFL subordinates, including the Aerospace Industries Organization (AIO), Defense Industries Organization (DIO), and Shahid [Hemmat] Industrial Group (SHIG).

[It has] provided logistical services to MODAFL and to its subordinate entities for the transport of military-related cargo; has facilitated the transport of cargo for [United Nations]- and [United States]-sanctioned entities, falsified documents, used generic language to evade shipping authorities, and employed cover entities to conduct official business; has altered bills of lading by changing the consignee of a shipment after a shipment has left the port of origin, to conceal involvement in proliferation-sensitive activities; has sought to evade sanctions by transferring nominal ownership of vessels to Starry Shine and other co-located entities (including Top Glacier Company Limited, Top Prestige Trading Limited, and Ideal Success Investments Limited) while continuing to manage and operate the ships.

[It has] transported items controlled by the Nuclear Suppliers Group (NSG); has allegedly transported hydraulic press machinery and copper discs, which are used in explosively formed penetrators (EEPs); has allegedly shipped military-related items to Hezbollah; has allegedly shipped military-related items on behalf of the Islamic Revolutionary Guard Corps (IRGC) and the IRGC Quds Force.

In November 2009, [it] allegedly transported a shipment of munitions, including Katyusha 107 mm rockets, Grad 20 122 mm rockets, and rocket fuses, on behalf of the IRGC Quds Force that was destined for Beirut, Lebanon and Latakia, Syria but was seized by Israel; in October 2009, [it] allegedly facilitated a shipment of small arms ammunition manufactured by DIO and destined for Syria that was interdicted by the U.S. Navy in the Gulf of Suez; in January 2009, [it] allegedly transported munitions from DIO destined for the Gaza Strip that was seized by Egypt.

…

In 2008, [it] allegedly shipped chemical weapons precursors from China; in 2007, [it] transported a shipment of a precursor chemical destined for use at Parchin Chemical Industries in Iran’s missile program.’

142 It must be stated that the passages of exhibit 1 in the evidence file WK 12325/2024 DCL1 cited in paragraph 141 above contain a series of assertions concerning IRISL’s involvement in shipping military-related cargo. However, it must be noted that those passages do not contain any information concerning the identity of IRISL’s vessels that were allegedly involved in the transportation of such cargo. Moreover, many of the allegations do not contain any indication of the time period, and those which contain such an indication refer to facts dating from the years 2007 to 2009, that is to say, 15 years before the adoption of the November 2024 listing acts, and are systematically introduced by the expression ‘allegedly’, which does not suggest that the facts in question were established, but rather that a context existed in which IRISL was the subject of accusations.

143 Second, it must be noted that exhibit 6 in the evidence file WK 12325/2024 DCL1 merely reproduces verbatim the wording of the first passage of exhibit 1 in that evidence file, and therefore does not add any additional probative value to it.

144 Third, it should be noted that exhibit 2 in the evidence file WK 12325/2024 DCL1 states the following:

‘An Iranian cargo ship that visited Syria has been detained in a Libyan port on suspicion of smuggling weapons. A cargo ship belonging to [IRISL] was detained on April 26 in the port of [Misrata] on suspicion of transporting weapons that were unloaded or loaded during its route in the Syrian port of Latakia. The ship [Shahr E Kord travelled] along a route that included [that port], from where it continued its journey on April 18 along the coast of [Türkiye] and Bulgaria and returned to Libya’s [Misrata]. The ship was suspected of following a very interesting route known among smugglers.’

145 It is clear from exhibit 2 in the evidence file WK 12325/2024 DCL1 that the vessel Shahr E Kord, owned by IRISL, was detained by the Libyan customs authorities on 26 April 2019 for an inspection in the port of Misrata (Libya) on the ground that it was suspected of transporting weapons that had been loaded or unloaded on its route to the Syrian port of Latakia. However, it is not clear from that document that the suspicions in question were confirmed. Moreover, it is clear from the customs clearance certificate issued by the Libyan customs authorities and produced by the applicant that the vessel in question was inspected by those authorities and authorised to sail again. It cannot therefore be inferred from that document that that vessel was involved in the transportation of military-related cargo.

146 Fourth, it must be noted that exhibit 7 in the evidence file WK 12325/2024 DCL1 is an extract from a report of the panel of experts set up in accordance with United Nations Security Council Resolution 1874 (2009) concerning a request for information addressed to the Islamic Republic of Iran by that panel in relation to information received by it concerning the involvement of the KOMID and the SHIG in shipments to the Islamic Republic of Iran, using vessels owned by IRISL, of materials related to the cooperation between the Islamic Republic of Iran and the Democratic People’s Republic of Korea in the field of ballistic missiles. It is clear from that extract that, in response to that request for information, the Islamic Republic of Iran stated that false information and fabricated data may have been used in the investigation and the analyses of the expert panel. Although that document refers to sufficiently serious suspicions for the expert panel to make a request for information to the Islamic Republic of Iran, in the absence of any identification of the vessels allegedly concerned and in the absence of any reference to the time period, or of any other detail, that document nevertheless does not appear sufficient to support the allegation that, ‘for years, IRISL ships have been involved in shipping military related cargo’.

147 Fifth, it must be borne in mind that the expression ‘for years’ used in the allegation that, ‘for years, IRISL ships have been involved in shipping military related cargo’, implies a certain continuity of the conduct of which the applicant is accused. In that regard, it is important to point out that, in accordance with the case-law, the Council may take into account, when assessing whether a person satisfies a listing criterion, information or evidence relating to circumstances predating the adoption of the act imposing or maintaining restrictive measures, provided that that information or evidence substantiates the grounds supporting that act and contributes to establishing that, despite the passage of time and taking into account all relevant circumstances specific to each case, the person concerned satisfies the listing criterion at issue. In particular, it cannot be ruled out that such information and evidence may be taken into account in order to establish, in the light of the listing criterion concerned, continuity between, on the one hand, the previous situation of the person concerned and, on the other hand, that person’s current situation (see judgment of 13 March 2025, Shuvalov v Council, C‑271/24 P, EU:C:2025:180, paragraph 40 and the case-law cited). Nevertheless, in the present case, it must be noted that, although exhibits 1 and 6 in the evidence file WK 12325/2024 DCL1 refer to shipments of military-related cargo by IRISL vessels which allegedly took place in 2007, 2008 and 2009, and exhibit 2 in that evidence file refers to facts of the same nature which took place in April 2019, none of those documents relates to IRISL’s situation at the time when the November 2024 listing acts were adopted.

148 Furthermore, it must be pointed out that exhibits 1, 2 and 6 in the evidence file WK 12325/2024 DCL1 refer to events prior to the applicant taking up his post as director of IRISL in July 2019, and for which he cannot therefore be held responsible in his capacity as director of IRISL.

149 It follows that the Council has not substantiated to the requisite legal standard the allegation that, ‘for years, IRISL ships have been involved in shipping military related cargo’.

(b) Error of assessment of the facts in the November 2024 listing acts

150 The applicant claims that the Council made an error of assessment in finding that the allegations set out in the statement of reasons for the November 2024 listing acts were sufficient to consider that the criterion laid down in Article 3(1)(c) of Decision 2023/1532 was satisfied.

151 The applicant claims in that regard that, although the notion of ‘association’ is not defined either in Decision 2023/1532 or in Regulation 2023/1529, it has been interpreted by the EU Courts. According to him, it is apparent from the case-law that demonstrating the existence of association in the context of restrictive measures requires the establishment of capital or economic links or the existence of common interests between the associated persons or entities, as well as a risk of circumvention of the restrictive measures.

152 Nevertheless, according to the applicant, in the present case, the Council has not established any of the elements necessary to find that there is an association. He submits that he has no capital or economic links with the IRGCN and that, in so far as the Council has not adduced evidence for the allegation that ‘[the IRGCN] converts container ships owned by IRISL Group into drone carriers’, the Council has not established the existence of a common interest between the IRGCN and him in his capacity as director of IRISL. In addition, the applicant submits that the Council has not demonstrated how the inclusion of his name on the lists at issue could contribute to preventing the IRGCN from circumventing the restrictive measures, which is a situation that could serve to justify the application of the association criterion for the purposes of that listing.

153 The Council disputes the applicant’s arguments.

154 The Council submits that the concept of ‘association’ is not defined as such in Decision 2023/1532 or in Regulation 2023/1529. It argues that, in similar cases, the General Court has held that association may be regarded as covering natural or legal persons who are generally connected by common interests, without, however, it being necessary for there to be a relationship by means of an economic activity, but which cannot, nevertheless, be based exclusively on a family relationship.

155 However, and contrary to what the applicant claims, it does not, the Council argues, follow from the case-law that demonstrating the existence of association in the field of restrictive measures systematically requires the establishment of capital or economic links between the associated persons or entities.

156 According to the Council, there is a common economic interest between the applicant, in his main managerial function within IRISL, and the IRGCN, in that the former provides the latter with carrier vessels for the purpose of converting them into aircraft carriers.

157 In that regard, it must be borne in mind that, in accordance with Article 3(1)(c) of Decision 2023/1532, all funds and economic resources belonging to, or owned, held or controlled by natural or legal persons, entities or bodies associated with natural or legal persons, entities or bodies referred to in Article 3(1)(a) or (b) of that decision are to be frozen.

158 The concept of ‘associated’ natural or legal persons, entities or bodies is not defined in Decision 2023/1532 or in Regulation 2023/1529.

159 It must be pointed out that, while the association criterion is often used in Council acts, it is not, as such, defined and its meaning depends on the context and circumstances of the case (see, to that effect, judgments of 28 July 2016, Tomana and Others v Council and Commission, C‑330/15 P, not published, EU:C:2016:601, paragraph 48; of 4 September 2015, NIOC and Others v Council, T‑577/12, not published, EU:T:2015:596, paragraph 114; and of 21 July 2016, Bredenkamp and Others v Council and Commission, T‑66/14, EU:T:2016:430, paragraphs 35 to 37). However, it may be accepted that that criterion concerns persons who are generally bound by common interests (judgment of 8 March 2023, Prigozhina v Council, T‑212/22, not published, EU:T:2023:104, paragraph 93).

160 In that regard, it should be noted that, although the existence of capital or economic relationships is capable of demonstrating common interests (see, to that effect, judgment of 20 March 2024, Mazepin v Council, T‑743/22, not published, EU:T:2024:180, paragraph 91), the absence of such links does not rule out, as a matter of principle, the existence of other common interests.

161 Furthermore, the applicant cannot claim that the Council is required to establish specifically a risk of circumvention of the restrictive measures in order to justify reliance on the association criterion. That criterion is in itself based on the finding that there is a not insignificant risk of circumvention of the restrictive measures (see, to that effect, judgment of 22 September 2016, NIOC and Others v Council, C‑595/15 P, not published, EU:C:2016:721, paragraphs 89 and 90). That criterion makes it possible to guarantee the efficiency and effectiveness of the restrictive measures taken against the persons included on the lists at issue by preventing those persons from circumventing the measures adopted against them. Therefore, that criterion contributes to the attainment of the objectives laid down in Article 21(2)(c) TEU, such as the preservation of peace, the prevention of conflicts and the strengthening of international security, in accordance with the purposes and principles of the Charter of the United Nations, signed in San Francisco on 26 June 1945.

162 In the present case, it is clear from the statement of reasons for the November 2024 listing acts that the association and, therefore, the existence of common interests between the IRGCN and the applicant, in his capacity as director of IRISL, are based solely on the allegations that, first, ‘for years, IRISL ships have been involved in shipping military related cargo’ and, second, ‘[the IRGCN] converts container ships owned by IRISL Group into drone carriers.’

163 Nevertheless, it is clear from paragraphs 119 to 137 and 139 to 148 above that those allegations are not supported by the documents in the evidence file WK 12325/2024 DCL1.

164 Therefore, in the absence of other evidence capable of demonstrating the existence of common interests between the IRGCN and the applicant, in his capacity as director of IRISL, it should be stated that the Council necessarily made an error of assessment in finding that the IRGCN and the applicant, in his capacity as director of IRISL, were ‘associated’ within the meaning of Article 3(1)(c) of Decision 2023/1532.

165 It follows that the first and fourth pleas in law are well founded in so far as they concern the November 2024 listing acts.

2. Whether the maintenance of the applicant’s name on the lists at issue by the July 2025 maintaining acts was well founded

166 The applicant claims that the Council made an error of assessment by maintaining his name on the lists at issue under the criteria laid down in Article 3(1)(b) and (c) of Decision 2023/1532, in so far as the documents contained in the evidence files WK 5620/2025, WK 5850/2025 and WK 8622/2025 do not substantiate to the requisite legal standard the allegations set out in the statement of reasons for the July 2025 maintaining acts.

167 First of all, the applicant disputes the accuracy of the facts referred to in the documents in the evidence files WK 5850/2025 and WK 8622/2025, relating to the transport of sodium perchlorate between China and Iran by the vessels Golbon and Jairan, and to the transfers of weapons to Russia and Syria by the vessels Shiba, Artam, Artenos, Azargoun, Daisy and Kashan. In addition, he submits that, even assuming that those facts were established, they would not be such as to justify maintaining his name on the lists at issue under the criterion laid down in Article 3(1)(b) of Decision 2023/1532.

168 Next, the applicant submits that, since, as he argued in the context of the challenge of the November 2024 listing acts, IRISL was no longer the owner of the vessels Perarin and Sarvin when they were transferred to the IRGCN, the Council failed to establish a current association between him, in his capacity as director of IRISL, and the IRGCN such as to justify maintaining his name on the lists at issue under the criterion laid down in Article 3(1)(c) of Decision 2023/1532.

169 Lastly, the applicant submits that, since the Council has failed to establish that sodium perchlorate was in fact transported between China and Iran by the vessels Golbon and Jairan, that the activity of those vessels could be attributed to IRISL, or that the sodium perchlorate at issue had a military purpose, the Council has also failed to establish an association between him, in his capacity as director of IRISL, and the IRGC/SSJO, such as to justify maintaining his name on the lists at issue under the criterion laid down in Article 3(1)(c) of Decision 2023/1532.

170 The Council disputes the applicant’s line of argument.

171 It must be noted that, in the last paragraph of the statement of reasons for the July 2025 maintaining acts, which are recalled in paragraph 22 above, the Council stated that, ‘in his principal managerial position as director of IRISL, [the applicant was] involved in transferring Iran’s UAVs or missiles or related technologies to [the Russian Federation] in support of its war of aggression against Ukraine and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region, and [was] associated with branches of the IRGC, in particular the (EU-listed) IRGC/SSJO and the (EU-listed) IRGCN.’

172 It is clear from the last paragraph of the statement of reasons for the July 2025 maintaining acts that the Council considered that maintaining the applicant’s name on the lists at issue was justified under both the criterion laid down in Article 3(1)(b)(i) and (ii) of Decision 2023/1532 and the criterion laid down in Article 3(1)(c) of that decision.

173 The reason why the Council considered that the applicant’s situation satisfied both the criteria laid down in Article 3(1)(b)(i) and (ii) of Decision 2023/1532 and the criterion laid down in Article 3(1)(c) of that decision is set out in the second paragraph of the statement of reasons for the July 2025 maintaining acts. Thus, first, it is clear from that paragraph that, for years, ships belonging to or managed by IRISL or its affiliated companies have been implicated in shipping military-related cargo and other activities aimed at providing support to the Russian Federation in support of its war of aggression against Ukraine and to armed groups and entities undermining peace and security in the Middle East and the Red Sea region. Second, it is also clear from that paragraph that that implication is linked to certain branches of Iran’s Islamic Revolutionary Guard Corps, namely the IRGCN and the IRGC/SSJO.

174 The statement of reasons for the July 2025 maintaining acts also provides, in its third paragraph, another ground justifying the inclusion of the applicant on the lists at issue under the criterion laid down in Article 3(1)(c) of Decision 2023/1532, namely that ‘the [EU-listed] IRGCN converts container ships owned or previously owned by IRISL Group into drone carriers.’

175 In order to justify maintaining the applicant’s name on the lists at issue by the July 2025 maintaining acts, the Council provided the documents contained, in addition to those in the evidence files WK 12709/2024 DCL1 and WK 12325/2024 DCL1, in the evidence files WK 5620/2025, WK 5850/2025 and WK 8622/2025.

176 The evidence file WK 5620/2025 contains an article in Farsi which appeared on 24 January 2025 on the website of the newspaper Mana, accessed on 16 April 2025, and an article in Farsi published in April 2025 on the website of the media outlet Tava news, accessed on 16 April 2025, which state that the applicant is the director of IRISL and refer to his comments concerning IRISL’s results and its economic strategy.

177 The evidence file WK 5850/2025 contains the following documents:

– an article which appeared on 14 February 2025 on the website Iran International, accessed on 15 April 2025, concerning the transportation by the vessels Jairan and Golbon, identified as being operated by IRISL, of sodium perchlorate from China to Iran (exhibit 1);

– two extracts from the database of the website Equasis, accessed on 7 May 2025, identifying IRISL as the International Safety Manager (ISM) of the vessels Golbon and Jairan (exhibits 2 and 3);

– a report of the Foundation for Defense of Democracies of 25 February 2025 (exhibit 4);

– a message posted online on 3 January 2025 on the social network X by the account of a member of the Nuclear Policy Program at the think tank Carnegie Endowment for International Peace, accompanied by a photograph concerning the probably first concrete evidence of the transfer of Iranian UAVs and missiles to the Russian Federation (exhibit 5);

– a press article which appeared on 1 April 2025 in the media Daraj, accessed on 15 April 2025, reporting on a journalistic investigation into the suspicious practices of several Iranian container ships (exhibit 6);

– four extracts from the database accessible from the website Equasis, accessed on 30 April 2025, identifying IRISL as being linked to the vessels Shiba, Artenos, Daisy and Kashan (exhibits 7 to 10);

– an article which appeared on 24 March 2025 on the website Lieber Institute for Law & Warfare at West Point, accessed on 15 April 2025, providing details on the role played by the vessels Saviz and Beshad, identified in the article as belonging to IRISL, in the transfer of weapons and in the provision of intelligence and logistical support to the Houthis since 2016 (exhibit 11);

– an extract from the website Shipvault, accessed on 24 April 2025, identifying the vessel Mensar, previously known as the Beshad, as having belonged, at least until 2024, to HDS Line and, previously, to IRISL (exhibit 12);

– an article which appeared on 30 March 2023 on the website of the newspaper Al-Masharek, accessed on 16 April 2025, reporting on the conversion by the IRGCN of two container ships previously owned by IRISL into aircraft carriers, namely the Shahid Bagheri and the Shahid Mahdavi (exhibit 13);

– two extracts from the database accessible from the website Equasis, accessed on 30 April 2025, confirming that the container ships Shahid Bagheri and Shahid Mahdavi had belonged to IRISL (exhibits 14 and 15);

– an article which appeared on 24 January 2025 on the website BAIRD Maritime, reporting on the involvement of the vessels Golbon and Jairan in the transfer of sodium perchlorate from China to Iran (exhibit 16);

– an article which appeared on 17 March 2025 on the website Marine Insight, accessed on 16 April 2025, reporting on the involvement of the vessel Jairan in the transfer of sodium perchlorate from China to Iran and identifying that vessel as belonging to IRISL (exhibit 17);

– an extract from an article which appeared on 10 December 2018 on the website Iran Watch, accessed on 8 May 2025, identifying Soroush Sarzamin Asatir Ship Management Company, the manager of the vessels Jairan and Golbon, as a subsidiary of IRISL (exhibit 18).

178 The evidence file WK 8622/2025 contains the following documents:

– an article which appeared on 30 March 2025 on the website The Maritime Executive, accessed on 19 June 2025, referring to a vessel bearing a strong resemblance to the vessel Jairan, identified as being owned by IRISL and as being involved in the transfer of sodium perchlorate from China to Iran; that article also explains that sodium perchlorate is the chemical precursor used to produce ammonium perchlorate, which is then used in the production of missile propellants (exhibit 1);

– an article which appeared on 23 December 2022 on the website Defense Express, accessed on 19 June 2025, referring to the increasing investment and cooperation between the Islamic Republic of Iran and the Russian Federation in the creation of a logistics route allowing the speedy delivery of goods between the two countries, and according to which IRISL made substantial investments in order to increase cargo shipments to the Solyanka river port in Astrakhan, Russia (exhibit 2);

– an article which appeared on 28 March 2025 on the website Iran International, accessed on 19 June 2025, referring to the docking in the port of Antwerp (Belgium) of six Iranian vessels, namely the Shiba, the Artam, the Artenos, the Azargoun, the Daisy and the Kashan, suspected of being involved in supporting the Houthis and in transferring weapons to Syria and Russia (exhibit 3);

– an article which appeared on 12 January 2025 on the website Star Concord, accessed on 19 June 2025, presenting the vessels Beshad and Saviz as formally controlled by IRISL, but in practice operated by the IRGCN; that article states that those vessels were involved in the collection and dissemination of intelligence to the Houthis between 2016 and 2024, and also identifies the container ship Shiba as owned by IRISL (exhibit 4);

– an article which appeared on 21 April 2021 on the website Center for Iranian Studies, accessed on 19 June 2025, reporting on the creation and development of IRISL and its practice of setting up numerous subsidiaries worldwide in order to circumvent the restrictive measures adopted against it (exhibit 5);

– an extract dated 10 December 2018 from the website Iran Watch, accessed on 19 June 2025, identifying HDS Line as acting on behalf of IRISL (exhibit 6);

– an extract from the website Vessel Tracker, accessed on 19 June 2025, showing several photographs of the container ship Jairan, on which IRISL’s name is visible (exhibit 7);

– an extract from the website Vessel Tracker, accessed on 19 June 2025, identifying the vessel Jairan as bearing IMO number 9167291 and as being linked to IRISL (exhibit 8);

– an article which appeared on 11 March 2025 on the website Tehran Times, accessed on 19 June 2025, stating that, despite the adoption of sanctions against it, IRISL continues to increase the volume of container transport, in particular due to increased demand by the Russian Federation (exhibit 9);

– extracts from the databases of the websites Vessel Tracker and Baltic Shipping, providing real-time data on vessels, featuring photographs of the vessel Golbon, bearing IMO number 9283033, which carries IRISL’s name (exhibits 10 and 11);

– an extract from the website Magic Port, accessed on 20 June 2025, providing real-time data on the location and ownership of the vessels, identifying HDS Line as owning seven vessels, four of which have as their commercial manager Rahbaran Omid Darya Ship Management Company (exhibit 12);

– a report by Lloyd’s List Intelligence, providing information on the fleet and the ownership of Mosakhar Darya Shipping Company, and also identifying IRISL as the ultimate owner of Mosakhar Darya Shipping Company, of Hafez Darya Arya Shipping Company Joint Stock Company (HDASCO), of HDS Line and of Oghiaanous Khoroushan Shipping Lines Company of Kish (exhibit 13);

– a report by Lloyd’s List Intelligence, providing information on the fleet and the ownership of Oghiaanous Khoroushan Shipping Lines Company of Kish, which operates the vessels Shiba and Golbon; that report identifies IRISL as the ultimate owner of a certain number of companies, in particular of Oghiaanous Khoroushan Shipping Lines Company of Kish, of Mosakhar Darya Shipping Company, of HDASCO and of HDS Line, which itself is linked to Rahbaran Omid Darya Ship Management Company (exhibit 14).

179 It must therefore be ascertained whether the documents referred to in paragraphs 177 and 178 above support to the requisite legal standard the grounds relied on by the Council to justify maintaining the applicant’s name on the lists at issue.

180 In that regard, it must be recalled that, in accordance with the case-law, in view of the preventive nature of decisions adopting restrictive measures, if the EU Courts consider that, at the very least, one of the reasons mentioned 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 judgment of 28 November 2013, Council v Manufacturing Support & Procurement Kala Naft, C‑348/12 P, EU:C:2013:776, paragraph 72 and the case-law cited).

181 In the light of those considerations, it is appropriate to examine, first of all, the applicant’s line of argument that the Council made an error of assessment in maintaining his name on the lists at issue under the criterion laid down in Article 3(1)(c) of Decision 2023/1532 due to the grounds relied on by the Council in that regard not being substantiated to the requisite legal standard.

(a) The conversion by the IRGCN of ‘container ships owned or previously owned by IRISL Group into drone carriers’

182 The applicant submits that the vessels Shahid Bagheri and Shahid Mahdavi are not owned by IRISL and that they were not transferred to the IRGCN, but to a third company, more than a year before the adoption of Decision 2023/1532. He claims that mere subsequent ownership by the IRGCN of those vessels is not sufficient to demonstrate an ‘association’ within the meaning of Article 3(1)(c) of Decision 2023/1532, since that does not establish an ongoing relationship between him, in his capacity as director of IRISL, and the IRGCN, and even less any ‘common interests’.

183 The Council does not dispute that the vessels Perarin and Sarvin were transferred by IRISL before they were transferred to the IRGCN, but maintains that the applicant has not demonstrated that IRISL had no links with the company that acquired those vessels. In addition, the Council refers to exhibit 13 in the evidence file WK 5850/2025 and to exhibit 4 in the evidence file WK 8622/2025, which demonstrate, in its view, the common interests between IRISL and the IRGCN.

184 It must be noted at the outset that, as regards the conversion of the vessels Shahid Mahdavi and Shahid Bagheri, the Council merely repeats the line of argument put forward in support of the November 2024 listing acts, which has been rejected in paragraphs 129 to 137 above. Exhibit 13 in the evidence file WK 5850/2025, relied on by the Council, does not provide any additional information in that regard as compared with exhibit 9 in the evidence file WK 12325/2024 DCL1.

185 It must therefore be found that the Council has not substantiated to the requisite legal standard the allegation in the statement of reasons for the July 2025 maintaining acts that ‘[the IRGCN, whose name is included on the lists at issue,] converts container ships owned or previously owned by IRISL Group into drone carriers.’

(b) The transportation, by the vessels Golbon and Jairan, of sodium perchlorate, used in the production of solid propellants for missiles

186 First, the applicant claims that the Council erred in imputing to IRISL and, therefore, to him, the conduct of other entities. He thus disputes the accuracy of exhibits 1, 4, 16 and 17 in the evidence file WK 5850/2025 and argues that it is apparent from the extracts from the IMO database which he has submitted before the General Court that the vessels Golbon and Jairan do not belong to IRISL, but are owned by, respectively, Oghiaanous Khoroushan Shipping Lines Company of Kish and Mosakhar Darya Shipping Company. He also disputes the reliability and probative value of exhibits 1 and 7 to 11 in the evidence file WK 8622/2025. He also claims in that regard that, even if it were established that IRISL controlled those two companies, that circumstance could not justify maintaining his name on the lists at issue, since the Court stated in the judgment of 9 September 2016, Tri Ocean Energy v Council (T‑719/14, not published, EU:T:2016:458), that the adoption of a restrictive measure against a person must be based on that person’s own conduct.

187 Second, the applicant submits that the Council relied on secondary and uncorroborated evidence to conclude that the vessels Jairan and Golbon were involved in transferring sodium perchlorate from China to Iran. According to him, the second of those vessels was located in a shipyard in China and was not operative during the period referred to in the evidence file WK 5850/2025. Similarly, he claims that the first of those two vessels was under repair until 2 March 2025 and did not perform any shipments in January 2025.

188 Third, the applicant claims that the Council has not provided sufficient evidence to prove that the sodium perchlorate allegedly transferred by the vessels Jairan and Golbon was used for military purposes and subsequently linked to the transfer of Iranian UAVs or missiles or related technologies or components thereof from Iran to Russia or to armed groups in the Middle East or the Red Sea region.

189 The Council disputes the applicant’s arguments.

190 It must be noted that the allegation contained in the second paragraph of the statement of reasons for the July 2025 maintaining acts, recalled in paragraph 173 above, is substantiated, inter alia, by exhibit 1 in the evidence file WK 5850/2025, which is an article that appeared on the website Iran International. That article identifies two vessels, namely the Jairan and the Golbon, as being operated by IRISL and involved in transferring sodium perchlorate from China to Iran, used in the production of solid propellants for missiles. It is stated that the second of those vessels left the port of Taicang in China on 21 January 2025 with a cargo of 1 000 tonnes of sodium perchlorate on behalf of the IRGC/SSJO and anchored outside the Iranian port of Bandar Abbas on 13 February 2025. It is also stated that the first of those vessels had yet to depart from China in order to transport sodium perchlorate to Iran. That article refers to an investigation by the newspaper Financial Times which, in January 2025, reported on that shipment of sodium perchlorate, highlighting the support of the People’s Republic of China for the military development of the Islamic Republic of Iran.

191 The information contained in exhibit 1 in the evidence file WK 5850/2025 is supported by three other press articles that appeared in different newspapers, namely exhibits 16 and 17 in that evidence file and exhibit 1 in the evidence file WK 8622/2025.

192 Thus, exhibit 16 in the evidence file WK 5850/2025, which is an article that appeared on 24 January 2025 on the website BAIRD Maritime, states that the vessel Golbon had left the port of Taicang with its cargo of sodium perchlorate, the main ingredient for solid propellants for missiles, intended for the IRGC, and that it had sailed on a three-week voyage without any port calls to the port of Bandar Abbas. It is stated that the vessel Jairan would depart in order to carry out the same journey with the same cargo at the beginning of February 2025.

193 Exhibit 17 in the evidence file WK 5850/2025, which is an article that appeared on 17 March 2025 on the website Marine Insight, states that the vessel Jairan was en route to Bandar Abbas and that it carried a shipment of sodium perchlorate, a chemical essential for missile fuel production. It is stated in that article that that vessel was owned by IRISL, that it had passed the Strait of Malacca on 16 March 2025 and that it was to arrive at Bandar Abbas, ahead of schedule, on 26 March 2025. It is also stated that the amount of sodium perchlorate transported by that vessel was sufficient to produce around 250 medium-range missiles, of the kind that had previously been used in attacks against the State of Israel, the Kingdom of Saudi Arabia, the United Arab Emirates, and Ukraine, and which had been supplied to the Russian Federation and to Iran’s Axis of Resistance allies in the Middle East. According to that article, reports suggested that the Islamic Republic of Iran could face a shortage of ammonium perchlorate, which could be explained by Israeli attacks on missile fuel production sites, which increased demand due to ongoing conflicts and exports to Russia. That situation led to the risky decision to ship sodium perchlorate despite potential interception threats.

194 Exhibit 1 in the evidence file WK 8622/2025, which is an article that appeared on 30 March 2025 on the website The Maritime Executive, states that a vessel bearing a strong resemblance to the vessel Jairan, the second of two vessels owned by IRISL carrying sodium perchlorate from China, was spotted in the anchorage of the port of Bandar Abbas midway between the islands of Qeshm (Iran) and Hormuz (Iran) on 29 March 2025. It is also stated that the Iranian authorities did not appear to have taken any particular measures to safeguard that vessel and that it travelled with its automatic identification system switched on. That article states that, once sodium perchlorate was ashore, it would likely be shipped by train to Tehran (Iran) and then to a processing infrastructure to be converted into ammonium perchlorate. It is also stated that ammonium perchlorate forms the basis of the solid rocket fuel used to power most Iranian medium-range missiles and that recent imports of that product by the vessels Golbon and Jairan would be sufficient to fuel approximately 250 medium-range missiles of various types.

195 That information is also supported by exhibit 4 in the evidence file WK 5850/2025, which is a report of the Foundation for Defense of Democracies of 25 February 2025. That report identifies the vessels Golbon and Jairan as being operated by IRISL and as involved in the transfer of sodium perchlorate from China to Iran. According to that report, the buyer of that chemical precursor is the IRGC/SSJO. The report also refers to an investigation published by the news channel CNN, confirming the information contained therein as regards the involvement of the two vessels in the transfer, the link between the vessels and IRISL, and the fact that the buyer of the chemical precursor is the IRGC/SSJO. Lastly, the report refers to the long-standing support which the People’s Republic of China has provided to the Islamic Republic of Iran in order to strengthen its arms industry.

196 Furthermore, it is important to point out that it is clear from exhibits 13 and 14 in the evidence file WK 8622/2025, namely the reports by Lloyd’s List Intelligence, which are not disputed by the applicant, that IRISL is the ultimate owner of Mosakhar Darya Shipping Company and of Oghiaanous Khoroushan Shipping Lines Company of Kish, which are themselves identified in the extracts from the IMO database produced by the applicant as the owner of the vessel Jairan and the owner of the vessel Golbon, respectively.

197 In that regard, it is necessary to reject the applicant’s argument based on paragraph 33 of the judgment of 9 September 2016, Tri Ocean Energy v Council (T‑719/14, not published, EU:T:2016:458), according to which the Council cannot legitimately rely on an alleged relationship of control in order to dispense with the obligation to demonstrate that the alleged conduct was committed individually by the applicant and constitutes the basis for maintaining his name on the lists at issue.

198 In the case which gave rise to the judgment of 9 September 2016, Tri Ocean Energy v Council (T‑719/14, not published, EU:T:2016:458), the Council, by referring to ‘Tri Ocean Trading or Tri-Ocean Energy’, even though they were two separate legal persons, had not identified the person subject to the restrictive measures with sufficient precision. It was in those circumstances that the General Court stated that the fact that Tri-Ocean Energy exerted control over its subsidiary Tri Ocean Trading did not exempt the Council from its obligation to identify individually the persons covered by the restrictive measures at issue and to specify the link between them and the actual and specific reasons justifying the listing of each of them. The General Court also clarified in the same judgment that the question of the identification of IRISL by the Council in its Implementing Decision 2014/678/CFSP of 26 September 2014 implementing Decision 2013/255/CFSP concerning restrictive measures against Syria (OJ 2014 L 283, p. 59) and in its Implementing Regulation (EU) No 1013/2014 of 26 September 2014 implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria (OJ 2014 L 283, p. 9) is separate from the question of the exercise of control by a parent company over its subsidiary.

199 In the present case, it is clear from the July 2025 maintaining acts that there is no doubt as to the identity of the person subject to the restrictive measures, since only the applicant’s name is referred to in the column ‘Names’ in entry 20 of Part A, entitled ‘Natural persons’, of the list annexed to those acts.

200 In so far as the applicant disputes the possibility for the Council to attribute to him, under the criterion set out in Article 3(1)(b) of Decision 2023/1532, the conduct of companies over which IRISL exerts control, it must be noted that, in the case which gave rise to the judgment of 10 September 2019, HTTS v Council (C‑123/18 P, EU:C:2019:694), which specifically concerned the interpretation of the words ‘… legal person, entity or body owned or controlled by [IRISL]’ in Article 16(2)(d) of Council Regulation (EU) No 961/2010 of 25 October 2010 on restrictive measures against Iran and repealing Regulation (EC) No 423/2007 (OJ 2010 L 281, p. 1), the Court of Justice held that the concept of ‘company owned or controlled’ did not have, in the area of restrictive measures, the same meaning as it generally has in company law, where it serves to ascertain the commercial liability of a company which is legally subject to the control, as regards decision-making, of another commercial entity (judgment of 10 September 2019, HTTS v Council, C‑123/18 P, EU:C:2019:694, paragraph 70).

201 According to the Court of Justice, the use by Regulation No 961/2010 of the terms ‘owned’ and ‘controlled’ reflects the need to enable the Council to adopt effective measures against all persons, entities or bodies linked to companies involved in nuclear proliferation. It follows that the ownership or control may be direct or indirect. If that link had to be established solely on the basis of the direct ownership or control of those persons, the measures could be circumvented by numerous contractual or de facto possibilities of control, possibilities which would confer on a company opportunities to exert influence over other entities that are as extensive as in the case of direct ownership or control (judgment of 10 September 2019, HTTS v Council, C‑123/18 P, EU:C:2019:694, paragraph 69).

202 In the present case, in view of IRISL’s status as the ultimate owner of Mosakhar Darya Shipping Company and of Oghiaanous Khoroushan Shipping Lines Company of Kish, as well as its practice of establishing a complex corporate structure in order to conceal the ultimate ownership and control of certain assets, which is apparent from exhibit 6 in the evidence file WK 5850/2025 and exhibit 5 in the evidence file WK 8622/2025, the Council did not commit an error of assessment in attributing to IRISL the conduct of Mosakhar Darya Shipping Company and Oghiaanous Khoroushan Shipping Lines Company of Kish.

203 It follows that exhibits 1, 4, 13, 14, 16 and 17 in the evidence file WK 5850/2025 and exhibit 1 in the evidence file WK 8622/2025 constitute a body of evidence that is sufficiently specific, precise and consistent to demonstrate that sodium perchlorate was transferred from China to Iran, by vessels owned or managed by IRISL or its subsidiaries.

204 That finding cannot be called into question by the applicant’s argument that the vessels Golbon and Jairan were immobilised during the period in which the Council claims that the transfer of sodium perchlorate took place, as evidenced, according to him, by several documents.

205 It is true that on 28 April 2026, IRISL produced, in the oral part of the procedure, several documents relating to the situation of the vessels Golbon and Jairan at the beginning of 2025.

206 The production of the documents referred to in paragraph 205 above by way of exception after the close of the written part of the procedure, which was disputed by the Council and the European Commission in Case T‑93/25, IRISL v Council, was duly justified by IRISL, on the basis of Article 85(3) of the Rules of Procedure, by the very strong restrictions on global internet access imposed by the Iranian authorities in the context of the military operations which affected that country, considerably impeding IRISL’s ability to retrieve and transmit to its counsel the documents in question, including during the period following the adoption of the July 2025 maintaining acts.

207 Nevertheless, it must be stated that the documents referred to in paragraph 205 above are not such as to substantiate the applicant’s argument that the vessels Golbon and Jairan were immobilised during the period in which the Council claims that the transfer of sodium perchlorate took place.

208 Thus, as regards the vessel Golbon, the documents referred to in paragraph 205 above, namely the logbooks of 20 and 21 January 2025, the pilot-away notice of 21 January 2025, and the arrival reports for Bandar Abbas Anchorage (13 February 2025) and Bandar Abbas Berth (20 February 2025) confirm that that vessel actually travelled from China to Iran from 21 January until 13 February 2025. In addition, the cargo manifest expressed as Harmonised System codes for the relevant voyage, produced by the applicant in order to show that it does not contain any entry under heading 28.29 (chlorates and perchlorates), consists of a mere list of codes in respect of which it is not possible to determine whether it relates to the voyage in question or to any voyage made by that vessel. Moreover, the applicant produced only 6 of the 700 pages contained in the document describing the goods transported by the vessel in question during that voyage. Those documents cannot therefore disprove the fact that sodium perchlorate was transported by that vessel, particularly since it is clear from exhibit 1 in the evidence file WK 12325/2024 DCL1 that, in the past, IRISL has falsified documents and used generic terms to evade shipping authorities and conceal its actual activities.

209 Similarly, it is apparent from the ‘workdone’ certificate produced by the applicant concerning the vessel Jairan that that vessel entered the shipyard where that work was carried out on 19 December 2024 and left that shipyard on 2 March 2025. Nevertheless, that fact is not incompatible with the fact that that vessel resumed its voyage from that date, since the applicant himself has admitted that the period of immobilisation of the vessel in question ended on that date, or with the fact that it transported sodium perchlorate from China to Iran, since the applicant has himself stated that the work in question had taken place in a Chinese shipyard. Nor are the dates of immobilisation of that vessel incompatible with the estimated duration of the journey of three weeks and an arrival in Bandar Abbas between 26 March and 29 March 2025, as is apparent from exhibit 17 in the evidence file WK 5850/2025 and exhibit 1 in the evidence file WK 8622/2025.

210 Furthermore, the applicant claims that the Council has not shown that the transportation of sodium perchlorate was intended for military use, or that sodium perchlorate was subsequently transferred to the Russian Federation, in support of its war of aggression against Ukraine, or to armed groups and entities undermining peace and security in the Middle East and the Red Sea region.

211 In that regard, it is clear from exhibits 1, 4, 16 and 17 in the evidence file WK 5850/2025 and exhibit 1 in the evidence file WK 8622/2025 that sodium perchlorate is mainly used for military purposes as a chemical precursor of ammonium perchlorate, which is itself then used in the production of missile propellants.

212 Furthermore, as the Council correctly submits, it is clear from exhibits 1 and 4 in the evidence file WK 5850/2025 that the sodium perchlorate that was transported from China to Iran, with the involvement of the vessels Jairan and Golbon, had been purchased by the IRGC/SSJO, itself identified as a branch of the IRGC Aerospace Force. It is also clear from exhibit 4 in that evidence file that a supply network which was implemented in Türkiye and in Oman by the IRGC/SSJO in order to acquire goods usable for the development of missiles was the subject of sanctions by the United States of America in 2024.

213 It can therefore be concluded from the documents in the evidence files WK 5850/2025 and WK 8622/2025 that the sodium perchlorate transported from China to Iran by the vessels Golbon and Jairan, controlled by IRISL, was intended for military use.

214 Furthermore, the circumstance that the sodium perchlorate transported by the vessels Golbon and Jairan had been ordered by the IRGC/SSJO is sufficient, in itself, to show that the applicant, in his capacity as director of IRISL, shares ‘common interests’ with the IRGC/SSJO, within the meaning of the case-law referred to in paragraph 159 above.

215 In that regard, it must be recalled that, under the criterion laid down in Article 3(1)(c) of Decision 2023/1532, a natural person, such as the applicant, may have his or her name maintained on the lists at issue where he or she is associated with a natural or legal person, entity or body referred to in Article 3(1)(a) or (b) of that decision.

216 In the present case, it must be noted that, on the date of the adoption of the July 2025 maintaining acts, the IRGC/SSJO’s name was maintained on the lists at issue for the following reasons:

‘The [IRGC/SSJO] is a research and development unit that develops and manufactures ground penetrating radar, communication systems, weaponry, combat vehicles and electronic cyberwarfare equipment.

As part of the [IRGC], the [IRGC/SSJO] has been involved in research, development and procurement activities linked to the development of Iranian UAVs and missiles.

The [IRGC/SSJO] is therefore involved in Iran’s UAV and missile programmes and in transferring Iranian UAVs to [the Russian Federation] in support of its war of aggression against Ukraine.’

217 Thus, it is implicit from the reasons set out in paragraph 216 above that, on the date on which the July 2025 maintaining acts were adopted, the name of the IRGC/SSJO was maintained on the lists at issue under both the criterion laid down in Article 3(1)(a) of Decision 2023/1532 and the criterion laid down in Article 3(1)(b)(i) of that decision.

218 In that regard, the applicant denies that he is associated with the IRGC/SSJO on the ground, in essence, that the Council has not demonstrated that the transportation of sodium perchlorate between China and Iran, referred to in the documents in the evidence files WK 5850/2025 and WK 8622/2025, was attributable to IRISL or that such a transfer was linked to IRCG/SSJO.

219 However, as concluded in paragraph 213 above, in the light of the documents in the evidence files WK 5850/2025 and WK 8622/2025, the sodium perchlorate transported from China to Iran by the vessels Golbon and Jairan, which were controlled by IRISL, had a military purpose.

220 It must therefore be held that the applicant shares, in his capacity as director of IRISL, common interests, within the meaning of the case-law referred to in paragraph 159 above, with the IRGC/SSJO.

221 However, under the criterion laid down in Article 3(1)(c) of Decision 2023/1532, a natural person such as the applicant may be included on the lists at issue where that person is associated with a natural or legal person, entity or body referred to in Article 3(1)(a) or (b) of that decision. In the present case, it should be noted that, as is apparent from the third and fifth paragraphs of the statement of reasons for the July 2025 maintaining acts, on the date on which those acts were adopted, the name of the IRGC/SSJO was maintained on the lists at issue for the following reasons:

‘The [IRGC/SSJO] is a research and development unit that develops and manufactures ground penetrating radar, communication systems, weaponry, combat vehicles and electronic cyberwarfare equipment.

As part of the [IRGC], the [IRGC/SSJO] has been involved in research, development and procurement activities linked to the development of Iranian UAVs and missiles.

The [IRGC/SSJO] is therefore involved in Iran’s UAV and missile programmes and in transferring Iranian UAVs to [the Russian Federation] in support of its war of aggression against Ukraine.’

222 Thus, it is implicit from the reasons set out in paragraph 216 above that, on the date on which the July 2025 maintaining acts were adopted, the name of the IRGC/SSJO was maintained on the lists at issue under both the criterion laid down in Article 3(1)(a) of Decision 2023/1532 and the criterion laid down in Article 3(1)(b)(i) of that decision.

223 Consequently, in the light of the case-law referred to in paragraph 180 above, and without there being any need to examine the applicant’s arguments that the documents in the evidence files WK 5850/2025 and WK 8622/2025 of the Council concerning the vessels Shiba, Artam, Artenos, Azargoun, Daisy and Kashan do not support to the requisite legal standard the maintenance of his name on the lists at issue under the criterion laid down in Article 3(1)(b)(i) and (ii) of Decision 2023/1532, it is appropriate to conclude that the Council did not commit an error of assessment in finding that the documents contained in the evidence files WK 5850/2025 and WK 8622/2025 justified that maintenance under the criterion laid down in Article 3(1)(c) of that decision.

224 It follows that the first and fourth pleas in law must be rejected as unfounded in so far as they concern the July 2025 maintaining acts.

225 Since the first and fourth pleas in law have been upheld in so far as they are directed against the November 2024 listing acts, it is therefore appropriate to examine the fifth plea only in so far as it is directed against the July 2025 maintaining acts.

D. The fifth plea in law, alleging an infringement of Articles 16 and 17 of the Charter

226 The applicant submits that the July 2025 maintaining acts have the effect of imposing on him restrictive measures laid down in Article 2(1) and Article 3(1) of Decision 2023/1532, which disproportionately and unjustifiably affect his right to property and his freedom to conduct a business, guaranteed by Article 17 and Article 16 of the Charter respectively. He submits, in particular, that the Council has not demonstrated how the restrictive measures adopted against him contribute to achieving the objective of combating the support provided by the Islamic Republic of Iran to the Russian Federation in its military intervention in Ukraine, as well as to military groups in the Middle East and the Red Sea region.

227 The Council disputes the applicant’s line of argument.

228 It should be noted that the arguments put forward by the applicant in support of the present plea must be regarded as referring to a disproportionate interference by the July 2025 maintaining acts with his right to property and his freedom to conduct a business, which are guaranteed by Article 17 and Article 16 of the Charter respectively.

229 In the present case, it must be noted that, under Article 3 of Decision 2023/1532, first, the applicant may not freely dispose of the funds and economic resources situated within the territory of the European Union owned, held or controlled by him, which are frozen, and, second, no funds or economic resources may be made available, directly or indirectly, to him or for his benefit. In addition, under Article 2(1) of that decision, the applicant is banned from entering the territory of the European Union.

230 Such restrictive measures undeniably result in a restriction on the applicant’s exercise of his right to property and his freedom to conduct a business (see, by analogy, judgment of 26 November 2025, Bazhaev v Council, T‑608/24, not published, EU:T:2025:1066, paragraph 71).

231 Nevertheless, the fundamental rights, including the right to property and the freedom to conduct a business on which the applicant relies, are not absolute rights, and the exercise thereof may be subject to limitations, under the conditions laid down in Article 52(1) of the Charter, according to which, first, ‘any limitation on the exercise of the rights and freedoms recognised by [the Charter] must be provided for by law and respect the essence of those rights and freedoms’ and, second, ‘subject to the principle of proportionality, limitations may be made only if they are necessary and genuinely meet objectives of general interest recognised by the Union or the need to protect the rights and freedoms of others.’

232 Thus, in order to comply with EU law, a limitation on the exercise of the fundamental rights and freedoms must satisfy four conditions. First, it must be ‘provided for by law’, in the sense that the EU institution adopting measures liable to restrict a natural or legal person’s fundamental rights must have a legal basis for its actions. Second, it must respect the essence of those rights. Third, it must refer to an objective of general interest, recognised as such by the European Union. Fourth, it must be proportionate (see, to that effect, judgment of 27 July 2022, RT France v Council, T‑125/22, EU:T:2022:483, paragraphs 145 and 222 and the case-law cited).

233 First, the restrictive measures at issue, that is to say, those resulting from the July 2025 maintaining acts, are ‘provided for by law’, since they are laid down in acts of general application, namely Decision 2023/1532, as amended, and Regulation 2023/1529, as amended, and they have a clear legal basis in EU law, namely Article 29 TEU and Article 215 TFEU, respectively.

234 Second, the restrictive measures at issue are limited in time and reversible, in so far as they apply until a specific date, namely until 27 July 2026, and are kept under constant review, in accordance with Article 10 of Decision 2023/1532, as amended. Furthermore, Article 3 of that decision lays down exemptions and possibilities to grant derogations in respect of the restrictive measures applied. In addition, the restrictive measures adopted vis-à-vis the applicant do not limit his freedom to conduct a business outside the European Union. It follows that the contested acts do not infringe the essence of the freedom to conduct a business (see, to that effect, judgment of 27 July 2022, RT France v Council, T‑125/22, EU:T:2022:483, paragraph 154).

235 Third, as is clear from recitals 5, 7 and 8 of Decision 2024/2894, the restrictive measures at issue are intended to discourage the Islamic Republic of Iran from supplying UAVs, missiles, related technologies or components thereof to the Russian Federation in support of its war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region. That is an objective of general interest which falls within the objectives pursued under the CFSP, referred to in Article 21(2)(b) and (c) TEU, such as the consolidation of and support for democracy, the rule of law, human rights and the principles of international law, and the preservation of peace, prevention of conflicts and strengthening of international security and the protection of civilian populations (see, to that effect, judgment of 30 November 2016, Rotenberg v Council, T‑720/14, EU:T:2016:689, paragraph 176).

236 Fourth, with regard to the principle of proportionality, it must be noted that, as a general principle of EU law, this requires that measures adopted by the EU institutions do not exceed the limits of what is appropriate and necessary in order to attain the objectives pursued by the legislation in question. Consequently, when there is a choice between several appropriate measures, recourse must be had to the least onerous, and the disadvantages caused must not be disproportionate to the aims pursued (see judgment of 30 November 2016, Rotenberg v Council, T‑720/14, EU:T:2016:689, paragraph 178 and the case-law cited).

237 First of all, as regards the requirement that the restrictive measures at issue be capable of attaining the objectives pursued, it should be noted that, given the paramount importance of the objective of maintaining peace and international security which they pursue and the negative consequences resulting from their application as described by the applicant, those measures are not manifestly inappropriate.

238 In that regard, it must be emphasised that the effects of the restrictive measures at issue are limited to the territory of the European Union, with the result that they concern at most only part of the own funds or economic resources belonging to the applicant and do not prevent him from carrying on his activities as director of IRISL in the country in which the latter is established or in other third countries.

239 Furthermore, it is clear from the case-law that any economic or financial restrictive measure has, ex hypothesi, consequences which affect the right to property and the freedom to pursue a trade or business, thereby causing harm, in particular to the persons and entities carrying on the activities that the restrictive measures in question are designed to stop. The importance of the aims pursued by the legislation at issue is such as to justify negative consequences, even of a substantial nature, for some operators (see judgment of 14 October 2009, Bank Melli Iran v Council, T‑390/08, EU:T:2009:401, paragraph 70 and the case-law cited; judgment of 14 September 2016, National Iranian Tanker Company v Council, T‑207/15, not published, EU:T:2016:471, paragraph 111).

240 Next, as regards the necessity of the restrictive measures at issue, it must be noted that alternative and less onerous measures, such as a system of prior authorisation or an obligation to justify, a posteriori, how the funds transferred were used, are not as effective in achieving the objectives pursued. In that regard, the applicant has failed to explain which less onerous measures the Council could have adopted that would have been just as appropriate as those provided for.

241 Lastly, a weighing up of the interests at stake shows that the disadvantages entailed by the temporary freezing of funds are not disproportionate to the objectives pursued, contrary to what the applicant claims. Specific derogations from the restrictive measures may be granted by the authorities of the Member States in accordance with Article 3(3) to (9d) of Decision 2023/1532, as amended, and Articles 3a to 3c of Regulation 2023/1529, as amended, in particular to satisfy the basic or essential needs of the persons concerned or to meet the necessary expenditure.

242 It follows from the foregoing considerations that the interference with the applicant’s right to property and freedom to conduct a business is not disproportionate.

243 The fifth plea in law must therefore be rejected as unfounded.

244 Since the first and fourth pleas in law are well founded in so far as they concern the November 2024 listing acts, those acts must be annulled and the action must be dismissed as to the remainder.

E. The effects of the annulment of the November 2024 listing acts

245 Since the applicant’s name appears on the lists at issue by virtue of the July 2025 maintaining acts, the annulment of the November 2024 listing acts does not entail the disappearance of that name from those lists. Consequently, it is not necessary to order that the effects of Decision 2024/2894 be maintained until the partial annulment of Implementing Regulation 2024/2896 takes effect.

IV. Costs

246 Under Article 134(1) of the Rules of Procedure, the unsuccessful party is to be ordered to pay the costs if they have been applied for in the successful party’s pleadings. Article 134(3) of those rules provides, inter alia, that the parties are to bear their own costs where each party succeeds on some and fails on other heads.

247 In the present case, since the applicant and the Council have each been partially unsuccessful, they must be ordered to bear their own costs.

On those grounds,

THE GENERAL COURT (First Chamber)

hereby:

1. Annuls Council Decision (CFSP) 2024/2894 of 18 November 2024 amending Decision (CFSP) 2023/1532 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region and Council Implementing Regulation (EU) 2024/2896 of 18 November 2024 implementing Regulation (EU) 2023/1529 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region, in so far as they concern Mr Mohammad Reza Khiabani;

2. Dismisses the action as to the remainder;

3. Orders Mr Reza Khiabani and the Council of the European Union to bear their own costs.

Buttigieg

Kancheva

Bestagno

Delivered in open court in Luxembourg on 30 September 2026.

V. Di Bucci

S. Papasavvas

Registrar

President

Table of contents

I. Background to the dispute and events subsequent to the bringing of the action

II. Forms of order sought

III. Law

A. The third plea in law, alleging a breach of the right to effective judicial protection and of the rights of the defence

1. Whether there was a breach of the right to effective judicial protection and of the rights of the defence in the context of the adoption of the November 2024 listing acts

2. The breach of the right to effective judicial protection and of the rights of the defence in the context of the adoption of the July 2025 maintaining acts

B. The second plea in law, alleging an error of law

1. Error of law relating to the November 2024 listing acts

2. Error of law relating to the July 2025 maintaining acts

C. The first and fourth pleas in law, alleging a lack of a sufficient factual basis and an error of assessment

1. Whether the inclusion of the applicant’s name on the lists at issue by the November 2024 listing acts was well founded

(a) Whether the allegations contained in the statement of reasons for the November 2024 listing acts are materially accurate

(1) The allegation that ‘[the IRGCN] converts container ships owned by IRISL Group into drone carriers’

(2) The allegation that, ‘for years, IRISL ships have been involved in shipping military related cargo’

(b) Error of assessment of the facts in the November 2024 listing acts

2. Whether the maintenance of the applicant’s name on the lists at issue by the July 2025 maintaining acts was well founded

(a) The conversion by the IRGCN of ‘container ships owned or previously owned by IRISL Group into drone carriers’

(b) The transportation, by the vessels Golbon and Jairan, of sodium perchlorate, used in the production of solid propellants for missiles

D. The fifth plea in law, alleging an infringement of Articles 16 and 17 of the Charter

E. The effects of the annulment of the November 2024 listing acts

IV. Costs

* Language of the case: English.