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Sanctions regimes

Russia sanctions regime

Why are sanctions imposed?

Australia imposes autonomous sanctions in relation to Russia in response to the Russian threat to the sovereignty and territorial integrity of Ukraine. They were first imposed in 2014 and extended in 2015 and 2022.

Australia imposes separate but related autonomous sanctions in relation to Ukraine as a whole and in relation to specified regions in Ukraine, also in response to the Russian threat to its sovereignty and territorial integrity. Go to the Ukraine Sanctions Regime and Specified Ukraine Regions Sanctions Regime for further information.

What is prohibited by the Russia sanctions regime?

The Russia sanctions regime imposes the following sanctions measures:

Measure UNSC Autonomous
restrictions on the export or supply of certain goods  
restrictions on the import, purchase or transport of certain goods  
restrictions on certain commercial activities  
restrictions on the provision of certain services  
restrictions on providing assets to designated persons or entities  
restrictions on dealing with the assets of designated persons or entities  
travel bans on designated persons  

Restrictions on the export or supply of certain goods

It is prohibited to supply, sell or transfer any of the following goods directly or indirectly to, for use in, or for the benefit of Russia:

  • arms or related materiel
  • aluminium ores (including bauxite), alumina and related products (as designated in the Autonomous Sanctions (Export Sanctioned Goods – Russia) Designation 2022)
  • certain luxury goods (as also designated in the above Designation)
  • items suited for use in the following categories of oil exploration or oil production projects in Russia (as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2015):
    1. oil exploration and production in waters deeper than 150 metres;
    2. oil exploration and production in the offshore area north of the Arctic Circle;
    3. projects that have the potential to produce oil from resources located in shale formations by way of hydraulic fracturing (other than exploration and production through shale formations to locate or extract oil from non‐shale reservoirs).

Arms or related matériel includes, but is not limited to, weapons, ammunition, military vehicles and equipment, and spare parts and accessories for any of those things. It also includes paramilitary equipment. While each case will be considered individually, goods on the Defence and Strategic Goods List are likely to be considered arms or related matériel. Depending on the context, end user and end use, other goods may also be considered arms or related matériel. Go to Factsheet: Arms and Related Matériel for information on what to consider when assessing whether a good is an arm or related matériel.

Restrictions on the import, purchase or transport of certain goods

It is prohibited to import, purchase or transport any of the following goods if they were exported from, or originated in, Russia:

  • arms or related materiel
  • oil, refined petroleum products, natural gas, coal and other energy products (as designated in the Autonomous Sanctions (Import Sanctioned Goods – Russia) Designation 2022).

Restrictions on certain commercial activities

It is prohibited to deal with financial instruments issued by, or provide loans or credit to:

  • specified publicly‐owned or controlled Russian banks (as specified in the Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2015)
  • specified Russian companies predominantly engaged in activities relating to military equipment or services (as also specified in the above Specification)
  • specified publicly‐owned or controlled Russian companies involved in the sale or transport of crude oil or petroleum products (as also specified in the above Specification)
  • majority owned subsidiaries or entities acting as agents for any of the above.

Restrictions on the provision of certain services

To complement the restrictions outlined above on the export and import of certain goods and on certain commercial activities, the provision of certain services is also restricted. It is prohibited to provide:

  • any service which assists with, or is provided in relation to, the supply, sale of transfer of goods listed under ‘restrictions on the export or supply of certain goods' above, except the items suited for use in certain categories of oil exploration or oil production projects
  • financial assistance or a financial service which assists with, or is provided in relation to, the import, purchase or transport of goods listed under ‘restrictions on the import, purchase or transport of certain goods' above
  • an investment service which assists with, or is provided in relation to, the activities listed under ‘restrictions on certain commercial activities' above
  • a service to Russia, or to a person for use in Russia, which assists with, or is provided in relation to:
    • a military activity
    • the manufacture, maintenance or use of arms or related matériel
  • certain services to Russia, or to a person or entity for use in Russia, that are necessary for certain types of oil exploration or production projects in Russia, including drilling or well‐testing services.

Restrictions on providing assets to, and dealing with the assets of, designated persons or entities

The Minister for Foreign Affairs may designate a person or entity for targeted financial sanctions if:

  1. the Minister is satisfied that the person or entity is, or has been, engaging in an activity or performing a function that is of economic or strategic significance to Russia
  2. the person is a current or former Minister or senior official of the Russian Government
  3. the person is an immediate family member of a person mentioned in paragraph (a) or (b).

It is prohibited to directly or indirectly make an asset available to, or for the benefit of, a designated person or entity.

It is also prohibited to use or deal with an asset, or allow or facilitate another person to use or deal with an asset, that is owned or controlled by a designated person or entity (the assets are ‘frozen' and cannot be used or dealt with). The prohibition on ‘dealing' with assets includes using, selling or moving assets.

An 'asset' includes an asset or property of any kind, whether tangible or intangible, movable or immovable.

Go to the Consolidated List to search the names of designated persons and entities.

If you become aware that you are holding an asset of a designated person or entity, you are required to freeze (hold) that asset and notify the AFP as soon as possible. Go to What You Need to Do for more information.

Travel bans on declared persons

The Minister for Foreign Affairs may declare a person for a travel ban if:

  1. the Minister is satisfied that the person or entity is responsible for, or complicit in, the threat to the sovereignty and territorial integrity of Ukraine
  2. the Minister is satisfied that the person or entity is, or has been, engaging in an activity or performing a function that is of economic or strategic significance to Russia
  3. the person is a current or former Minister or senior official of the Russian Government
  4. the person is an immediate family member of a person mentioned in paragraph (b) or (c).

Sanctions permits

The Minister for Foreign Affairs may grant a sanctions permit to allow an activity that would otherwise be prohibited under autonomous sanctions in relation to Russia provided the activity meets specific criteria.

The table below provides a general guide to relevant criteria. You should get your own legal advice if you think your proposed activity is affected by sanctions and may meet the criteria for a permit. Go to Sanctions Permits for information on permits, including how to apply.

 

Measure Criteria Reference
Restrictions of the export or supply of certain goods The Foreign Minister is satisfied that it would be in the national interest to grant a permit Regulations 4, 12 and 18 of the Autonomous Sanctions Regulations 2011

 

Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2015

 

Regulation 11 of the Customs (Prohibited Exports) Regulations 1958

Restrictions on the import, purchase or transport of certain goods The Foreign Minister is satisfied that it would be in the national interest to grant a permit Regulations 3, 4A, 12A and 18 of the Autonomous Sanctions Regulations 2011
Restrictions on certain commercial activities The Foreign Minister is satisfied that it would be in the national interest to grant a permit Regulations 3, 5A, 12 and 18 of the Autonomous Sanctions Regulations 2011
Restrictions on provision of certain services The Foreign Minister is satisfied that it would be in the national interest to grant a permit Regulations 5, 13 and 18 of the Autonomous Sanctions Regulations 2011
Restrictions on providing assets to, and dealing with the assets of, designated persons or entities The Foreign Minister is satisfied that it would be in the national interest to grant a permit and, for a permit granted on application, the permit must be for a basic expense dealing, a legally required dealing, or a contractual dealing Regulations 6, 14, 15, 18 and 20 of the Autonomous Sanctions Regulations 2011

 

Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Russia and Ukraine) List 2014

US and other countries' sanctions laws

You should consider the wider legal and commercial context of your activities, and seek your own legal advice on the sanctions laws of other countries, including the United States, that may be relevant to you. The Australian Government cannot provide advice on other countries' sanctions laws.

You may also wish to consult your financial institution to ensure that it will accept any payments from Russia. Some Australian financial institutions have restricted their dealings with Russian financial institutions, including in response to Australian and other countries' sanctions laws, and their own commercial considerations.

Relevant legislation

The relevant legislation for the Russia sanctions regime includes the following:

Other Resources

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