Australia and sanctions

The IT sector includes companies involved in the provision of products and services, including software, hardware, networking, cybersecurity, and cloud computing. Telecommunications and webhosting companies also face sanctions risks when providing services or infrastructure.

Low-risk sectors in relation to sanctions refer to areas of business activity that are less likely to be directly targeted by sanctions or have a lower potential for sanctions contraventions. While it is challenging to classify any sector as entirely 'low risk' some areas are typically regarded as having less exposure to sanctions.

Australia has imposed autonomous sanctions on the importation of certain Russian-origin energy goods, including petroleum gases, oil, and refined petroleum products. These goods are Russia's largest source of export revenue. By sanctioning these goods, Australia aims to diminish Russia's ability to finance its illegal and immoral invasion of Ukraine.

This guidance note details the restrictions on dealing with sanctioned vessels. It also outlines the responsibilities of individuals and businesses to take reasonable precautions and exercise due diligence to ensure adherence to sanctions. This guidance is aimed at the financial and maritime sector.

Fintech (financial technology) and DeFi (decentralised finance) companies are required to adhere to Australian sanctions laws. It is expected that Fintech and DeFi companies (companies) have in place sanctions compliance policies, and appropriate risk mitigations measures.

This Guidance Note is produced by the Australian Sanctions Office (ASO) within the Department of Foreign Affairs and Trade (DFAT). It provides a summary of relevant sanctions laws but does not cover all possible sanctions risks. 

The Minister for Foreign Affairs (the Minister) has by legislative instrument designated persons and entities for targeted financial sanctions and declared persons for travel bans (together, 'listed') in accordance with item 6A of regulation 6 (the Russia Criteria) of the Autonomous Sanctions Regulations 2011 (the Regulations).

This guidance note details the restrictions on exporting certain goods to Russia and specified regions of Ukraine (Crimea, Sevastopol, Luhansk, and Donetsk) and sanctioned services relating to a sanctioned supply or associated activities.

Over the coming months, the Australian Sanctions Office will be progressively making improvements to the PAX Portal to enhance user experience and overall functionality.