Australia and sanctions

The UN humanitarian exemption can be relied on in limited circumstances, but it is important to understand that this exemption only applies to UNSC sanctions and does not provide an exemption to sanctions imposed under Australian's autonomous sanctions framework.

This guidance applies to all companies, employees, agents, representatives, and subsidiaries of your businesses.

Australian businesses involved in the mining and machinery export sectors to Russia are at heightened risk of contravening Australian sanctions law if they are involved in the export of machinery and related goods that fall under Australian Harmonized Export Commodity Classification (AHECC) codes 8207, 84, 85, 8806 and 8807. 8806 and 8807 relate to unmanned vehicles (drones) and componentry.

Australia has imposed sanctions on vessels in response to situations of international concern, including in response to Russia's invasion of Ukraine and to increase pressure on the Democratic People's Republic of Korea (DPRK) to comply with its nonproliferation obligations.

In accordance with section 15 of the Charter of the United Nations Act 1945 (Cth) (the Act), the Minister for Foreign Affairs (the Minister) has previously listed, by legislative instrument, certain persons and entities. These persons and entities are hereby given notice that these listings are being considered as to whether they will continue to have effect.

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).

On 19 May, AUSTRAC released ‘the second public consultation on new AML/CTF Rules’. Among the proposed changes include the requirement for reporting entities regulated by AUSTRAC to develop, maintain and comply with policies to ensure that they do not contravene targeted financial sanctions obligations, including asset freezing, in the provision of their designated services.

In accordance with regulation 6A(4) of the Autonomous Sanctions Regulations 2011, the Minister for Foreign Affairs has designated two individuals for targeted financial sanctions and declared them for travel bans.

The Australian Sanctions Office (ASO) has released 10 new guidance and advisory notes to assist the regulated community understand their sanctions obligations.