Australia and sanctions

This guidance note sets out how Australian sanctions laws apply to Australian citizens, and foreign residents living in Australia, considering employment with designated persons or entities. 

Targeted financial sanctions have been implemented by the United Nations Security Council (UNSC) and / or the Australian Government against holders of political office including current and former ministers from a range of countries.

Within the financial sector, there are instant payments systems known as remittance services that allow users to send and receive funds almost immediately. These systems operate at high speeds and volumes, posing questions about sanctions compliance measures.

Australian touring companies and sports professionals are subject to increased risk of sanctions contravention generally when participating in activities in countries subject to Australian sanctions. It is essential for these entities and individuals to be fully aware of their sanctions obligations when organising or engaging in activities in jurisdictions where such sanctions exist. 

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.

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).