Australian Autonomous Sanctions

The Australian Sanctions Office (ASO) is the Australian Government’s sanctions regulator and sits within the Department of Foreign Affairs and Trade’s (DFAT) Legal Division. Sanctions impose restrictions on activities that relate to particular countries, themes of conduct, goods and services, or persons and entities. Australian sanctions laws apply to activities within Australia and to activities undertaken overseas by Australian citizens (and Australian‐registered bodies corporate). Violating Australian sanctions laws can result in severe criminal penalties.

Australian sanction laws implement United Nations Security Council (UNSC) sanctions regimes and Australian autonomous sanctions regimes. The sanctions regimes currently implemented under Australian sanction laws are shown in the figure below (source: DFAT website):

How do sanctions affect university activities?

Sanctions measures may impact a range of activities including:

• enrolling a student from a sanctioned country
• employing a person from a sanctioned country
• collaborating with another person or entity (including a foreign university) from a sanctioned country.
• supply of certain goods to sanctioned countries
• provision of certain services to sanctioned countries
• provision of assets to designated persons and entities
• dealing in the assets of a designated persons or entity
• travel bans on certain individuals

For detailed information on the sanctions measures imposed by each regime implemented by Australia, please refer to relevant sanctions regimes.

Enrolment of HDR students from a sanctioned country

The ANU Graduate Research Office has established procedures for undertaking risk assessments in relation to prevailing sanctions on applicants for admission to Higher Degree Research Programs, and applications from continuing candidates to change Higher Degree Research Program or change of research topic. Contact Graduate research Office for further information.

Consolidated lists

The Consolidated List includes all individuals and entities subject to Australian sanctions laws. Listed persons and entities are subject to targeted financial sanctions. Listed persons may also be subject to travel bans.

The ASO maintains and regularly updates the Consolidated List. You can subscribe to the email list to receive updates to the list.

Individual researchers are responsible for undertaking necessary due diligence checks necessary to understand whether any of the individuals or entities connected with the proposed activity are listed.

Sanction permits

In some circumstances, it may be possible to obtain a sanctions permit from the Minister for Foreign Affairs to engage in an activity that would otherwise be prohibited by a sanctions measure. Different sanctions regimes impose different criteria for the grant of a permit. Information on the criteria for the grant of a permit is provided under each Sanctions Regime. 

The ASO works closely with other government regulatory agencies, including Defence Export Controls (DEC) to implement Australian sanctions law. In some cases, an export will require both a DEC permit, and a sanctions permit.  ASO frequently requests technical assessments from DEC regarding the export of goods and technology to inform decisions on sanctions permit applications. 

The ANU Research Compliance Office is responsible for submitting sanctions permit applications on behalf of researchers wishing to engage with sanctioned individuals or entities. Please contact us for more information.