Interactive map: Australia’s financial sanctions

The Australian Sanctions Office (ASO) monitors compliance with sanctions that have been imposed by Australia or by the United Nations Security Council (UNSC) – as a member of the UN, Australia must implement the latter alongside its autonomous sanctions.

Sanctions measures include trade restrictions, commercial activity restrictions, travel bans and targeted financial sanctions. Financial sanctions limit access to financial services, markets, funds and resources. They may be imposed to influence or penalise those responsible for a situation of concern, or to limit its impact.

Targeted financial sanctions, DFAT explains, prohibit the provision of any asset to, or the use of any asset owned or controlled by, an individual or entity subject to targeted financial sanctions.

The ASO maintains a list, called the ‘Consolidated list’, of all individuals and entities subject to targeted financial sanctions. The list includes detailed identifying information about each person and entity, including, where known, date and place of birth, location or address, citizenship, names and aliases, and more.

The map below shows the number of individuals on the ASO Consolidated list with citizenship listed for each country. Darker blue indicates a greater number of individuals holding citizenship who are subject to sanctions in Australia – hover over each country or use the search function for detailed information. 

Assessing risk

“This data shows the importance of maintaining thorough customer due diligence and Know Your Customer processes, and conducting rigorous risk assessments for every client,” IPA Manager Professional Standards Andrew Best says.

“Sanctions are in place for Australian citizens, for example, as well as citizens of several G7 nations – this may defy some expectations.”

Each firm’s AML risk assessment should address targeted financial sanctions and other regime sanctions.

“Include sanctions risk assessments in customer due diligence (CDD) processes, and consider whether you have a clear understanding of company structures and beneficial owners. Keep thorough records of those processes for all clients,” Best says.

“Searching the ASO’s Consolidated List, which is a simple spreadsheet, is good practice to maintain even for low-risk clients.”

What to do if you suspect a breach of sanctions

Accountants and firms must report all breaches of sanctions, or suspected breaches, to the Australian Federal Police (AFP).

Anyone holding assets owned or controlled by an individual or entity subject to targeted financial sanctions must ‘freeze’ those assets (ie, keep hold of them) and report them to the AFP.

Those wishing to act on behalf of a client on the Consolidated List can apply to the ASO for a permit lasting between 180 days and two years. While the application is under assessment, they must not act on behalf of the client and must continue to freeze assets.