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Sanctions before you trade: the list, the permits and the reform

Direction
Inbound and outbound
Who acts
Anyone in Australia, and Australians overseas
Checked
9 October 2026

Australian sanctions laws apply to activities in Australia, to activities overseas by Australian citizens and bodies corporate, and to activities on Australian-flagged vessels and aircraft, and they can prohibit trade in certain goods and services with specific countries or regions as well as dealings with listed people and entities. The Australian Sanctions Office (ASO) keeps the Consolidated List that is the first check, and the laws themselves are being reformed.

General information, not legal advice. The official place to check is the Australian Sanctions Office, part of DFAT, whose pages are listed at the foot of this page.

The rules can change

As DFAT’s page read on 9 October 2026, the government says it will make the reforms through three Bills and two pieces of subordinate legislation, and “The primary Bill underpinning the reforms is the Autonomous Sanctions Bill 2026.” Public consultation opened on Monday 7 September 2026 and was extended to Friday 16 October 2026, on a point-in-time exposure draft of that Bill.

Everything below describes the law as it stood when it was read. Check the Australian Sanctions Office’s pages before relying on any of it.

Two kinds

Two kinds of sanctions, and the laws behind them

DFAT describes sanctions as “measures not involving the use of armed force that are imposed in response to a situation of international concern.” Australia enforces two kinds. United Nations Security Council sanctions are imposed by the Security Council, and Australia is obliged to implement them as a matter of international law; they are governed by the Charter of the United Nations Act 1945, alongside the Charter of the United Nations (Dealing with Assets) Regulations 2008. Australian autonomous sanctions are imposed by the Australian Government as a matter of foreign policy, under the Autonomous Sanctions Act 2011 and the Autonomous Sanctions Regulations 2011.

Sanctions are grouped into frameworks named after the country, group or theme they respond to. DFAT’s page lists the frameworks alphabetically, from Afghanistan to Zimbabwe, with themed ones such as serious corruption and significant cyber incidents among them.

What they stop

What a sanction can stop

Targeted financial sanctions
These bar making assets available to designated persons or entities, and bar dealing with assets they own or control, which in effect freezes those assets. The Autonomous Sanctions Act defines an asset widely: “an asset of any kind or property of any kind, whether tangible or intangible, movable or immovable, however acquired”.
Restrictions on goods, services and commercial activities
These generally prohibit the export or import of certain goods, the provision of certain services, and certain commercial activities with specific countries or regions.

For goods on the Defence and Strategic Goods List, sanctions also weigh in Defence’s permit decision, as the guide to export permits for controlled goods explains.

Check first

The Consolidated List

  • What it holds. The ASO maintains and regularly updates the list of all individuals, entities and vessels subject to Australian sanctions, with names and aliases, dates and places of birth, citizenships and addresses.
  • When to check it. The ASO calls checking it before dealing with an individual, entity or vessel “a precaution you can take to help prevent you from contravening Australian sanctions laws.”
  • What it leaves out. It lists only those listed under Australian sanctions laws, including those listed by the UN Security Council, and not people listed under other countries’ sanctions laws.
  • A match. The ASO’s advice is to “seek legal advice before proceeding with any dealings involving that person, entity, or vessel, or any assets owned or controlled by them.”
  • An asset already held. Anyone who is, or thinks they may be, dealing with an asset owned or controlled by a designated person or entity must hold, or freeze, it, inform the ASO and notify the Australian Federal Police as soon as possible.
Permits

When a permit is the answer

A sanctions permit, issued by the Minister for Foreign Affairs or a delegate, authorises an activity that would otherwise breach Australian sanctions laws, and each framework sets its own criteria. The ASO is clear that permits are not the first tool: it “advocates for proactive risk management rather than relying on permits”, and treats a permit as generally appropriate only where a contravention is clearly likely. For broad risks, it points to reasonable precautions and due diligence. Under the autonomous frameworks, the Minister must be satisfied a permit is in the national interest.

Applications go through the ASO’s Pax Portal. The ASO says to allow a minimum of three months, especially for complex activities and high-risk countries or regions, and to note any critical commercial deadlines in the application. It does not give legal advice. Giving false or misleading information in connection with the administration of sanctions laws is a serious criminal offence, and a permit granted on such information is treated as never granted.

Penalties

The penalties, as the 2011 Act stands

These are the penalties in section 16 of the Autonomous Sanctions Act 2011 as compiled at 9 April 2024, before the reform described at the top of this page. An individual whose conduct contravenes a sanction law, or a condition of an authorisation under one, faces imprisonment for not more than 10 years, a fine, or both. Where the court can determine the value of the transaction, the fine can reach the greater of three times that value or 2,500 penalty units; otherwise it can reach 2,500 penalty units. For a body corporate the offence is one of strict liability, and the fine can reach the greater of three times the transaction’s value or 10,000 penalty units where the court can determine that value; otherwise it can reach 10,000 penalty units. The body corporate has a defence if it proves it “took reasonable precautions, and exercised due diligence”. Anyone who applies for an authorisation under a sanction law must keep the records relating to the application for 5 years, counted from the day the Act sets.

Sanctions sit beside the other checks on this site: export permits for controlled goods for goods going out, and import declarations for goods coming in.