Following the impact of the Russia-Ukraine conflict, Australia has joined the fray by imposing new economic sanctions on Russian individuals, financial intuitions, and businesses under the Autonomous Sanctions Regulations 2011 (Cth).
Australia’s sanction regime imposes strict liability offences for any party that makes assets available to a designated person (business or individual) or engages in the trading of goods and services or commercial activities with such designated persons.
Australia’s sanctions are targeted at the following designated persons:
- 5 senior members of the Russian Government, including Vladimir Putin and Sergei Lavrov
- 339 members of the State Duma of the Federal Assembly of the Russian Federation who voted in favour of recognising the Ukrainian regions of Donetsk and Luhansk as independent republics
- 8 individuals holding senior leadership positions in banks, social media oil, gas and transport companies and companies that support the Russian military
- the Belarusian Minister of Defence, Viktor Khrenin, and the Secretary of the Security Council of the Republic of Belarus, Aleksander Volfovich, and
- 5 individuals and 6 entities with close links to the Belarusian Armed Forces, Russian military, or in senior leadership positions in companies that provide software that supports the use of surveillance and facial recognition technology for the identification, apprehension, and persecution of protestors by the Belarusian and Russian governments.
- prohibit assets from being made available to designated persons, either directly or indirectly for any benefit
- freeze assets owned or controlled by a designated person, and
- prohibit designated parties from travelling to or entering into Australia.
The Australian Government has been closely following the moves of its international neighbours in the United States, the European Union, and the United Kingdom. We will likely see Australia impose further sanctions as the Russia-Ukraine conflict continues, particularly against further Russian financial institutions. These sanctions also create interesting opportunities for the use of digital assets and technology to circumvent legacy financial systems. Russia may even deploy the use of cryptocurrency in its economy, and it will be interesting to see whether Australia introduces new technological economic sanctions in response.
On a domestic level, Australian businesses cannot engage with designated persons and suspend any trade or relations with designated persons. If an Australian organisation is concerned about its business position it should contact the Australian Sanctions Office.