Autonomous Sanctions Act 2011¶


Regulator	Department of Foreign Affairs and Trade
Jurisdiction	AU
Status	live
Applicability	Platform

The Autonomous Sanctions Act 2011 (Cth) gives the Australian Government authority to impose autonomous targeted financial sanctions and travel bans independently of UN Security Council resolutions. Sanctions are implemented through the Autonomous Sanctions Regulations 2011 and administered by the Department of Foreign Affairs and Trade (DFAT). The Act enables designations against individuals and entities in relation to specific situations or countries where Australia has decided to act autonomously — including Russia/Ukraine, Myanmar, Iran, and others.

Reporting entities operating in Australia must screen customers, counterparties, and payment beneficiaries against the DFAT Consolidated Sanctions List (which includes both UN Security Council designations given effect in AU law and Australian autonomous designations) and must not provide an asset or service to, or deal with an asset owned or controlled by, a designated person or entity.

Obligations under this Act are operationally parallel to NZ sanctions obligations and are satisfied through the same sanctions screening infrastructure — AML-007 — with DFAT list feeds added alongside the MFAT and UN Security Council lists. The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) also imposes sanctions screening obligations on reporting entities via AUSTRAC.

Compliance register¶

This register maps every material obligation under the Act to the platform control or institutional process that satisfies it. It is the static traceability layer for the Totara compliance report — dynamic data (module build status, test evidence, control test dates) is overlaid at runtime.

Scope legend¶

Symbol	Meaning
🤖 Automated	Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced	Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional	Obligation is met by a process entirely outside the platform — training programmes, board governance, HR, legal. Platform may generate evidence inputs but does not own the process.
N/A	Obligation does not apply to this deployment configuration.

Build legend¶

Symbol	Meaning
✅	Module built and deployed
🔨	Module planned — not yet built (`build_status: Not started`)
❌	Uncontrolled gap — no module attributed

Screening obligations¶

Obligation	Scope	Policy	Platform controls	Build
Screen all customers and counterparties against the DFAT Consolidated Sanctions List at onboarding and on an ongoing basis	🤖 Automated	AML-007	MOD-013 (GATE) — no payment to or from a confirmed sanctions match; hard gate, not advisory; DFAT list included alongside UN Security Council and MFAT lists	🔨
Continuous rescreening — re-screen existing customers when the DFAT list is updated with new designations	🤖 Automated	AML-007	MOD-014 (AUTO) — existing customers rescreened against new designations without manual trigger; list update propagation is automated	🔨
Pre-payment sanctions screen — screen all payment beneficiaries before funds are committed	🤖 Automated	AML-007	MOD-020 (GATE) — sanctions screening is a mandatory pre-payment gate; cannot be bypassed regardless of account relationship	🔨
Correspondent and intermediary screening — screen all payment routing counterparties against DFAT list	🤖 Automated	AML-007	MOD-154 (GATE) — every correspondent and named intermediary screened before routing; DFAT list coverage included	🔨
Tipping-off prohibition — must not inform a designated person that they have been screened or that an asset freeze has been applied	🤖 Automated	AML-007	MOD-013 (GATE) — freeze and block operations occur at the system layer; no notification generated to the customer when a sanctions block is applied	🔨
UN Security Council targeted financial sanctions — give effect to UNSC binding resolutions in AU operations	🤖 Automated	AML-007	MOD-013 (GATE) — UN Security Council designations included in the DFAT Consolidated List feed; same gate applies	🔨

Evidence and audit obligations¶

Obligation	Scope	Policy	Platform controls	Build
Record false positive adjudication — document the reasoning when a potential match is determined not to be a designated person	📊 Evidenced	AML-007	MOD-015 (LOG) — false positive decisions recorded with analyst ID, reasoning, and list reference; auditable by DFAT and AUSTRAC	🔨

Institutional obligations (not platform scope)¶

The following obligations are the responsibility of the institution, not the platform. The platform may generate evidence inputs but does not own these processes.

Obligation	Owner	Platform evidence input
Report to DFAT when a sanctions match is confirmed and an asset is frozen	Chief Compliance Officer	MOD-013 generates the sanctions hit record; human compliance officer makes the DFAT notification
Respond to DFAT and AUSTRAC requests relating to AU sanctions obligations	Chief Compliance Officer	MOD-015 provides the adjudication log and match record for disclosure
Maintain register of frozen assets under DFAT notifications	Chief Compliance Officer	Institutional record; platform provides the source data via MOD-013 and MOD-015
Train staff on AU autonomous sanctions obligations and DFAT list updates	Chief Compliance Officer / Chief People Officer	Institutional LMS; not platform scope

Coverage summary¶

Area	Total obligations	Platform automated 🤖	Platform evidenced 📊
Screening	6	6	0
Evidence and audit	1	0	1
Total	7	6 (86%)	1 (14%)

All obligations have attributed controls. All attributed modules are currently build_status: Not started — the compliance position will update as modules are built and deployed.

Policy	Title
AML-007	Sanctions Screening Policy

See AU AML/CTF Act 2006 for the primary AU AML/CFT framework. See D03 AML / Financial Crime for the full risk domain.

Official documentation¶

Policies referencing this standard¶

AML-007 — Sanctions Screening Policy

Compiled 2026-05-22 from source/entities/regulations/au-autonomous-sanctions-act.yaml