Sanctions Compliance

Australia implements both United Nations Security Council (UNSC) sanctions and its own autonomous sanctions regimes governed by the Charter of the United Nations Act 1945 and Autonomous Sanctions Act 2011, respectively. These laws restrict certain activities such as providing military or strategic goods, services (including technology transfer, technical assistance or advice and dual-use goods), or financial support to designated individuals, entities, or countries. All Australian individuals and institutions including universities must comply with these laws.

At Western Sydney University, we are committed to upholding our legal obligations by conducting due diligence in international collaborations, student and staff engagements, research activities, and financial transactions.

The Australian Sanctions Office (ASO) sits under the Department of Foreign Affairs and Trade (DFAT) and is the government regulator that administers Australian sanctions. Different sanctions regimes enforce different types of measures; the Minister for Foreign Affairs or the Minister's representative may be able to issue a permit authorising an activity that would otherwise contravene an Australian sanctions law. It is a serious criminal offence to contravene a sanctions measure (or a condition of a sanctions permit). The penalties include up to ten years in prison and substantial fines.

More information on sanctions is available from DFAT, see Australia and Sanctions

Sanctions Regimes

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:

You can find a list and details of Australia’s sanctions regimes under Sanctions Regimes

How do sanctions affect research staff and students?

Australia’s sanctions laws prohibit the University from engaging with certain individuals, entities, and countries. This includes providing them with access to specific types of training, services, technology, or resources, unless a sanctions permit has been granted by the Australian Sanctions Office (ASO). These restrictions apply across a range of university activities, including research, teaching, international partnerships, financial transactions, and recruitment.

The most common activities that are of particular relevance to researchers that may involve sanctioned individuals, entities or countries may include but not limited to:

• Research staff recruitment
• Admission and enrolment of Higher Degree of Research (HDR) candidates
• Research collaborations (formal and informal) involving international partners
• Academic travel for collaboration, or conferences where the sharing of information may inadvertently enable access to sanctioned goods, technology, or research data
• Payments to sanctioned entities for goods or services
• Research funding or commercial research income originating from or connected to sanctioned entities or countries

Western staff involved in any of these areas must ensure appropriate due diligence is undertaken and seek advice where necessary to comply with sanctions obligations.

For full guidance with examples of case studies, visit the Australian Sanctions Office’s Guidance for Universities

Facilitating Compliance

HDR Students from sanctioned countries

The HDR candidature process includes a step for applicants from sanctioned countries, where their application is flagged in the system. As part of this process, the nominated supervisors are required to complete the UN Sanctions Compliance Assessment Form. The form is then submitted to the School/Institute for review, followed by approval from the Dean of Graduate Studies. The Graduate Research School (GRS) team is informed of the outcome, indicating whether the application will proceed or be declined.

If the application is approved, supervisors must ensure that HDR students from sanctioned countries are restricted from accessing controlled equipment, software, technology or materials during their studies at Western. It’s also important to monitor and limit any changes to the scope of their research project throughout their HDR journey. If the project scope does change, please contact GRS for further guidance.

Staff or Visitors from sanctioned countries

HR review process includes verification of recruiting staff against the current sanctioned lists before any offer of employment is made.

If a staff/visitor from a sanctioned country is recruited, the line managers must ensure the staff/visitors are restricted from accessing controlled equipment, software, technology, or materials while at Western. If the staff requires access to the controlled items, a sanctions permit may be required. For further guidance, please contact the Research Office (research.compliance@westernsydney.edu.au)

Research Collaboration and Activities

Australian sanctions laws apply to research collaborations involving individuals, institutions, or countries subject to sanctions, and a sanctions permit may be required for certain activities to ensure compliance and avoid contravening the law.

Questions to consider:

• Are any collaborators, institutions, or funders listed on the DFAT Consolidated List or affiliated with sanctioned countries?
• Does the research activity include goods, technology, or software listed on the Defence and Strategic Goods List (DSGL)? Could the research activity have military or dual-use applications? For more information please refer to Defence Export Controls webpage at Western.
• Is the research taking place in, or being shared with, individuals or entities in sanctioned countries?
• Does the research involve travelling to countries subjected to sanctions?

If you have answered ‘Yes’ to any of the questions above, please contact the Research Office (research.compliance@westernsydney.edu.au) for further advice and guidance.

For all international collaborations with individuals/entities located overseas, please complete the Foreign Arrangement Notification form for a due diligence check.

Additional Resources

The Australian Sanctions Office has developed the Sanctions Compliance Toolkit and the Sanctions Risk Assessment Tool to help researchers understand and comply with Australian sanctions laws. These tools provide clear, practical guidance on identifying potential risks in research activities, including international collaborations and data sharing. By outlining key compliance principles, risk management strategies, and best practices, the resources support researchers in ensuring their work does not inadvertently breach sanctions regulations.