Know the list and its owner
Australian sanctions laws operate through regulations made under the Autonomous Sanctions Act 2011 and the Charter of the United Nations Act 1945. DFAT maintains the Consolidated List for all persons and entities designated for TFS under those laws. AUSTRAC guidance directs reporting entities to the Consolidated List and stresses that sanctions change often, so the most recently published list must be checked.
Screening is not a one-time event. A customer who was not on the list at onboarding may be designated later, which is why ongoing screening and monitoring matter. The program should define re-screening events and frequencies.
Run the check on the right subjects
A sanctions match is a legal red line: Australian law prohibits providing assets or services to designated persons and using or dealing with their assets, subject to the specific prohibitions in each regime. A confirmed match is not a risk rating to debate; it is a legal blocker requiring the practice to freeze or refuse and take the steps the law requires.
- Each customer and beneficial owner or controller
- Counterparties and parties to the transaction where the program requires
- Representatives and intermediaries for higher-risk relationships
- New owners discovered during review cycles
Confirm before you act
Vendor results can include false positives from name variations, aliases, transliteration and similar names. Confirm the match against identifiers such as date of birth, passport or registration details, address, alias and entity identifiers before treating it as a designation. Where the match is confirmed, do not continue providing the service and follow the applicable sanctions law and any reporting requirements.
Record both the vendor result and the confirmation. A file that shows the search date, the list version, the identifiers compared and the disposition explains why a false positive was cleared and a real match was blocked.
Integrate sanctions with the AML/CTF program
Sanctions and AML/CTF are separate legal frameworks that operate together in practice. A designated person may also trigger an SMR, and an SMR process does not suspend sanctions obligations. The program should connect both controls so one does not wait for the other.
- Screen at onboarding, before the service starts
- Re-screen on risk-based events and ownership changes
- Escalate confirmed matches to the compliance officer immediately
- Coordinate with suspicious-matter reporting where the facts also raise suspicion
- Retain the list version and search evidence for the program's retention period
Official sources
Use these primary AUSTRAC pages to confirm the current rules and apply them to your circumstances.
Frequently asked questions
Where is the Australian sanctions list published?
DFAT maintains the Consolidated List of persons and entities designated for targeted financial sanctions under Australian sanctions laws. AUSTRAC directs reporting entities to use it and to check the most recent version.
Is a sanctions hit the same as a PEP match?
No. A PEP is a politically exposed person who may warrant enhanced scrutiny; a sanctions designation is a legal prohibition on dealing. Do not treat them as interchangeable results.
How often should we re-screen customers?
Set risk-based frequencies in the program and re-screen on material events such as ownership changes, new services or unusual activity. Because the list changes often, periodic re-screening is an operational requirement.
What do we do with a confirmed match?
Stop providing the service and dealing with the person or entity, follow the applicable Australian sanctions law and any reporting requirements, and escalate immediately. Record the evidence and the decision.
Put it into practice
Cassandra AML turns these obligations into a working system: designated-service decisions, customer due diligence, screening, monitoring and reporting records — hosted in Sydney, free to start.
This guide is general information for Australian professionals. It is not legal advice and does not replace the AML/CTF Act, the AML/CTF Rules or AUSTRAC guidance. Confirm your specific obligations with AUSTRAC or a qualified legal adviser. See our editorial and correction standards.