Last reviewed: May 2026 | Russia Autonomous Sanctions TFS
- Australia has imposed comprehensive autonomous sanctions against Russia and Belarus in response to Russia’s
invasion of Ukraine, maintained under the Autonomous Sanctions Act 2011. - Over 1,200 persons and entities are designated under the Russia sanctions regime as at May 2026, including
government officials, oligarchs, financial institutions, and defence sector entities. - The core prohibition: you must not deal with any asset owned or controlled by a Russia-designated person, or
provide financial services to or for the benefit of a designated person. - Designated persons are subject to travel bans — meaning most will be refused entry to Australia at the border
— but this does not remove your independent screening obligation. - Criminal penalties of up to 10 years’ imprisonment apply. A due diligence defence is available under s.17 of
the Autonomous Sanctions Act if reasonable precautions and due diligence are demonstrated.
Background: Australia’s Response to Russia’s Invasion of Ukraine
Following Russia’s full-scale invasion of Ukraine in February 2022, Australia acted rapidly to impose comprehensive
autonomous sanctions coordinated with its like-minded partners — the United States, European Union, United Kingdom,
Canada, Japan, and New Zealand. Australia’s Russia sanctions are among the most extensive autonomous sanctions
measures the country has ever imposed.
The sanctions target three principal categories of persons and entities:
- Russian and Belarusian government officials, including the President, ministers, senior
military commanders, and members of the Russian State Duma; - Oligarchs and high-net-worth individuals with close connections to the Putin regime, including
their immediate family members and associates; and - Strategic entities — Russian financial institutions (including Sberbank, VTB, Alfa-Bank, and
others), state-owned enterprises in the energy and defence sectors, and Russian military-industrial complex
entities.
In addition, Australia has imposed sanctions specifically relating to the Specified Ukraine
Regions — Crimea, Donetsk, and Luhansk — prohibiting certain commercial activities, financial services,
and infrastructure dealings in connection with those regions.
Legal Basis
Australia’s Russia sanctions operate under the following instruments:
- Autonomous Sanctions Act 2011 (Cth) — primary enabling legislation;
- Autonomous Sanctions Regulations 2011 (Cth) — set out the designation criteria for Russia-related
sanctions; - Ministerial declarations under the Autonomous Sanctions Act designating individual persons and entities by name;
and - The Russia section of the DFAT Consolidated List, which is updated in real time as new
designations are made.
Unlike some other regimes, Australia’s Russia sanctions do not derive from a UNSC resolution — Russia and China
hold veto power in the UNSC and have blocked UN-level sanctions. Australia’s measures are therefore purely
autonomous, imposed in solidarity with like-minded nations.
Scope of Prohibited Conduct
Dealing with Designated Assets
Under section 15 of the Autonomous Sanctions Act 2011, it is an offence to directly or indirectly:
- Make an asset available to, or for the benefit of, a Russia-designated person or entity;
- Use or deal with an asset owned or controlled by a Russia-designated person or entity (including by exchanging,
transferring, converting, or providing currency); or - Facilitate any transaction that falls within the above prohibitions.
An “asset” includes money, currency, financial instruments, property rights, and any other thing of economic value.
Physical currency exchanged at a foreign exchange counter constitutes an “asset” for this purpose.
Providing Sanctioned Services
It is a separate offence under section 16 to provide a “sanctioned service” to, or for the benefit of, a
Russia-designated person. This includes financial services and other designated service categories specified in the
regulations.
Sector-Specific and Trade Prohibitions
In addition to TFS against specific individuals, the Russia regime includes broader prohibitions relating to:
- Import and export of specified goods (oil, gas, steel, minerals, luxury goods);
- Financial services in connection with sanctioned Russian entities in specific sectors (financial services,
energy, transport, technology); and - Commercial activities in the Specified Ukraine Regions (Crimea, Donetsk, Luhansk).
For most financial services businesses, the TFS prohibitions (sections 15 and 16) are the most directly applicable.
The trade and sector prohibitions are primarily relevant to businesses importing from or exporting to Russia, or
operating in Russia-connected supply chains.
The DFAT Consolidated List — Russia Designations
All Russia-designated persons and entities are included in the DFAT Consolidated List, available at dfat.gov.au. As at May 2026, Russia-related designations number over 1,200 entries, making it
the largest single autonomous sanctions list maintained by Australia.
The list includes:
- Full legal names and aliases of designated natural persons;
- Dates of birth, passport numbers, and other identifying details where available;
- Legal names and registration details of designated entities; and
- The specific designation criterion met.
DFAT updates the Consolidated List in real time following Ministerial declarations. Compliance teams must have
processes in place to capture list updates without delay and reflect them in screening systems.
Travel Bans
Designated persons under the Russia sanctions regime are subject to travel bans, meaning they are generally refused
entry to Australia at the border by the Australian Border Force (ABF). This provides a meaningful practical
mitigation — a designated Russian national will ordinarily not reach a financial institution’s counter.
permanent residents. They also do not cover persons who entered Australia before being designated, or those present
on humanitarian or exceptional travel grounds. Your institution’s independent screening is the primary control for
these residual categories.
Compliance Obligations for Financial Services Businesses
Pre-Transaction Screening
All customers and counterparties must be screened against the Russia section of the DFAT Consolidated List (and
supplementary lists including OFAC SDN, EU Consolidated List, and UN Consolidated List) before executing any
transaction. Screening must occur on every transaction occasion — a customer who was not designated at their last
visit may have been designated since.
Beneficial Ownership Screening
For wholesale counterparties, corporate customers, and any person acting on behalf of another, you must identify
and screen all beneficial owners (persons owning or controlling 25% or more). Russian oligarchs frequently hold
assets through complex corporate structures specifically designed to obscure beneficial ownership.
Enhanced Due Diligence
Customers who are Russian or Belarusian nationals, or who have connections to Russia-designated sectors or
entities, should be subject to enhanced due diligence — including verification of source of funds, purpose of
transaction, and economic activity.
Ongoing Monitoring
Wholesale and correspondent relationships must be screened on an ongoing basis (at a minimum, monthly) given the
frequency with which new Russia designations are added to the Consolidated List.
Practical Compliance Checklist
| Obligation | Action Required | Frequency |
|---|---|---|
| Customer screening | Screen all customers against DFAT Consolidated List, OFAC SDN, EU/UK lists | Every transaction |
| Wholesale counterparty screening | Screen entity + all beneficial owners + directors | Onboarding + monthly |
| List update monitoring | Subscribe to DFAT Consolidated List update notifications | Real-time / daily |
| Risk assessment update | Assess impact of new Russia designations on risk profile | On material update |
| Incident reporting | Freeze assets, notify DFAT/AFP, submit SMR to AUSTRAC | On confirmed match |
| Staff training | Russia-specific typologies, red flags, escalation procedures | Annually + on updates |
Frequently Asked Questions
- Does the Russia sanctions regime apply to dealings with all Russian nationals, or only those named on the list?
- Only persons and entities specifically designated and listed on the DFAT Consolidated List are subject to the
TFS prohibitions. Dealings with Russian nationals who are not designated are not prohibited by the TFS provisions
alone. However, additional vigilance is appropriate — transactions with Russian nationals connected to sanctioned
sectors, state entities, or known associates of designated persons should be subject to enhanced due diligence. - A customer presents a Russian passport — should we automatically decline the transaction?
- No. Holding Russian nationality is not grounds for automatic refusal. You must screen the individual’s name,
date of birth, and other identifying details against the DFAT Consolidated List and supplementary databases. If
there is no match, and no other red flags, the transaction may proceed (subject to standard CDD). Only a confirmed
match to a designated person requires refusal and the mandatory reporting protocol. - Are Australian-incorporated subsidiaries of Russian companies subject to sanctions?
- Yes, if the Australian entity is owned or controlled (directly or indirectly) by a Russia-designated person, its
assets may be treated as assets of the designated person and subject to the asset freeze. Corporate structure does
not provide a shield. Beneficial ownership analysis is essential for all corporate counterparties with Russian
connections. - How do I handle a situation where a long-standing customer is newly added to the sanctions list?
- Immediately freeze all assets held in connection with that customer. Do not execute any pending transactions.
Notify the Australian Sanctions Office (DFAT), notify the AFP if relevant, and submit an SMR to AUSTRAC. Await
instructions from the relevant authority regarding the disposition of frozen assets. Do not inform the customer
that a report has been made. - Do the Russia sector sanctions affect our ability to provide any financial service to Russian entities?
- Yes, for designated entities and persons. For non-designated Russian entities, the sector prohibitions in the
regulations may still apply if the financial service is connected to certain restricted sectors (energy, finance,
defence, transport, technology). Legal advice is recommended for any wholesale or correspondent relationship
involving Russian entities in these sectors.
This article is general information only and does not constitute legal advice. Sanctions law is subject to
frequent change. Always verify current designations against the live DFAT Consolidated List and seek independent
legal advice for specific situations.