Sanctions 2026

AUSTRALIA Law and Practice Contributed by: Dennis Miralis, Jack Dennis and Phillip Salakas, Nyman Gibson Miralis

Nyman Gibson Miralis Level 9 299 Elizabeth Street Sydney NSW 2000 Australia Tel: +61 2 9264 8884

Email: dm@ngm.com.au Web: www.ngm.com.au

1. Trends and Overview 1.1 Sanctions Market

1.2 Key Trends Statistics on the Use of Sanctions

As of July 2026, approximately 3,838 primary designa - tions were active under Australian sanctions regimes according to the ASO Consolidated List. Comparisons between prior years have been impeded by certain changes to the Consolidated List, renewal of 336 designated entities under the UNSC sanctions related to the 1267 (ISIL (Da’esh) and Al-Qaida) Com - mittee and the introduction of a separate sanctions framework for Vessels. Nevertheless, observations can be made from a close examination of the Consolidated List, as follows. • Sanctions have been imposed against 2,537 indi - viduals, 1,039 entities and 262 vessels. • The sheer number of active sanctions has stead- ily increased year-on-year, with there being 3,213 designations in July 2025 and 3,052 in July 2024. Approximately 25% of the active sanctions were imposed within the first six months of 2026; however, this figure may be misleading due to the renewal of sanctions and the transposition of oth- ers between frameworks. • Of the 262 vessels that have been designated, all but one are Russian and the remainder is Iranian. • The focus of Australia’s sanctions regime contin- ues to be Russia, with 25.3% of active sanctions imposed under the Russian sanctions framework and the overwhelming majority of sanctions under the vessels sanctions framework (making up 6.8%

During the past 12 months, Australia’s focus on sanc- tions has been primarily on Russia, in response to the conflict with Ukraine and against North Korea, to target cybercrime and missile development. The Australian Government is utilising many aspects of the sanctions law, including introducing new frame- works, general permits and adjusting the Oil Price Cap (OPC). However, notable aspects remain underuti - lised, including the Magnitsky-style thematic cyber sanctions framework. The primary regulator, the Australian Sanctions Office (ASO), has maintained a co-operative and educative regulatory approach. Throughout 2026, the ASO has released advisory and guidance notes on a variety of topics and conducted outreach sessions. There is an increasingly strong focus on enforcement and compliance, suggesting that the ASO may soon switch into a more proactive role. Enforcement action will likely be in conjunction with other Australian agen- cies, including the Australian Federal Police (AFP), the Australian Border Force (ABF) and the Australian Transaction Reports and Analysis Centre (AUSTRAC). This may be supported by at least one of the ASO’s sanctions matters being referred to the AFP; however, the outcome of this case and whether it is an isolated enforcement action remains to be seen.

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