Sanctions 2026

AUSTRALIA Trends and Developments Contributed by: Dennis Miralis, Jack Dennis, Phillip Salakas and Jessica Semsarian, 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

Over the last 12 months, Australia’s sanctions regime has continued to grow and evolve, driven by continu- ing geopolitical tensions, increased global coordina- tion and the pursuit of widespread compliance and streamlining reforms. Snapshot of the Consolidated List: July 2026 In Australia, the key regulator, the Australian Sanc - tions Office (ASO), maintains a list of all individuals, entities and vessels subject to Australian sanctions. This includes aliases, the relevant instruments and the relevant types of sanctions (eg, targeted financial sanctions, travel bans, arms embargoes and maritime sanctions). As of mid-July 2026, 3,838 primary designations were active under Australian sanctions regimes according to the ASO Consolidated List. These comprised 2,537 individuals, 1,039 entities and 262 vessels. When compared to preceding years’ Consolidated Lists, it is clear that Australia’s active sanctions con- tinue to climb year-on-year. In fact, the 3,838 active listings as at July 2026 are a jump compared to the 3,213 designations in July 2025 and the 3,052 in July 2024. Further examination of the Consolidated List informs the article below. 2024 Reviews and 2026 Reform? We are witnessing the slow emergence of effects from the reviews and reports conducted between 2023 and 2025 and more are to come. For example, the ASO has already taken steps to simplify the Consolidated

List and to release extensive guidance and advisory notes (see further below). DFAT carried out the primary review into Australia’s autonomous sanctions framework after 12 years of operations. This review commenced in January 2023 and concluded on 30 October 2024, titled “Review of Australia’s Autonomous Sanctions Framework” and was started in light of the impending expiry of the Sanctions Act on 1 April 2024. This was extended to 1 October 2027. Although another extension could be on the cards, we will likely see public consultations and reforms proposed over the next 12 months. The other reviews covered topics including one in September 2024 on Australia’s support for Ukraine; another on the regime more generally, which con- cluded in February 2025; and a fourth in March 2025 concerning the thematic sanctions frameworks. Overall, these reviews noted a serious need to strengthen regulatory monitoring and enforcement capabilities and a strong desire for increased reason- ing and challenging processes. These reports called for significant legislative reform and increased regula - tory operations for both compliance and enforcement. The Australian Government has signalled the reform process is still underway “to ensure [the sanctions laws] are fit for purpose and easier to understand”. They are currently considering reform proposals and drafting legislative and regulatory amendments. The next steps of the process will include releasing expo- sure drafts for at least one round of public consulta- tion. So watch this space.

22 CHAMBERS.COM