AUSTRALIA Trends and Developments Contributed by: Dennis Miralis, Jack Dennis, Phillip Salakas and Jessica Semsarian, Nyman Gibson Miralis
Changes to the Consolidated List On 6 November 2025, the Australian Sanctions Office launched a new format for the Consolidated List, resulting in changes to reporting. This change was in response to public feedback. The Consolidated List is an official register that the Australian Sanctions Office publishes on its website to display the desig - nated entities and certain other relevant information at that date. Some changes are cosmetic, such as rephrasing cer - tain terms, fixing recurring typographical issues and standardising formatting for dates of birth and nation- alities. Three changes are more informative: • the strength of an alias (either Weak or Strong); • the explicit inclusion of “vessels” (as distinct from entities or individuals); and • the specification of the type of sanction (Targeted Financial Sanction; Travel Ban; Arms Embargo; Maritime Restriction). The first may be useful for companies in undertak - ing risk assessments, given that it is information that may not otherwise have been publicly available. At the same time, the latter two may make an assess- ment process more efficient. Additionally, any indi - vidual vessels that are subject to UN sanctions are not included in this Consolidated List and are located on the 1718 Designated Vessels List on the United Nations Security Council website. However, the tool itself remains largely the same. 2026 Focus Point 1: Russia-Ukraine Conflict Australia utilises at least three frameworks to impose sanctions in relation to the Russia-Ukraine conflict: the Russia country framework, the Ukraine country framework and the new vessels framework. Over the last 12 months, sanctions related to the Rus- sia framework have accounted for only 9.3%. There have been no additions under the Ukraine framework, with the number of active sanctions holding steady at 841. However, 261 of the 262 vessels have been designated in relation to Russia under the new ves-
sels framework, resulting in over 23% of the Austral- ian sanctions imposed between July 2025 and 2026. Overall, the share of active sanctions related to the Russia-Ukraine conflict has risen to 53.9%. Additionally, there have been notable updates regard- ing the Oil Price Cap (OPC) applicable to Russian- origin products. For some time, there has been a total ban on the importation of Russian-origin products and related financial activities. Simultaneously, cer - tain activities related to third-party selling have been allowed via a general permit, subject to the OPC. By February 2025, the general permits that previously authorised OPC-related activities had expired. From that point, those engaging in such activities must have applied and obtained a specific permit. Such activities will be issued only when the typical requirements are met and third-party countries purchase the products at prices below the relevant price caps. At the time of writing, these price caps were: • USD44.10 per barrel for crude oil; • USD100 per barrel for high-value refined petroleum products; and • USD45 per barrel for low-value refined petroleum products. The crude oil price cap was reduced from USD60 on 18 September 2025, further restricting the availability and commercial viability of such activities. Over the last 12 months, the OPC has been reduced twice, on 18 September 2025 (to USD47.60) and 24 February 2026 (to the current level). The other price caps have remained the same. 2026 Focus Point 2: DPRK In terms of raw numbers, Australia’s use of sanctions in relation to the Democratic People’s Republic of Korea (DPRK) has been a significant focal point for the first six months of 2026, with 155 designations under the DPRK country framework. Multilateral Sanctions Monitoring Team and reports In March 2025, Russia vetoed the renewal of the man - date of the Panel of Experts (PoE) under the Security
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