Sanctions 2026

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

Council Committee established pursuant to resolution 1718. The PoE was responsible for reporting on North Korea’s non-compliance with sanctions. In response, Australia has joined Canada, France, Germany, Italy, Japan, the Netherlands, the Repub- lic of Korea, New Zealand, the United Kingdom and the United States to establish a member state-led Multilateral Sanctions Monitoring Team (MSMT) to monitor and report on North Korea’s sanctions non- compliance. Australia’s motivation behind participating in the MSMT was driven by the need to address North Korea’s ongoing pursuit of weapons of mass destruc - tion and malicious cyber activities. Since its establishment, the MSMT has released two reports. The first was published on 29 May 2025 and titled ‘Unlawful Military Cooperation including Arms Transfers between North Korea and Russia (MSMT/2025/1)’. The second was published on 22 October 2025 and titled ‘DPRK’s Violation and Eva - sion of UN Sanctions through Cyber and Information Technology Worker Activities (MSMT/2025/2)’. The latter canvassed a range of issues relevant to sanctions enforcement and cyber-related activity. For example, the report outlined that DPRK actors have engaged in a range of cybercrimes, including the theft of USD1.65 billion in cryptocurrency and the theft of sensitive information from defence companies through social engineering, malware and ransomware. The DPRK also uses cryptocurrency (primarily stable - coin) as a means of payment and sale to more easily evade and violate UN sanctions. The report speci- fies the sanctioned entities involved before making 11 recommendations primarily aimed at governments, financial institutions or cryptocurrency-related service providers. Australia’s sanctions response In response to the MSMT’s second report, the Aus - tralian Government imposed financial sanctions and travel bans on four entities and one individual in rela- tion to the cybercrime report. This was done under the Autonomous Sanctions Regulations 2011 – Demo -

cratic People’s Republic of Korea, not the thematic cyber regime. We are likely to see the MSMT recommendations fil - ter through to regulatory action and international law enforcement partnerships, rather than through law reform, given the current landscape of Australian law concerning money laundering, sanctions and related areas. 2026 Focus Point 3: Israel-Palestine Conflict Australia utilises two frameworks in imposing sanc- tions in response to the continuing Israel-Palestine conflict: • The Charter of the United Nations Act 1945 (Cth). For example, Hamas and certain organisations named in relation to Palestine have been listed via this framework. Certain relevant designations were reviewed in July and renewed in September 2025, and new listings were made as recently as 6 June 2026. • The Magnitsky-style human rights sanctions frame- work. The latest were imposed on 2 June 2026 in relation to three additional Israeli individuals and four entities in response to escalating settler violence against Palestinians in the West Bank. These are usually taken as part of a coordinated effort with other countries, including New Zealand, Canada, France, Norway and the United Kingdom. What is important to note is that Australia does not follow these countries in lockstep and there con- tinues to be a growing gap between the sanctions imposed by close allies such as the UK and those of Australia. For Australia’s foreign policy and sanc- tions use, this misalignment is not unusual. Given the calls from human rights organisations for further sanctions in this space and the growing mis- alignment between Australia and its close allies, it is likely that more sanctions are to come. New Frameworks As at July 2026, Australia has 25 sanctions frame - works. These include country-specific, thematic and UNSC-specific.

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