Sanctions 2025

AUSTRALIA Law and Practice Contributed by: Dennis Miralis, Jack Dennis, Henry Yu and Darren Pham, 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

• There continues to be a deceleration of sanctions use. As at June 2024, there were almost double the amount of sanctions that had been imposed as at June 2025. Of the sanctions still in force, 35.62% were imposed in 2022, 25.31% were imposed in 2023, 13.96% were imposed in 2024, with only 6.9% being imposed in the first six months of 2025. • Australia’s overall focus with sanctions remains on the Russia–Ukraine conflict. Over 50% of in-force sanctions as at June 2025 relate to the autono - mous sanction regimes concerning Russia and Ukraine. • Australia’s sanctions focus is narrowing. In the first six months of 2024, an almost equal amount of individuals and entities were designated under the autonomous sanctions regimes relating to Syria (25.3%), Russia (24.1%), and Iran (23.2%). This focus barely shifted throughout the remain - ing six months. In contrast, Australia’s sanctions regime over the first six months of 2025 has been squarely utilised in relation to Russia (85.78%) and the remainder peppered towards ISIL (Da’esh) and Al-Qaida, UN 1373 (2001), and Magnitsky-style sanctions. • There continues to be a steady but minimal use of Magnitsky-style sanction instruments since the introduction of the Autonomous Sanctions Amend - ment (Magnitsky-style and Other Thematic Sanc - tions) Regulations 2021 (Cth) (the “Magnitsky-style Regulations”) in December 2021, with Australia incrementally using these powers more throughout 2024, with five of the nine instruments being issued between November 2023 and June 2024. While

During the past 12 months, Australia’s steady decel - eration in the use of sanctions overall continued and contrasted against an influx of government reviews. It remains to be seen what will come from the multiple recommendations. However, the stakeholders made it very clear that they want change in both the legislation and regulatory operations. Out from the gates of 2025, the primary regulator’s co-operative and educative regulatory approach has been amped up with the release of a deluge of advi - sory and guidance notes and in conducting outreach sessions. There is an increasingly strong focus on enforcement and compliance, suggesting that the Australian Sanctions Office (ASO) may soon switch into a more proactive role. Russia is now the primary focus for Australian sanc - tions law, with the overwhelming amount of sanctions directed towards the Russia-Ukraine conflict and Rus - sia’s potential sanctions evasion tactics being a pri - mary concern of the recent government reviews. 1.2 Key Trends Statistics on the Use of Sanctions As of July 2025, approximately 3,259 individuals and entities were designated under Australian sanctions regimes according to the Consolidated List. From an examination of the Consolidated List, the following observations can be made:

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