International sanction compliance
Curtin University staff and students engaging in activities with an international connection should be aware that various international sanctions may affect those activities. The University is required to comply with Australian Autonomous Sanctions regimes and United Nations Security Council (UNSC) sanctions regimes. These regimes include restrictions on:
- The supply of goods and services to particular persons, entities or countries;
- Engaging in commercial activities with particular persons, entities or countries; and
- Travel too, or transit through Australia by specified persons.
Individuals can face a penalty of up to 10 years in prison and/or significant fines of $500k for breaching a sanction. The University could also be subject to a fine of over $2M.
Impact on activities in Australia
Sanctions restrictions prohibit the University from providing training to specified persons or persons with significant links to specified groups or entities. There may also be prohibitions on postgraduate research in certain fields to individuals from specified countries. The Office of the Chief Security Officer works with relevant university stakeholders to ensure compliance with these obligations.
Impact on activities outside Australia
University staff planning to participate in:
- Collaborative projects, exchanges or conferences involving international universities, entities or governments ; or the
- Transfer of funds or equipment, or intangible assets such as intellectual property outside Australia;
Should be vigilant in managing the risk potential for interaction with nations, entities or individuals subject to restrictions under sanctions. The level of vigilance applied to manage the risk should reflect the level of international engagement activity.
Assessing the Risks
You can search for specific entities and individuals on the Consolidated List managed by the Department of Foreign Affairs and Trade (DFAT). DFAT also provides detailed information on the scope of sanction regimes that apply to various countries.
If your plans include activities which could potentially contravene an Australian sanction law, the University may be able secure a permit authorising those activities from DFAT.
For more information on sanction compliance at Curtin University, including advice on applying for a sanctions permit, please contact the Chief Security Officer, Gary Hale on email@example.com.