Australia has implemented sanctions legislation and regulations which are designed to control situations of international concern without involving the use of armed force but rather by restricting trade, commercial activity and travel. The Australian Sanctions Office (ASO) sits within Department of Foreign Affairs and Trade’s (DFAT) Legal Division and is the Australian Government’s sanctions regulator. The University of Wollongong is required to comply with the Australian Government’s Charter of the United Nations Act 1945 and the Autonomous Sanctions Act 2011 and related regulations.
It is a serious criminal offence to contravene a sanctions measure (or a condition of a sanctions permit). It is critical that all staff at the University understand sanctions and comply with them. All staff are required to understand the University’s processes and take reasonable precautions and exercise due diligence to prevent conduct that may breach sanctions.
The following information is provided to assist you to determine if sanctions could influence your ability to recruit HDR candidates, invite visiting students and academics to the university, travel internationally or collaborate with researchers overseas.
The Dean of Graduate Research is able to provide you with further information on Sanctions in relation to supervision of HDR candidates or Visiting Research Students. The Dean of Graduate Research is the responsible officer for the Autonomous Sanctions approval or rejection of proposals for admission to candidature or changes to research project.
The Research Integrity and Ethics Unit has a dedicated point of contact, the Research Integrity Officer, who can provide you with further information and advice on Autonomous Sanctions and provide guidance on the permit application process in relation to your research.
DFAT have advised of new listing criteria related to Russia, effective 25 February 2022, and new measures for the Donetsk and Luhansk regions of Ukraine, effective 28 March 2022. Australia has announced extended sanctions as follows:
- From 7 April 2022, the supply, sale or transfer of certain luxury goods directly or indirectly to, for use in, or for the benefit of Russia is prohibited.
- From 25 April 2022, the import of oil, refined petroleum products, natural gas, coal and other energy products from Russia is prohibited.
The consolidated list of designated persons and entities is being updated regularly. Of note, updates extend beyond Russia and Ukraine.
Academics with collaborations in these regions are encouraged to review the changes.
For further information and to keep up to date, subscribe to DFAT’s news page.
International Collaboration and Other Regulatory Requirements
Sanctions are just one of the regulatory requirements designed to ensure that Australia’s national interest is protected. The investigators, partners and research area of all projects should be assessed to ensure the project complies with all assessment, permit and notification requirements for Defence Export Controls, the Foreign Influence Transparency Scheme and the Foreign Arrangements Scheme. The Regulatory Checklist for International Collaborations is designed to help staff navigate the legislative requirements and understand if a permit, notification or additional assessment is required.
- Information on Sanctions
- How do sanctions affect research?
- Sanctions breaches and offences
- Sanctions permits
- Forms, Guidelines and Policies
- Frequently Asked Questions
Australia currently implements the sanctions regimes listed on the Department of Foreign Affairs and Trade (DFAT) website. Sanctions change frequently, so it is important to consult the DFAT sanctions webpage for current information.
Sanctions measures are aimed at removing circumstances which threaten international and/or national security. In terms of research at the University, these measures may be relevant to enrolling students (HDR and Visiting) from sanctioned regimes, travel to sanctioned countries for conferences and seminars and collaboration activities between universities and academics. Sanctions measures can vary from regime to regime. Detailed information on the sanctions measure imposed by a particular sanctions regime can be found on the DFAT website.
Australia’s sanctions laws prohibit the University from dealing with specific individuals and entities, or providing those individuals, entities and specified countries with access to certain types of training, services and resources - unless a permit has been granted.
This is of particular relevance to researchers at the University with respect to:
- Recruitment, admission and enrolment of Higher Degree Research candidates
- Visiting Research Students
- Visiting Academics
- Student Exchanges
- Research Collaborations
- Fees received from sanctioned regimes
- Fees paid to sanctioned regimes
- International Examiners of Theses
- Travel for collaboration, seminars, conferences where the material shared may breach sanctions laws by enabling access to and/or use of sanctioned goods, information or technology
It is important for researchers to understand that individuals from sanctioned countries are prohibited from undertaking certain types of research projects or being provided technical advice, assistance or training in sanctioned goods, information, technology or materials unless a permit has been granted.
Both the University and individual researchers are expected to take reasonable precautions and exercise due diligence to apply the restrictions. As a researcher, it is your responsibility to ensure you do not contravene a sanctions law. You can do this by:
- Being informed – familiarise yourself with the information available on the DFAT website and complete training
- Familiarising yourself with the sanctioned regimes and complete your due diligence
- Familiarising yourself with the consolidated list and complete your due diligence
- Planning ahead if you are travelling for a collaboration, partnership, seminar or conference – familiarise yourself with the Travelling Overseas with Devices Procedure.
- Asking for an assessment by the Dean of Graduate Research if you are recruiting a HDR candidate or Visiting Research Student or recruiting a thesis examiner from a sanctioned regime.
- Contacting the Research Integrity and Ethics Unit if you believe your proposed research activity is affected by sanctions so you can discuss applying for a permit.
It is a serious criminal offence to contravene a sanctions measure (or a condition of a sanctions permit). The penalties include up to ten years in prison and substantial fines.
As a researcher you need to:
- Be informed.
- Apply for a sanctions permit when required.
- Take reasonable precautions to avoid contravention of a sanctions measure.
- Provide true and accurate information. Penalties also exist for providing false or misleading information.
- If you think you have breached, or at risk of breaching an Australian sanctions law, or if you have information in relation to a possible illegal activity or you have made a mistake and unintentionally undertaken an activity that contravenes a sanctions law you should report it immediately. Contact the Research Integrity and Ethics Unit for assistance.
A sanctions permit provides authorisation to undertake an activity that would otherwise be prohibited by an Australian sanctions law. A permit may have associated conditions.
Information on the criteria, information that will need to be provided, how to make an application using the Pax system, expected turnaround times and conditions can be found on the Department of Foreign Affairs and Trade Sanctions Permits website.
Contact the Research Integrity and Ethics Unit for queries and assistance or if you believe a permit may be required.
UOW Documents (Internal access only):
- Department of Foreign Affairs and Trade – Sanctions webpage
- Current sanctioned regimes
- Consolidated list of persons and entities
- Pax system – questions about sanctions, indicative assessments and applying for a permit. Contact the Research Integrity and Ethics Unit in the first instance if you believe a permit may be required.
* Note this is not a definitive list, other legislative considerations can be found within the Department of Foreign Affairs and Trade, Australian Sanctions Office website.
The Department of Foreign Affairs and Trade (DFAT) provided a Virtual Information Session on Sanctions in April 2021 which is available on their website.
Training on sanctions is also incorporated into the Defence Export Controls Office (DECO) awareness training. Refer to Module 2.
You can subscribe to DFAT's mailing list to receive regular updates on Australian sanction laws
A webinar on International Collaborations, including researcher responsibilities for Sanctions was held on Tuesday 30 November 2021. A copy of the slides and recording can be found in the International Collaborations folder in the self-enrol Research Integrity Moodle site
Training can be delivered by the Research Integrity and Ethics Unit and may take the form of seminars, workshops and tailored training sessions delivered to affected research groups upon request.
Help and Advice
The Dean of Graduate Research can assist prospective students who have questions about sanctions requirements. The Dean of Graduate Research can also assist University staff members who need help in assessing the risks regarding a prospective student, a visiting research student, visiting academic or thesis examiner from a sanctioned regime.
The Research Integrity and Ethics Unit can assist researchers with sanctions compliance and permit applications. They are also available to offer presentations for your School, Faculty or research group upon request. To determine if you need a permit, want to arrange a presentation or are still unsure about whether your research is affected by Sanctions legislation contact the Research Integrity and Ethics Unit.
How do I know which countries are sanctioned?
We encourage you to visit Department of Foreign Affairs and Trade (DFAT) website to review the full list of sanctions imposed and enforced by the Government. The website is updated regularly and contains the most current advice.
How do I check if an individual is known as a 'designated person'?
Refer to the consolidated list on the DFAT website. The website is updated regularly and contains the most current advice. DFAT maintain a subscription mailing list for people interested in receiving updates to the consolidated list.
I have a student or academic who wants to visit the University and they are from a sanctioned country - what do I need to do?
It is important to note that although the student or visitor may have been granted a visa, a permit may also be required depending on the project.
If the permit is for a HDR Student or Visiting Research Student, contact the Dean of Graduate Research for further advice. Remember projects should also be assessed to ensure the project complies with all assessment, permit and notification requirements for Defence Export Controls, the Foreign Influence Transparency Scheme and the Foreign Arrangements Scheme.
If the permit is in relation to your research activities, please contact the Research Integrity and Ethics Unit so we can discuss the situation and provide appropriate advice. You can also refer to the DFAT website for more information on Sanctions permits.
What if a student I am considering supervising is from a sanctioned country?
Supervisors are advised to contact the Dean of Graduate Research to discuss the potential student as early as possible. Any potential student should be advised that the UOW Future Students team and the Graduate Research School will undertake a risk assessment and you can direct them to the Australia and sanctions page on the DFAT website for further information.
What do I need to do in the event I require a permit?
If the permit is for a HDR Student or Visiting Research Student, contact the Dean of Graduate Research for further advice.
If the permit is in relation to your research activities, please contact the Research Integrity and Ethics Unit in the first instance so we can discuss the situation and provide appropriate advice. You can also refer to the DFAT website for more information on permits. Sanctions permit applications are submitted through the Pax system on the DFAT website.
How can I request an indicative assessment?
If the assessment is related to a HDR or Visiting Research Student, contact the Dean of Graduate Research in the first instance for further advice. If the permit is in relation to your research activities, please contact the Research Integrity and Ethics Unit initially so we can discuss the situation and provide appropriate advice. It is possible to request an indicative assessment through the Pax system on the DFAT website.
How can I receive regular updates on Sanctions?
DFAT maintain a subscription mailing list for people interested in receiving updates to the on Australian sanctions law and the consolidated list.
You can also keep up to date with News on the DFAT website.
The Dean of Graduate Research can assist with queries regarding Sanctions and HDR candidates or Visiting Research Students.
The Research Integrity and Ethics Unit can assist with queries regarding Sanctions and your research.