Curtin University employees and students engaging in activities with international collaborators should be aware that various sanctions may affect those activities. Sanctions 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 to, or transit through Australia by specified persons.

Sanctions Compliance

There are two lists of sanctions implemented under Australian law:

• Unilateral Australian Autonomous Sanctions; and
• United Nations Security Council (UNSC) Sanctions

In addition to Australian and UNSC sanctions regimes, Curtin University is required to consider a range of international sanctions due to a variety of contractual and regulatory mechanisms. These additional sanctions regimes include:

• DFAT terrorist organisations
• OFAC Sanctions List
• UK Sanctions list
• EU Sanctions list
• Japan End User List
• Swiss Sanctions
• World Bank Listing of Ineligible Firms and Individuals

Sanctions compliance is everyone’s responsibility. Whilst Curtin conducts due dilligence with specific reference to Australian and United Nations sanctions, non-Australian and dual citizens should be aware that the sanctions regimes of their own countries of citizenship may still apply to them while in Australia (extraterritorial sanctions).

Assessing the Risks

Whether an activity constitutes a sanctions contravention depends on the specific circumstances. Each sanctions framework is unique, so it is crucial to reference the relevant sanctions laws for the specific sanctioned country when conducting an assessment.

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.

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 employees planning to participate in:

1. Collaborative projects, exchanges or conferences involving international universities, entities or governments ; or the
2. 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.

Sanctions Permits

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.

Contact us

For more information on sanction compliance at Curtin University, including advice on applying for a sanctions permit, please contact foreign.arrangements@curtin.edu.au