Australia Publishes Sanctions Compliance Assessment Tool
The Australian Sanctions Office recently published a risk assessment tool to help companies evaluate the “sanctions risks” of a transaction or other activity, including whether the company should investigate further, obtain legal advice, apply for a license or abandon the deal. The tool covers activities with sanctioned parties, deals involving export- or import-controlled goods, the provision of sanctioned services and more.
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The office also urged businesses to “implement a system to monitor changes in sanctions regulations, including updates” to the country’s sanctions lists. Although companies can apply for a “sanctions permit,” Australia said it “advocates for proactive risk management rather than relying on permits. Sanctions permits are generally appropriate only when there is a clear likelihood of a sanctions contravention occurring. For broad or non-specific sanctions risks, it is better to manage compliance through reasonable precautions and due diligence to prevent issues before they arise.”