Sanctions & Research Engagement

July 2026 Update

University Guidance: Collaboration with Iran, Russia, Belarus and North Korea

Research Governance and Services: Fortnightly Global engagement compliance Q&A sessions will start on Tue 30th of June.

 

International research engagement compliance

All research engagements must be assessed for foreign risk considerations and compliance with relevant legal, regulatory, and ANU policy requirements:

Australian Sanctions

Australian sanctions laws impose restrictions on activities with certain countries.  The ANU is breaching the law if it provides specified goods or services to named countries or provides or deals with assets to named individuals or entities.  If the activity cannot be conducted with an alternative partner, it may be possible to apply for a permit. Violating sanctions laws can result in severe individual and institutional criminal penalties.

Australian sanctions laws implement United Nations Security Council sanctions regimes and Australian Autonomous Sanctions frameworks. 

Countries under Sanctions Restrictions

Countries under current sanctions frameworks implemented under Australian sanction laws
AfghanistanIran**South Sudan
Belarus*IraqSudan
Central African RepublicLebanonSyria
Democratic Republic of the CongoLibyaUkraine
DPRK (North Korea)**MyanmarYemen
Guinea-BissauRussia**Former Federal Republic of Yugoslavia
HaitiSomaliaZimbabwe
* No specific sanctions regime under foreign policy.
** Foreign policy extends the sanctions restrictions for these countries. More information here.

Please note:

  • If you receive funding from another country, you will need to check their sanction requirements. Each sanctions regime has specific prohibited activities. For detailed information on the sanctions measures under each Australian sanctions regime, please refer to the relevant sanctions framework.

Australian Sanctions Office (ASO) provides a sanctions framework for each country subject to Australian sanctions. A sanctions framework outlines the activities that are prohibited in relation to that country, as well as any individuals and entities listed under the framework in the Consolidated List. The relevant sanctions framework are identified in the “Committee” column of the Consolidated List. Please note that an individual’s country of birth may differ from the sanctions framework under which they are listed.

The ASO maintains and regularly updates the Consolidated List. You can subscribe to the email list to receive updates to the list.

In some circumstances, it may be possible to obtain a sanctions permit from the Minister for Foreign Affairs to engage in an activity that would otherwise be prohibited by a sanctions measure. Different sanctions frameworks impose different criteria for the grant of a permit. 

The University is required by law to keep records of the sanctions permits. Please, inform the ANU Research Compliance Office when you submit a sanctions permit application when wishing to engage with sanctioned individuals or entities. Please contact us (sanction.ris@anu.edu.au) for more information.

Due diligence requirements for Individuals

Individuals are responsible for undertaking due diligence checks to understand whether:

  • any of the individuals or entities they are engaging with are on the consolidated list. 
  • any of the individuals or entities they are engaging with have links to the individuals or entities on the consolidated list.
  • activity they are engaging with foreign partner is prohibited under the sanctions frame works.
  • documenting outcomes of the risk assessments despite the outcome.

Note:Research involving topics listed in the Defence and Strategic Goods List may be subject to arms embargo sanctions and other restrictions under Australian sanctions laws, even where the research is considered as fundamental research.

Due diligence requirements for the ANU

The University is responsible for

  • making sure there are guidelines in place appropriate to the risk levels related to the research subject matters and international engagements in the college. 
  • ensuring that an appropriate documentation is created and maintained and reporting provided to the ANU Research Compliance Office. 
  • providing information and training to the staff and students appropriate to their position.
  • keeping records of all the sanctions permits and controls required.

Sanctions measures may impact a range of activities including:

  • enrolling an undergraduate or higher degree by research (HDR) student from a sanctioned country with remaining links to the country (contact Research Training for more information).
  • employing a person from a sanctioned country.
  • collaborating with another person or entity with links to a sanctioned country, individual or entity.
  • supplying/importing of certain goods to/from sanctioned countries.
  • provisioning/receiving of certain services to/from sanctioned countries
    • Training
    • Supervision
    • Consultancy
  • provisioning/receiving of assets (benefits) to/from designated persons and entities
    • Equipment
    • Funding
    • Data
    • Intellectual Property
  • dealing in the assets of a designated persons or entity.
  • travel bans on certain individuals.

What to do

Document the risk assessment despite the outcome.

Australian sanctions frameworks

  1. Check the list of countries under sanctions frameworks:
    1. Check if your partner is at the Consolidated list (individuals or entities).
    2. If yes, assess if the activity with the sanctioned partner is prohibited from the sanctions framework :
      1. ASO provides a risk assessment document.
      2. If unsure ask for help (see information resources).
    3. If activity is sanctioned:
      1. Don’t proceed with the activity with the partner.
      2. Ask for guidance (ANU Legal Office, ANU Research Compliance Office, ASO).
      3. Apply for a sanctions permit.
      4. Need to justify how the activity is beneficial for the National Interest.

If you are collaborating with a partner located in a country that is under Australian sanctions, you are required to make a risk management plan that needs to be reviewed yearly. 

 

Updated August 2026

Reference documents

Policies

Related links

Contact

  • Foreign Interference & Arrangements contact
  • Send email

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