Doing business in Australia? Then check the Consolidated List (AUCL).
Sanctions compliance

Doing business in Australia? Then check the Consolidated List (AUCL).

Trading with parties on relevant sanctions lists is prohibited. AUCL stands for the Consolidated List in Australia. Does it apply to you and if yes, what then?

What’s the Consolidated List in Australia (AUCL) about?

The Australian Consolidated List, or short AUCL, is a list of all persons and entities who are subject to targeted financial sanctions under Australian sanctions law. Listed parties can be Australian citizens, foreign nationals, residents in Australia or outside of it. This sanctions list is issued by the Australian Government’s Department of Foreign Affairs and Trade (DFAT). Australia’s targeted financial sanctions prohibit the following:

  1. Making assets available to (or for the benefit of) a designated person or entity – directly or indirectly.
  2. Using or dealing with “frozen assets”, i.e. assets that are owned or controlled by a designated person or entity.

Australia’s Consolidated List includes all persons and entities to which the Charter of the United Nations Act 1945 and the Autonomous Sanctions Act 2011 currently apply. This follows the transition of Australia's targeted financial sanctions from the Banking (Foreign Exchange) Regulations 1959 to the Autonomous Sanctions Regulations 2011. Australian sanctions laws implement both United Nations Security Council (UNSC) sanctions as well as Australian autonomous sanctions. 

The AUCL does not include persons or entities listed under other Australian laws, or the sanctions laws of other countries – so, depending on your activities, you may need to check and ensure compliance with other laws and global sanctions lists.

There is no leeway for compliance with targeted financial sanctions – it’s prohibited to supply any kind of asset to designated persons or entities. Non-compliance with the AUCL is a serious criminal offence and penalties include up to ten years in prison for individuals and significant fines for individuals and corporate bodies.

Who needs to check this Consolidated List?

Companies or organizations need to ensure not to do business with parties listed on the Consolidated List in Australia if: 

  1. They are incorporated under Australian law.
  2. They are subject to Australian law.
The second scenario may also include companies or organizations that are incorporated anywhere in the world but have a branch or subsidiary in Australia that engages in trade.

Some companies or organizations outside of these two scenarios may also be required to check the AUCL. For example, if their company-wide compliance programs or contractual obligations require them to do so.

If any of this applies to you, you need to check Australia’s Consolidated List before starting any kind of business activity to ensure you do not engage with designated persons or entities. This includes any business transaction from offer to delivery.

What to do if you check the AUCL and have a “match”?

The Australian government offers clear advice on their website for anyone who comes across a “match” – i.e. who finds a person or entity that they want to do business with on the Consolidated List:

  • Promptly stop your planned transaction and seek legal advice.

They also offer guidance if anyone is (or even think they might be) using or dealing with an asset that is owned or controlled by a person or entity on the AUCL:

  • Promptly hold the asset (known as “freezing an asset”) and inform the Australian Federal Police (AFP) as soon as possible. You will need to provide specific information about such assets in line with regulation 42 of the Charter of the United Nations Regulations 2008 and regulation 24 of the Autonomous Sanctions Regulations 2011.

The Australian Federal Police also provides assistance to asset holders if they are unsure whether or not an asset is owned or controlled by a person or entity on the Australian Consolidated List. You can complete an online form with as many details about the asset as possible and email it to the AFP. You can find more information directly on the DFAT website.

Automatically updated sanctions lists

AEB's Compliance Screening software runs automated business partner screening in the background of your transactions. Optional integration into your ERP/CRM systems such as SAP®, Salesforce, Microsoft Dynamics 365, and more. And with extended content from Dow Jones. 

What’s the best way to ensure compliance with this Consolidated List?

The scope of and entries on sanctions lists change frequently and dynamically. It’s therefore best to check against applicable sanctions lists, like the AUCL if it’s relevant for you, on every business transaction from offer to delivery. Based on the number of entries on sanctions lists, it would be highly cumbersome and very time-intensive to do such checks manually. The only way to efficiently screen against sanctions lists regularly is doing so with software.

AEB’s Compliance Screening software automatically runs sanctions list screening for you in the background of your transactions while your everyday business continues without interruptions. It offers a vast number of sanctions lists to choose from and you can use the software from anywhere in the world to secure your trade transactions. Sanctions list checks are done in real-time and updates by authorities are available automatically so you don’t need to worry and can trade with peace of mind.

Request online demo now