Sanctions assessments

The University has a responsibility to ensure all its activities comply with Australian sanctions law. Processes related to recruitment of staff (including visiting and honorary appointments) and enrolment of higher degree research students with a connection to a sanctioned country are governed by UQ’s Policy and Procedures Library (PPL) Export Controls and Sanctions Regimes Procedure. Information on this website should be read together with the procedure.

Types of sanctions assessments

The type of assessment required will depend on the applicable sanctions regime. Many sanctions regimes only require a check of DFAT’s Consolidated List while other sanctions regimes require both a list check and an assessment of the proposed activity to determine if the activity is prohibited under sanctions law.

DFAT Consolidated List checks

A check of DFAT’s Consolidated List is conducted to:

determine if any individuals or entities are ‘designated’, in which case it is prohibited to provide an asset to, or deal with the asset of, the individual or entity, and
determine if any individuals are subject to a ‘travel ban’, in which case the individual is unable to travel to Australia.

DFAT list checks are conducted by:

International Safeguards for staff candidates and certain research collaborations,
the Graduate School for higher degree by research students, and
International Admissions for coursework students.

However, it is possible for anyone to view the consolidated list. Researchers are encouraged to check the list when considering any collaboration with an individual or entity from or based in a sanctioned country. The consolidated list is publicly available on DFAT’s website.

Activities assessments

Activities assessments are conducted to determine if an individual with a connection to a sanctioned country can undertake a given activity. This usually involves two steps:

determining if the research, teaching or other activity involves any sanctioned goods or services, and
if it does, determining whether the involvement of the individual with those goods or services may breach Australian sanctions law.

Step 1 is undertaken by the person with the best understanding of the activity, usually the individual’s immediate supervisor. Step 2 is undertaken by International Safeguards (for staff) or the Graduate School (for HDR students).

For more information on the roles of staff involved with activities assessments, see the 'sanctions assessments role guide' on the forms and guides page.

Types of sanctioned goods and services

The types of goods and services that are sanctioned will depend on the on the applicable sanctions regime.

Many sanctions regimes include restrictions or prohibitions related to arms or related materiel, which are sometimes referred to as arms embargoes.

Several sanctions regimes – Iran, Russia, Syria, Iraq, North Korea and Ukraine Regions – also include restrictions or prohibitions on other non-military goods and services.

Arms or related materiel

There is no exhaustive definition of arms or related materiel in Australia sanctions law and determining whether an activity involves arms or related materiel can be a complex process.

Items specifically designed for military use are considered arms or related material. However, ‘dual-use’ goods, those that are designed for commercial use but that may also have a military application, are also considered arms or related materiel.

If you are required to determine whether an activity involves arms or related materiel, it is recommended that you read the ‘arms or related materiel assessment guide’ on the forms and guides page.

Other sanctioned goods and services

The types of other (non-military) goods and services that are sanctioned varies widely and are specific to the objectives of the applicable sanctions regime.

See the 'summary of Australian sanctions table' on the forms and guides page for an overview of the different goods and services that are sanctioned.

Determining whether an activity involves one of these other sanctioned goods or services will generally require interrogation of relevant regulations and/or legislative instruments. For more information, see the 'sanctions assessment role guide' on the forms and guides page.