[co-author: Natasha Garthe]
Australia’s autonomous sanctions regime has continued to evolve over the past 12 months. Driven by ongoing geopolitical tensions, increased global coordination and a commitment to strengthening compliance frameworks, 2025 has seen the introduction of several new measures including an expansion of targeted measures in Russia, North Korea and Iran.
These developments reflect Australia’s deepening commitment to sanctions, including utilising its autonomous sanctions framework, as a foreign policy and national security tool, deployed in close coordination with the United States, United Kingdom, European Union and other key allies. For businesses operating internationally, sanctions compliance is no longer a peripheral operational consideration but a central governance obligation requiring robust systems, ongoing vigilance, and the flexibility to respond swiftly to legal change. Trade flows through the Asia Pacific region mean that Australian sanctions have salience across the region, even in jurisdictions where only UN sanctions are implemented.
This article outlines the key developments over the past 12 months and what may be expected in 2026.
Key updates in 2025
Australia continued to expand its sanctions footprint in 2025, particularly in response to the protracted conflicts in Ukraine and the situation in North Korea. The key sanctions developments in 2025 included:
Developments in 2026 and beyond
As we move into 2026, we expect ongoing developments to the Australian sanctions landscape, including as follows:
Further coordinated measures
We expect to see further sanctions measures implemented in response to the situations in Ukraine, Afghanistan, Iran and North Korea, in line with the US, UK and EU. This continued coordination is likely to be seen in respect of Russia’s war economy (including further designations of oil-shipping networks and evasion facilitators), emerging cyber threats including North Korea’s increasing use of cybercrime to fund weapons development and supply chains linked to Iran’s missile programs.
This trend was underscored by the Government’s announcement on 4 December 2025 of additional support for Ukraine, including a $95 million military assistance package, a $50 million contribution to NATO’s Prioritised Ukraine Requirements List, and $2 million to the Drone Capability Coalition. These contributions follow Australia’s ongoing contribution to multinational efforts to train Ukrainian military personnel in the UK under Operation Kudu and bring total assistance to more than $1.7 billion, reinforcing Australia’s status as the largest non-NATO contributor of military support.
This sustained commitment signals that sanctions, in conjunction with direct military aid, will continue to be used as complementary tools to constrain Russia’s war economy and uphold the global rules-based order. As such, 2026 is likely to see additional designations targeting oil-shipping networks, evasion facilitators and shadow-fleet vessels, as well as measures aimed at closing remaining gaps in supply chains supporting Russia’s military operations.
Regulatory expectations
Australian companies can expect to see regulators raise expectations around due diligence. Companies involved in exporting dual-use goods, high-risk technologies or industrial components can expect closer scrutiny of:
- end users and intermediary verification;
- dual-use exports and AHECC codes;
- contract-based mitigation (e.g. “no-Russia” contractual clauses);
- data driven screening systems particularly for financial institutions and governance frameworks.
- Corporate boards will be expected to treat sanctions risk as part of mainstream corporate governance.
Russian oil and substantially transformed products
Ongoing concerns about the importation of petroleum products refined from Russian crude in third countries, and the presence of Russia-origin oil across the Asia Pacific region, are likely to intensify in 2026. While Australia’s direct imports of Russian energy products have fallen from $80 million to zero, indirect imports via refining hubs in India, Turkey and Singapore have raised questions about the long-term effectiveness of existing prohibitions.
As international partners move to close this loophole, including the EU’s ban on third-country petroleum products derived from Russian crude commencing 21 January 2026, Australia may face pressure to more closely align with international partners and consider further regulatory intervention.
Afghanistan sanctions regime
In October 2025, DFAT closed a public consultation on proposed amendments to the Autonomous Sanctions Regulations 2011 to establish a dedicated autonomous sanctions regime for Afghanistan, Autonomous Sanctions Amendment (Afghanistan) Regulations 2025. The proposed changes would introduce new listing criteria specific to Afghanistan, including an arms embargo and prohibitions on the supply of arms-related material or services to designated individuals or entities, and enable targeted sanctions such as asset freezes and travel bans for persons responsible for serious human rights abuses, and the suppression of women and girls and minority groups. Should the regulations be introduced, Australian businesses operating globally will need to take account of these new compliance obligations.
Enforcement developments
Increased resourcing and rising international scrutiny on sanctions evasion networks point to heightened investigative activity. To that end, 2026 is likely to see additional investigations and prosecutions directed at sectors with recurring compliance weaknesses or heightened risks, particularly remittance providers, freight and logistics operators, and exporters of dual-use goods.
Chapters
- Corporate Crime 360: Your complete guide to APAC trends in 2026
- Australian sanctions: Navigating the waters of 2025 and charting the course for 2026 across the Asia Pacific
- Leveraging technology in internal investigations: The promise and potential of generative AI
- Modern slavery: Rising expectations and steady reform across Australia, APAC and beyond
- Foreign bribery risk: What happens when your agent pays a bribe overseas?
- Playing by new rules: AUSTRAC’s growing reach in 2026
- When insider risk becomes corporate risk: How corporations may be held liable for the fraud of others
- Whistleblower laws: developments and trends across Australia and the Asia Pacific
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