The instrument uses a small set of legal concepts and mechanisms, all operating by reference to the Autonomous Sanctions Regulations 2011.

• Designation and declaration: The instrument uses the terms "designated person" and "declared person." Section 4 states that each person mentioned in Schedule 1 is "designated as a designated person and declared as a declared person for Ukraine" for the purposes of regulation 6 of the Autonomous Sanctions Regulations 2011. The instrument does not define those terms within its own text; it relies on the definition and operative effect in the Regulations (section 4).

• Responsibility or complicity as criterion: Section 4 identifies the criterion applied. It declares that, for regulation 6, each listed person is "responsible for, or complicit in, the threat to the sovereignty and territorial integrity of Ukraine." That factual or legal finding, as expressed in the instrument, is the basis for the designation and declaration. The instrument records that finding; it does not include evidentiary material within its text.

• Schedule-based insertion and maintenance of the consolidated list: The instrument comprises a Schedule 1 that sets out the specific persons declared and designated; and Schedule 2 that amends the pre-existing Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014 by inserting corresponding items in Part 1. Section 5 explicitly states that Schedule 2 amends the 2014 list. The amendment is effected by adding entries after item 153 in Part 1: the new inserted entries are numbered 154-163 (Schedule 2, [1]).

• Ministerial instrument-making power under the Regulations: The instrument is made under subregulation 6(1) of the Autonomous Sanctions Regulations 2011 (section 3). The printed signature block shows it was made by the Minister for Foreign Affairs, Marise Payne, and dated 15 March 2019. The instrument therefore uses delegated rule‑making powers conferred by the Regulations to add or declare persons on the autonomous sanctions list.

• Identifying particulars included: The Schedules include particulars for each listed individual: full name, also-known-as (aka) entries where provided, date of birth, and some additional information such as place of birth for particular entries (Schedules 1 and 2). The Schedules thus supply the identifiers by which the instrument designates persons for the list.

These are the instrument's core mechanisms: it records findings of responsibility/complicity, declares and designates individuals under the Regulations, and amends the maintained list by inserting the entries. The instrument itself does not restate the operative prohibitions or penalties that attach to designated/declared status; it ties those statuses back to regulation 6 of the Regulations (sections 3-4), and amends the 2014 list which the Regulations use (section 5).

Directly: the ten named individuals listed in Schedule 1 are the primary objects of the measure. Schedule 1 lists the following persons with their particulars (as reproduced in the instrument):

• Sergey Nikolayevich Stankevich, born 27.1.1963 (Schedule 1; Schedule 2 item 154).
• Andrey Borisovich Shein, born 10.6.1971 (Schedule 1; Schedule 2 item 155).
• Oleksii Mykhailovych Saliaiev (aka Alekseii Mikhailovich Saliaiev), born 22.8.1978 (Schedule 1; Schedule 2 item 156).
• Andrii Shypitsyn (aka Andrei Shipitsin), born 25.12.1969 (Schedule 1; Schedule 2 item 157).
• Oleksii Volodymyrovych Shatokhin (aka Aleksey Vladimirovich Shatohyn), born 26.1.1971 (Schedule 1; Schedule 2 item 158).
• Ruslan Romashkin, born 15.6.1976 (Schedule 1; Schedule 2 item 159).
• Serhii Shcherbakov (aka Sergey Shcherbakov), born 2.11.1986 (Schedule 1; Schedule 2 item 160).
• Leonid Ivanovich Pasechnik (aka Leonid Ivanovych Pasichnyk), born 15.3.1970, place of birth recorded as Voroshilovgrad - Luhansk, Voroshilovghrad Oblast, Ukrainian SSR (Schedule 1; Schedule 2 item 161).
• Vladimir Anatolievich Bidyovka (aka Vladimir Anatolievich Bidevka; Volodymyr Anatoliyovych Bidiovka), born 7.3.1981, additional information noting Makeevka - Donetsk Oblast (Schedule 1; Schedule 2 item 162).
• Denis Nikolaevich Miroshnichenko, born 8.12.1987, additional information noting place of birth: Luhansk (Schedule 1; Schedule 2 item 163).

The instrument explicitly states that each listed person is "designated as a designated person and declared as a declared person for Ukraine" for regulation 6 purposes (section 4). Those statuses are the immediate legal characterisations applied to the named persons by the instrument.

Indirectly and consequentially: the instrument amends the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014 by adding these entries into Part 1 after item 153 (section 5; Schedule 2). Entities and persons who rely on or reference that maintained list for compliance purposes therefore have a duty to treat the list as carrying these additional entries from the instrument's effective date. The instrument itself does not catalogue the full set of third parties affected by those list entries; however, by amending the 2014 list (section 5 and Schedule 2) it alters the authoritative consolidated list that intermediaries, financial institutions, legal advisers, government agencies and businesses routinely consult for sanctions screening.

Who decides: the instrument was made by the Minister for Foreign Affairs under the delegated authority in the Regulations (section 3; instrument header). The act of designation and declaration is therefore an executive decision effected by instrument, not an administrative determination recorded elsewhere.

Temporal effect and operational start: the instrument commences the day after registration (section 2). That means the Schedules and the amendment to the 2014 list take legal effect from that commencement date. The instrument gives no transitional carve-outs or phase-in periods within its text.

Scope limitation: the instrument confines its operation to persons listed in Schedule 1 and the specific insertion into the 2014 list as set out in Schedule 2. There are no corporate entities listed in this instrument; all entries are individuals (Schedules 1 and 2).

The instrument itself records declaratory and list-amendment actions; it does not set out affirmative duties, prohibitions or rights within its own text. The key legal consequences are framed by reference to the Autonomous Sanctions Regulations 2011 and the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014, which this instrument amends. The instrument therefore functions as a mechanism to alter who is on the maintained list and to record, for regulation 6 purposes, that particular persons are "responsible for, or complicit in, the threat to the sovereignty and territorial integrity of Ukraine" (section 4). The concrete legal rights and duties that attach to being a "designated person" or a "declared person" are located in the Regulations and in the consolidated list that the Regulations use; this instrument refers to those instruments rather than restating their content (sections 3-5).

Duties that will be relevant in practice, implied by the instrument's function and based on its references, include the following, each grounded in the instrument's mechanism rather than stated as text within it:

• Obligations of identifying authorities and regulated entities to update compliance systems: because the instrument inserts the listed individuals into the 2014 list (section 5; Schedule 2), entities that use that list to screen customers, counterparties or payment instructions will need to update their screening files to reflect the new entries. The instrument itself does not specify who must perform those updates; it amends the authoritative list that those entities rely on.

• Duties of government agencies to treat the listed persons as designated/declared for regulation 6 purposes: section 4 explicitly directs that, for regulation 6, these persons are to be treated as responsible or complicit and designated/declared. Agencies applying regulation 6 will therefore, by virtue of this instrument, treat those persons accordingly.

• Rights of the listed persons: the instrument does not create or describe procedural rights, review mechanisms, notice obligations or merits review within its text. It records a factual/legal finding and effects a list amendment. Any procedural or review rights that exist to challenge designation or seek delisting must be located in the Regulations or other applicable instruments; they are not contained in this instrument.

• No standalone exemptions or licences in this instrument: the instrument does not supply exemptions, licences, or carve-outs that would permit transactions with the listed individuals. All operational permissions or licences would need to be sought under the Regulations (the instrument is silent on any such regime).

Because the instrument operates by reference to regulation 6, readers must consult the Autonomous Sanctions Regulations 2011 and the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014 (as amended) to determine the specific duties, prohibitions, enforcement powers, and rights that will affect the listed persons and third parties. The instrument does not itself purport to set penalties, prohibitions or remedial schemes; it creates and records the status that triggers such consequences under the regime established by the Regulations (sections 3-5).

This instrument does not itself specify penalties, enforcement mechanisms, or investigative procedures. Its operative text declares persons to be designated and declared for the purposes of regulation 6 of the Autonomous Sanctions Regulations 2011, and it amends the maintained 2014 list (sections 3-5). The instrument therefore functions as the vehicle by which particular persons acquire the statuses that, under the Regulations, lead to legal consequences; the particular penalties and enforcement mechanisms must be located in the Regulations and in any other statutes or delegated instruments that implement the sanctions regime.

What the instrument does specify about enforcement architecture is limited and procedural:

• Source of authority: the instrument is made under subregulation 6(1) of the Autonomous Sanctions Regulations 2011 (section 3). That identifies the regulatory power used to record the designations and declarations. The instrument itself does not recite the text of subregulation 6(1) or any enforcement provisions; it simply uses that delegated power.

• Operative effect for regulation 6: section 4 expressly frames the entries as effective "for regulation 6 of the Autonomous Sanctions Regulations 2011." That is the textual hook that ties these names to whatever enforcement tools, civil or criminal penalties, and licensing schemes regulation 6 and related provisions of the Regulations provide. The instrument preserves enforcement authority to the extent the Regulations confer it; the instrument does not expand or limit those powers within its own text.

• Amendment of the consolidated list: section 5 and Schedule 2 insert the entries into Part 1 of Schedule 1 of the 2014 list (after item 153). That insertion is the administrative step that makes the list used by enforcing agencies and regulated parties current with these designations.

Because the instrument contains no penalties itself, practitioners and compliance officers must refer to the Autonomous Sanctions Regulations 2011 and the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014 for the detailed enforcement consequences. This instrument establishes who is on the list and when that addition takes effect (commencement is the day after registration, section 2). Any criminalisation, civil remedy, asset freeze, travel restriction, licensing requirement or exceptions that apply to designated and declared persons will be found in the Regulations and in any administrative guidance those instruments produce; they are not restated here.

If an affected party requires clarity on enforcement steps, remedies, penalties, or enforcement actor powers, the instrument makes two procedural pointers clear: first, the legal power relied on is subregulation 6(1) of the Regulations (section 3); second, the status imposed is to be applied for the purposes of regulation 6 (section 4). The instrument itself contains no enforcement schedule, no civil or criminal penalty clauses, and no procedural timetables for review or appeal.

The instrument expressly interacts with two existing instruments referenced by name and by regulatory cross‑reference in its text:

• Autonomous Sanctions Regulations 2011: The instrument is made under subregulation 6(1) of the Autonomous Sanctions Regulations 2011 (section 3) and operates "for regulation 6" of those Regulations (section 4). Accordingly, this instrument is a delegated measure that alters the set of persons to which the Rules in regulation 6 apply. The instrument relies on the Regulations to provide the operative regime that attaches consequences to the statuses it records. It does not restate or modify the Regulations themselves; it exercises a power vested by subregulation 6(1).

• Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014: Section 5 states that Schedule 2 amends the 2014 list. Schedule 2 gives the mechanics of that amendment by inserting new items into Part 1 after item 153 (Schedule 2, [1]). In other words, this instrument updates the maintained list that sits alongside the Regulations as the operative catalogue of designated or declared persons relevant to the Ukraine-related autonomous sanctions regime.

Beyond those explicit cross-references the instrument does not name any other statutes, regulations or international instruments. The instrument does not purport to modify the text of the Regulations themselves, nor does it create any new statutory powers beyond the delegated authority exercised under subregulation 6(1) (section 3).

By amending the 2014 list, the instrument modifies the authoritative list that other domestic laws, licences, or compliance frameworks may reference. Entities that rely on the 2014 list to implement obligations under other laws or internal policies will need to incorporate this change into their operational controls. The instrument does not state whether the updated 2014 list overrides or supplements any other lists; it is, however, itself the amending instrument for the 2014 list and therefore becomes part of the chain of documents that define who is a designated/declared person under the domestic autonomous sanctions framework.

This instrument does not itself create cross-border obligations, treaties, or refer to foreign law. Its interaction is internal to the Australian autonomous sanctions regime as implemented through the Regulations and the maintained 2014 list.

The instrument records its own creation, date and procedural linkage to the pre-existing list. Relevant points in the instrument concerning amendment history are:

• Date and maker: The instrument bears the printed date 15 March 2019 and is made by Marise Payne, Minister for Foreign Affairs (instrument header and signature block). That identifies the authorising decision-maker and the date the instrument was produced.

• Commencement: The instrument commences on the day after it is registered (section 2). The instrument does not include the registration date within the body beyond the commencement clause; the commencement rule identifies when the declared/designated statuses and the list amendments become effective.

• Legal authority for amendment: The instrument is made under subregulation 6(1) of the Autonomous Sanctions Regulations 2011 (section 3). The amendment power is therefore provided by the Regulations; this instrument exercises that power by amending the 2014 list.

• What the amendment does: Section 5 declares that Schedule 2 amends the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014. Schedule 2 specifies that, in Part 1 of that 2014 list, after item 153 the instrument inserts items numbered 154 through 163 which correspond to the persons listed in Schedule 1 of this instrument (Schedule 2, [1]).

• Redundancy between Schedules: The instrument both lists the persons in Schedule 1 (thereby declaring them to "have effect" for regulation 6) and separately includes a Schedule 2 that inserts identical entries into the maintained 2014 list as new items. The Schedule 1 listing and Schedule 2 insertion are therefore two administrative steps: the instrument records the new designations and implements them in the maintained list.

• No prior amendments recorded in the instrument: This instrument does not recount prior amendment steps to the 2014 list except to identify where the freshly inserted items will be placed (after item 153). There is no internal history of earlier insertions, removals, or re-numbering provided in this instrument.

• Scope of inserted entries: Schedule 2 itemises each individual entry with name variants and particulars identical to those in Schedule 1. Items 154-163 are each specified by name, aliases where provided, date of birth and additional particulars such as place of birth where present (Schedule 2).

That is the full amendment history contained in the instrument itself: the instrument was made on 15 March 2019, commences the day after registration (section 2), is made under subregulation 6(1) (section 3), declares persons to be designated and declared for regulation 6 purposes (section 4), and effects entries inserted into the 2014 list as items 154-163 (section 5; Schedule 2).

The instrument contains no record of litigation, judicial review, or legal challenges. There are no references within the text to any court decisions, ongoing proceedings, or administrative appeals related to these entries. The instrument simply records the Ministerial decision to designate and declare the listed individuals and to insert corresponding entries into the 2014 list (sections 3-5; Schedules 1 and 2).

Because the instrument does not itself describe any review or appeal mechanisms, it does not supply procedural detail about how a listed person might challenge a designation. Any litigation or review rights that exist will depend on the procedures, remedies and judicial review pathways established by the Autonomous Sanctions Regulations 2011, the enabling statute and the general law, none of which are restated in this instrument. The instrument therefore contains no litigation record or history relevant to the entries it creates.

Practitioners seeking to know whether any of these particular entries have been subject to litigation will need to consult external sources or case law databases; that information is not contained in this instrument.

The instrument is short and mechanically focused, but it contains several practical features and traps for operators that arise directly from its wording and structure. Each of these is grounded in the instrument text.

• Dual action: declaration and list amendment. The instrument both declares the persons to "have effect" for regulation 6 (section 4; Schedule 1) and inserts them into the 2014 list (section 5; Schedule 2). The duplication means that there are two places where these names are manifested in the instrument. Compliance processes should ensure both the immediate Schedule 1 entries and the amended 2014 list are captured, because practitioners often rely on the consolidated list in the 2014 instrument rather than isolated amending instruments.

• Commencement is the day after registration. The instrument commences the day after registration (section 2). That can be a tight operational window for banks and other regulated entities that update screening lists on fixed cycles. The "day after registration" rule means the effective date is not the date the instrument was signed (15 March 2019) but the day after registration; however the actual registration date is not printed in the instrument text. Parties that need to know the exact point at which obligations arise must check the instrument's registration metadata in the register or Federal Register to determine the operative day.

• Reliance on external text for operative consequences. The instrument does not state the specific prohibitions, licensing regimes, or penalties that attach to being a designated or declared person. Section 4 ties the declaration to regulation 6 of the Autonomous Sanctions Regulations 2011, and section 5 amends the 2014 list. Practitioners cannot determine, from this instrument alone, which acts are prohibited or whether exceptions apply; they must consult the Regulations and the consolidated 2014 list. Treating this instrument as self-contained would be a mistake.

• Name variants and transliteration differences. Several entries include alternative names (aka) and transliteration variants (Schedules 1 and 2, e.g. Oleksii/Alekseii; Andrii/Andrei; Vladimir/Volodymyr). Compliance systems that rely on exact-match searching may miss these variants. The instrument provides alias fields for some entries but not all. For example, Sergey Nikolayevich Stankevich and Andrey Borisovich Shein have no aka fields recorded in the Schedule tables, yet adjacent entries include variants. Operators must capture all name variants listed and consider transliteration permutations when conducting screening.

• Partial identifying particulars. Some entries include place of birth information (e.g. Leonid Pasechnik, Vladimir Bidyovka, Denis Miroshnichenko) while others do not. Dates of birth are present for every entry, but other identifiers such as passport numbers, national identity numbers or addresses are absent. Where entities rely on unique identifiers other than name and date of birth for matching, those identifiers are not supplied here. The available particulars are limited to name, aka (where provided), date of birth and occasional place of birth (Schedules 1 and 2).

• Duplicate numbering and table positioning. Schedule 2 inserts new items after item 153 in Part 1 of the 2014 list and assigns numbers 154-163. If the 2014 list has since been amended by other instruments, numbering may have shifted. Practitioners should use the instrument's text to verify that these items were intended as immediate insertions after item 153 in the 2014 list as constituted at the time of amendment, but confirm the present numbering and text in the latest consolidated source.

• No procedural detail for delisting or review in this instrument. The instrument is silent on review processes. If a listed individual seeks delisting, the instrument contains no procedural map within its text. Any such process will depend on the Regulations or other administrative procedures outside the instrument.

• Limited geographic scope as expressed. Section 4 frames these persons as "designated and declared for Ukraine" and as "responsible for, or complicit in, the threat to the sovereignty and territorial integrity of Ukraine." The instrument does not make these designations for other contexts. Entities that apply multiple sanctions lists must ensure they apply the designation in the correct legal context (that is, under the Ukraine autonomous sanctions sheet of the domestic regime).

Those are the principal operational pitfalls and practical considerations the instrument itself reveals. Each arises from textual features in sections 2-5 and the Schedules.

This instrument is an amendment and record of designation; compliance therefore requires treating the named persons as designated and declared for the purposes of regulation 6 of the Autonomous Sanctions Regulations 2011 and ensuring that any operational systems referencing the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014 incorporate the Schedule 2 insertions. The instrument provides the following concrete compliance-relevant facts and steps, grounded in its text:

1. Confirm effective date: The instrument commences the day after registration (section 2). To know precisely when the entries became effective, check the registration date in the relevant register (the instrument text gives the signing date but commencement is tied to registration). Compliance obligations triggered by listing begin on that commencement day (section 2). Do not assume the date in the signature block is the operative commencement; rely on the registration date.

2. Update authoritative lists: Section 5 and Schedule 2 specify that items are to be added to Part 1 of the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014 (section 5; Schedule 2). Practically, organisations should update their authoritative sanctions screening databases to include the new items 154-163 or the corresponding entries as they appear in the consolidated 2014 list, and capture the same name variants, dates of birth and place-of-birth information provided in the Schedules. Failure to update the consolidated list risks missing matches during automated screenings.

3. Capture alias and transliteration variants: Several entries include aka fields and alternative spellings (Schedules 1 and 2). Capture those alias forms in screening systems, and where only limited variants are provided, consider adding likely transliteration permutations to reduce false negatives. The instrument itself supplies specific aliases for some individuals, which should be used verbatim in screening profiles.

4. Treat the listed persons as designated/declared for regulation 6 purposes: Section 4 expressly states that, for regulation 6, each person mentioned in Schedule 1 is responsible for, or complicit in, the threat to the sovereignty and territorial integrity of Ukraine and is designated and declared accordingly. Agencies applying regulation 6 and entities acting under licenses or exemptions in the Regulations should therefore apply any relevant obligations or prohibitions to these persons from the effective date.

5. Check the Autonomous Sanctions Regulations 2011 and the 2014 list for operative prohibitions and licensing regimes: This instrument does not state what transactions are prohibited, whether asset freezes, travel restrictions, or other measures apply, or whether exemptions and licensing paths exist. Section 3 identifies subregulation 6(1) as the authority; section 4 ties the designations to regulation 6. To determine concrete legal obligations, consult the text of the Autonomous Sanctions Regulations 2011 (including regulation 6 and any related provisions) and the consolidated 2014 list as amended. The instrument amends that 2014 list, but the Regulations contain the operative prohibitions and enforcement mechanics.

6. Record-keeping and audit trails: Because this instrument both declares and amends the consolidated list (sections 4-5; Schedules 1 and 2), compliance departments should retain a copy of the instrument (signed and registered) and document the date on which internal systems were updated. The instrument's signature block records the maker and the date of signature; the commencement clause ties effect to registration (sections 2-3). Keep a record of when the internal update occurred relative to the instrument's commencement to demonstrate timely compliance.

7. Use the precise identifying particulars supplied: The Schedules provide dates of birth for all entries and place-of-birth information for some entries (Schedules 1 and 2). Use these particulars to reduce false positives in screening and to verify matches with greater confidence. Do not assume additional identifiers beyond those supplied are authoritative unless corroborated elsewhere.

8. If necessary, seek clarification from the competent authority: The instrument does not detail enforcement, penalties, or review rights. If an organisation faces uncertainty about whether a particular activity is permitted, or how to process a match (for example to proceed with a blocked payment, apply for a licence, or freeze an asset), the instrument’s text points back to the Regulations for operative rules (sections 3-5). Practitioners should therefore consult the Regulations and, if ambiguity remains, direct inquiries to the government agency responsible for sanctions administration.

9. Be alert to numbering and consolidation variations: The instrument inserts items after item 153 in Part 1 of the 2014 list (Schedule 2, [1]). If your compliance system relies on static item numbers, verify the current consolidated list in official sources, because subsequent instruments may have renumbered or further amended items. The instrument’s own insertion points are precise only relative to the 2014 list as it stood at that moment.

10. Treat the instrument as a formal legal source for screening and enforcement: The instrument is an official legislative instrument made under the Regulations and is therefore an authoritative source for the addition of the named persons to the sanctions list. Use the instrument text (sections 2-5; Schedules 1 and 2) as the basis for updating internal policy, drafts of restricted-counterparty lists, and legal analyses. Do not rely on summaries or tertiary databases without cross-checking them against the instrument and the consolidated 2014 list.

These practical steps are the direct compliance actions that flow from the instrument’s textual provisions. The instrument does not itself give permission, exemptions, or procedure for transactions with listed persons; compliance is therefore about identifying matches, escalating to the correct internal or governmental authority, and consulting the Autonomous Sanctions Regulations 2011 and the consolidated 2014 list for the substantive legal consequences.