Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Ukraine) Amendment List 2017

The instrument deploys a small cluster of statutory concepts drawn directly from the Autonomous Sanctions Regulations 2011. The instrument uses and updates the administrative "designation" and "declaration" mechanisms, and it relies on the definition of responsibility for or complicity in the "threat to the sovereignty and territorial integrity of Ukraine" as the threshold for listing.

Key concepts as used in the instrument are:

• Designated person and designated entity , the instrument expressly declares individuals and entities to be "designated" for Ukraine. Clause 6(1) invokes paragraph 6(1)(a) of the Regulations to make persons designated persons for Ukraine. Clause 5 extends designations that already existed in the 2014 List by declaring they continue to have effect under subregulation 9(3).
• Declared person , clause 6(2) cites paragraph 6(1)(b) of the Regulations and declares the listed persons to be "declared persons for Ukraine". Clause 4 likewise declares that prior declarations continue.
• Continuing effect and renewal , the instrument invokes subregulation 9(3) to continue earlier designations and declarations, which the instrument understands to be subject to the three-year expiry rule set out in subregulations 9(1) and 9(2). The note to clause 8 reproduces the three-year renewal mechanism: designations and declarations lapse on the third anniversary unless renewed by declaration under subreg 9(3), or else the third anniversary of the most recent declaration.
• Revocation , clause 7 uses subregulation 10(1) to revoke listed designations and declarations, thereby removing named persons from the list where so specified in Schedule 4.
• Amendment by substitution , Schedule 5 operates to repeal and replace Schedule 1 of the 2014 List, effecting a comprehensive update to the designated persons, designated entities and declared persons recorded in that schedule. The instrument achieves this by direct substitution rather than incremental edits.

Operationally, the instrument supplies identifying information for listed persons and entities: full names, dates of birth (where known), alternative names or aliases in some cases, addresses for corporate entities, and brief "additional information" or "listing information" describing the role or conduct said to justify listing. That material forms part of the public record that will be relied on by affected third parties and compliance systems to identify listed persons and entities.

The instrument does not itself restate the prohibitions or penalty provisions that attach to listings under the Regulations. It neither creates new sanctions measures on its own nor changes the substantive scope of prohibitions under the Regulations; rather it updates the list to which those measures apply.

The primary, direct subjects of this instrument are the named natural persons and corporate and quasi-governmental entities set out in the instrument’s Schedules. The instrument lists dozens of individuals and entities across Schedules 1, 2 and 3, and it revokes listings for three named individuals in Schedule 4. Those named include senior Russian political and security figures, military commanders, regional appointees in Crimea and eastern Ukraine, banks and commercial groups, and a range of organisations described as separatist or appropriated enterprises in Crimea and Donbas. The instrument also replaces Schedule 1 of the 2014 List with an updated Schedule via Schedule 5.

Who pays, in practical terms, is the broader population of persons and organisations that interact with the named individuals and entities. Although the instrument itself does not recite the specific prohibitions that flow from designation and declaration, the legal effect under the Autonomous Sanctions Regulations 2011 is to attach sanctions consequences to the persons and entities on the List. In most administrative sanctions regimes, listing generates compliance obligations and transaction restrictions for third parties. Those third parties include:

• Financial institutions and their compliance units, who will need to update screening lists to reflect new or continuing designations for banks and persons, using the names, aliases, dates of birth and addresses provided in the Schedules.
• Australian businesses and trustees, accountants, lawyers and agents dealing with clients that have cross-border exposures or dealings with persons or entities named in the Schedules, who must check whether counter-parties or beneficial owners appear on the updated list.
• Importers and exporters, or service providers with connections to Crimea and the Donbas or to the specific corporate entities listed, who will need to determine whether business activities implicate designated entities.
• Individuals named in the Schedules and their legal representatives, who are directly affected by the administrative act of listing and by any downstream operational measures applied by third parties.
• Government agencies and procurement officials, where the presence of listed persons or entities may affect contracting, grants, or licence applications.

The instrument’s Schedule entries also list addresses and alternative names for entities, which broadens the identification chain for screening. In a few entries there are multiple administrative roles attributed to the same person, for example indicating both present and past offices. The instrument revokes three prior designations in Schedule 4, which will directly affect any third party that had previously blocked or refused dealings solely on the basis of those now-revoked entries.

The Minister for Foreign Affairs is the decision-maker who made the instrument, indicating executive responsibility for the update. The instrument itself does not create any new rights of appeal or review for listed persons, nor does it set out an internal government process for reconsideration beyond the existing Regulations’ powers to revoke or renew, as referenced in clauses 3, 6 and 7.

Finally, the instrument affects record‑keeping and systems costs. Because the instrument replaces the 2014 List’s Schedule 1 and lists many names and entities, organisations that maintain sanctions‑screening systems must ingest the new Schedule 1 as substituted by Schedule 5, and also reconcile continued, new and revoked entries across the Schedules to avoid false positives or negatives.

The instrument itself does not enumerate duties or rights in prescriptive, labelled form. It is an order‑making instrument that exercises statutory powers under the Autonomous Sanctions Regulations 2011 to maintain and update the operative sanctions list. Nonetheless, the instrument’s form and citations identify the governmental duties and the legal mechanics that create obligations or consequences for others.

Who decides

• The instrument is made by the Minister for Foreign Affairs, Julie Bishop, as recorded at the head of the instrument, and clause 3 states that it is made under subregulations 6(1), 9(3) and 10(1) of the Regulations. That establishes executive decision-making at ministerial level for listing, renewal and revocation.

Primary operational duties flowing from the instrument

• To continue a designation or declaration: clause 4 and clause 5 declare that particular prior designations and declarations continue to have effect under subregulation 9(3). The operational duty of the executive is therefore to publish and maintain the continuity of the listed status for those persons and entities in the 2014 List’s Schedule 1, as specified in this instrument’s Schedules 1 and 2.
• To designate and declare new persons: clause 6 designates persons listed in Schedule 3 as both designated and declared persons. This creates the administrative status that triggers the operative sanctions in the Regulations for those individuals.
• To revoke: clause 7 revokes the designations and declarations for the named persons in Schedule 4, thereby removing their listed status.

Legal rights of listed persons

• The instrument does not state procedural rights available to listed persons, such as review, representations, or compensation. It does not create or alter statutory rights in the text. Any such rights, or routes to challenge, would exist, if at all, under the broader administrative law framework and the Autonomous Sanctions Regulations 2011, which the instrument references but does not reproduce.

Compliance duties for third parties

• The instrument imposes the practical duty to update sanctions screening data sets and to act in accordance with the sanctions regime established by the Regulations. The instrument does not re-state what those actions are. Instead, by declaring the continued effect or making new designations, it places listed persons within the scope of the Regulations, and the legal consequences of that status are realised through the Regulations’ operative prohibitions, exemptions and enforcement provisions.

Temporal duty

• The instrument commences the day after registration (clause 2). The note following clause 8 highlights a temporal rule in the Regulations, namely that designations and declarations lapse on the third anniversary unless renewed under subregulation 9(3). Practically, responsible agencies must track these renewal and expiry cycles.

Identification duties

• The Schedules include transliterations, aliases and alternative dates of birth for some individuals, and full postal addresses for many entities. Those inclusions function as identification aids and impose a duty on downstream users to match multiple identifiers when implementing screening and due diligence procedures.

In short, the instrument does not itself specify operational prohibitions, but by listing and continuing listings it places named persons and entities within the sanctions framework governed by the Regulations. The duty to comply with that framework lies with administrative agencies and with private actors whose interactions with listed persons or entities would fall within the Regulations’ prohibitions. The instrument records who decided to list, who is listed, and when the listing takes effect.

This instrument is primarily a list management and designation instrument; it does not itself prescribe penalties or enforcement mechanisms. Instead, it operates under the Autonomous Sanctions Regulations 2011, citing subregulations 6(1), 9(3) and 10(1) as its statutory authority (clause 3). As a result, the instrument’s enforcement context must be understood in relation to the Regulations that it invokes, which the instrument does not reproduce in full.

What the instrument does show about enforcement mechanics

• Continuation and expiry: the note following clause 8 reproduces the Regulations’ time-limit mechanics, which are part of the enforcement and temporal framework. It states that designations under paragraph 6(1)(a) and declarations under paragraph 6(1)(b) cease to have effect on the third anniversary of their commencement unless renewed under subregulation 9(3), or otherwise on the third anniversary of the most recent declaration. That mechanism creates a recurring administrative check point, and failure to renew results in automatic cessation of the designation or declaration.
• Revocation authority: clause 7 explicitly exercises subregulation 10(1) to revoke listed designations and declarations for the persons in Schedule 4. That shows the executive’s capacity to remove persons and entities from the list, which is an enforcement-related power.

What the instrument does not state

• The instrument does not list or describe criminal or civil penalties, nor does it specify the operational prohibitions that are triggered by listing, such as asset freezes, travel bans, export restrictions, or transaction prohibitions. The instrument therefore does not itself impose sanctions penalties; it simply updates the roster of persons and entities to whom the Regulations’ prohibitions apply.
• The instrument does not describe inspection, seizure, or investigative powers of any particular enforcement agency, nor does it reference delegated enforcement arrangements.

Practical enforcement implications (as can be inferred from the instrument)

• When a person or entity is designated or declared by the instrument, enforcement will depend on the provisions in the Regulations that operate against designated or declared persons. The instrument’s publication and substitution of Schedule 1 (via Schedule 5) is the administrative step that permits enforcement action under the Regulations to be directed at those named persons and entities.
• The revocation entries in Schedule 4 remove the named persons from the schedule that the Regulations reference, and so operational enforcement actions directed solely at the basis of those names should cease to have effect where the revocation is effective.

Compliance monitoring and third-party enforcement

• The listing and continuation entries create duties for financial institutions, corporate registries, customs authorities and other compliance agents to check updated lists. The instrument’s detail on alternative names and dates of birth shows an administrative effort to reduce identification errors at the enforcement stage.

In short, penalties and enforcement measures are the legal effect of the autonomous sanctions framework in the Regulations. This instrument functions as the ministerial action that updates the list to which those penalties and enforcement mechanisms apply. It does not itself specify the sanctions, nor does it record enforcement action or penalties; those remain within the scope of the Autonomous Sanctions Regulations 2011 and any enforcement policies or operational guidance linked to that regulatory framework.

This instrument is explicitly an instrument under and part of the autonomous sanctions regulatory architecture established by the Autonomous Sanctions Regulations 2011. Clause 3 states that the instrument is made under subregulations 6(1), 9(3) and 10(1) of those Regulations. The instrument also directly amends the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014 through Schedule 5, by repealing and substituting Schedule 1 of that List.

Direct statutory interactions

• Primary link: the instrument depends on the Autonomous Sanctions Regulations 2011 for its legal effect. The instrument does not itself create the prohibitory or penalty regime; it updates the roster to which the Regulations apply, as reflected in clauses 4-8 and Schedule 5.
• Temporal rules: the instrument reproduces the Regulations’ three-year expiry mechanic in the explanatory note to clause 8, which is part of the Regulations’ interplay with the instrument insofar as expiry and renewal affect the continuing legal status of listed persons and entities.

Administrative interactions

• List substitution: Schedule 5 amends the 2014 List by substituting Schedule 1. That is an administrative law exercise, and the instrument interacts with the existing administrative record that other agencies and private parties rely upon for compliance. A substituted schedule can change the set of persons and entities subject to the Regulations instantaneously when the instrument commences.
• Revocation: clause 7 invokes subregulation 10(1) to revoke specific designations and declarations, which interacts with any administrative actions taken in reliance on prior listing, such as asset restrictions, blocked account arrangements or internal no-deal lists. The instrument provides the legal basis for agencies to lift measures tied to revoked entries.

Indirect or practical interactions with other legal regimes

• Commercial law and contracts: while the instrument does not directly invoke corporate, contract or banking laws, the practical effect of continued designation or revocation will interact with contracts, executory obligations and fiduciary duties. For example, entities that find counterparties named in Schedules will need to consider contractual covenants and statutory banking obligations, although the instrument does not specify those interactions.
• Record-keeping and reporting obligations: the instrument imposes an operational imperative to reconcile corporate registers and client due diligence files with the updated Schedules. That interacts with corporate and anti-money laundering compliance frameworks, even though this instrument does not itself reference those regimes.
• International law and foreign affairs: the instrument states, repeatedly, that listed persons and entities are "responsible for, or complicit in, the threat to the sovereignty and territorial integrity of Ukraine." That reflects a foreign policy determination used as the basis for listing. The instrument therefore sits at the intersection of domestic statutory powers and international relations, as manifest in the executive finding and the consequential legal status under the Regulations.

Limitations and boundaries

• The instrument is narrowly framed: it amends and updates the domestic schedule that triggers sanctions under the Regulations. It does not purport to amend the Regulations themselves, nor does it alter the substantive legal sanctions in those Regulations. Any interplay with other domestic statutes, including penal or civil statutes, must be read through the Regulations and applicable enforcement action, not through the instrument alone.

In sum, the instrument interacts directly with the Autonomous Sanctions Regulations 2011 and the 2014 List by continuing, creating or revoking entries, and thereby determines the roster to which the Regulations’ prohibitions apply. Practical consequences extend into commercial, financial and compliance domains, but those interactions are realised through the underlying Regulations and through agencies’ operational responses to the instrument.

The instrument itself records its own immediate amendment actions and the lineage back to the 2014 List, but it does not provide a historical index beyond the 2014 List it amends. The amendment history contained in and implied by this instrument is as follows.

Instrument provenance and date

• Made by the Minister for Foreign Affairs, Julie Bishop, and dated 13 June 2017. Clause 2 sets the commencement rule, which is the day after registration.

Amendment actions executed by the instrument

• Clause 4 and Schedule 1: continues to have effect certain designations and declarations originally listed in Schedule 1, Part 1 of the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014. That action formalises a renewal under subregulation 9(3) for the named persons in Schedule 1 of this instrument.
• Clause 5 and Schedule 2: continues to have effect certain entities’ designations that were listed in Schedule 1, Part 2 of the 2014 List, again by operation of subregulation 9(3).
• Clause 6 and Schedule 3: adds or confirms designated and declared persons by listing them in Schedule 3 of the instrument, citing paragraphs 6(1)(a) and 6(1)(b) of the Regulations.
• Clause 7 and Schedule 4: revokes the designations and declarations for the individuals listed in Schedule 4, using authority in subregulation 10(1).
• Clause 8 and Schedule 5: amends the 2014 List by repealing and substituting its Schedule 1 with the updated Schedule 1 set out in Schedule 5 to this instrument.

Nature of the Schedule 5 substitution

• Schedule 5 performs a wholesale replacement of Schedule 1 of the 2014 List. The substituted Schedule 1 is extensive and reorganises entries into Part 1 (Designated and declared persons) and Part 2 (Designated entities), expanding biographical and identification details for listed persons and providing addresses and additional information for entities. This substitution is not a minor patch; it is a full replacement.

Temporal context and renewal mechanics

• The instrument carries a note referring to subregulation 9(1) and 9(2) of the Regulations, stating that designations and declarations end on their third anniversary unless a declaration under subregulation 9(3) is made. The inclusion of that note signals the instrument’s role in the rolling renewal and expiry cycle for list entries.

Revocations: narrow and specific

• Schedule 4 lists three names for which prior designations and declarations are revoked. The instrument therefore contains both additions and deletions, which alters the operational list used by government and private sector compliance systems.

Administrative continuity

• By expressly continuing designations and declarations in Schedules 1 and 2, and by substituting Schedule 1 of the 2014 List, the instrument ensures a single authoritative list is published and circulated going forward. That reduces ambiguity about which entries remain operative, at least so far as the instrument’s Schedules show.

What the instrument does not record

• The instrument does not present a broader historical table of prior amendments, nor does it cite prior instruments that have modified the 2014 List between 2014 and 2017, other than by implication. The only explicit amendment record within the instrument is the substitution effected by Schedule 5.

In sum, the instrument’s amendment history is immediate and internal: it updates the 2014 List by continuing some prior entries, adding new persons and entities, revoking some entries, and substituting the 2014 List’s Schedule 1 with a new, expanded Schedule. The legal mechanics used are subregulations 6(1), 9(3) and 10(1) of the Autonomous Sanctions Regulations 2011.

This instrument does not record any litigation history. There are no judicial decisions, administrative appeals or contested proceedings referred to, nor is there any indication within the text that a judicial determination is attached to any designations or revocations listed in the Schedules.

What the absence of recorded litigation means, operationally

• The instrument is silent on whether any person named has sought judicial review, merits review, or any other legal process challenging their inclusion or removal. The absence of a litigation record in the instrument does not mean no such proceedings exist, it only means the instrument itself does not document them.
• The instrument provides neither a procedural narrative of how entries were reached, nor a summary of representations made by listed persons, nor details of any advisory board or internal review. It is therefore an administrative listing instrument rather than a reasoned decision record of adjudicative proceedings.

Practical litigation considerations for practitioners

• Since the instrument is an administrative act made under statutory powers in the Regulations, typical administrative law avenues may be available to affected persons or entities under the broader administrative law framework. The instrument does not set out those routes. Practitioners advising listed persons should therefore look beyond this instrument to the Autonomous Sanctions Regulations 2011 and general administrative law remedies, including judicial review, as potential avenues. This instrument itself does not define or limit that possibility.
• Where a revocation is recorded in Schedule 4, any prior litigation standing on the basis of the earlier listing may change in practical terms, but the instrument itself does not state any transitional arrangements or remedial steps that follow revocation.

Risks and evidence posture

• The Schedules include specific identifying information such as dates of birth, aliases and positions held. Any litigation or review proceeding would engage those factual entries as part of the administrative record. The instrument will be part of the public administrative record that a court or tribunal may consult.

In summary, the instrument contains no litigation history, and it does not reference any court or tribunal outcomes. It is a ministerial list update, and any litigation history relevant to listed persons, if it exists, must be sourced from court records and other instruments beyond the text of this instrument.

This instrument has several practical features and drafting details that compliance officers, lawyers and businesses should notice because they can create identification, operational and legal risk if overlooked.

1. The instrument continues designations and declarations, but does not state the operative prohibitions

• The instrument repeatedly declares that entries "continue to have effect" (clauses 4 and 5) and makes new designations and declarations (clause 6), but it does not detail the specific prohibitions or exemptions that attach to being a designated or declared person. Users must refer to the Autonomous Sanctions Regulations 2011 for the legal consequences. Failure to consult the Regulations risks mis-implementing obligations.

2. Substitution of Schedule 1 is a wholesale change

• Schedule 5 repeals and substitutes Schedule 1 of the 2014 List. That is not a partial amendment, it is a complete replacement. Organisations relying on older extracts must ensure they replace their local database with the substituted Schedule 1 in full to avoid omitting newly listed persons or entities.

3. Identification complexity: aliases, transliterations and alt dates of birth

• Several entries include alternative names, "also known as" entries, or alternative dates of birth (for example, Evgeni Bushmin has DOB 04/10/1958; alt DOB 10/10/1958 in Schedule 1). Some individuals appear multiple times across Schedules, for example Vladimir Ustinov appears in Schedule 3 and is also present in the substituted Schedule 1 entries. Systems must be able to match across variants to avoid false negatives or duplicate blocking.

4. Formatting anomalies in the text

• The instrument contains small formatting or typographical issues such as misaligned date-of-birth entries, missing DOB in one line followed by DOB in the next (for example Viktor Yanukovych is presented with an empty cell then DOB), and duplicated listings (some names appear both in the main schedule and the Schedule 3 list). These anomalies may produce ambiguity when ingesting the list automatically. Manual reconciliation is advisable.

5. Mixed categories and overlapping entries

• The instrument treats persons as both "designated" and "declared" in clause 6 for Schedule 3 lists, reflecting paragraph 6(1)(a) and 6(1)(b) of the Regulations. For practical screening, this means the same person may be captured under multiple regulatory hooks. Systems that differentiate by category must map both categories to the same sanctions consequence set.

6. Revocations are specific and partial

• Schedule 4 revokes the designations and declarations for three named individuals. Practitioners should check whether any internal blocking or contractual measures are tied to those names, and if so whether the revocation requires de‑blocking or other remediation. The instrument does not outline transitional arrangements or the effective date of relief beyond the instrument’s commencement rule, so operational teams must act promptly on the commencement date.

7. Temporal effect: commencement day after registration and three-year expiry

• Clause 2 makes the instrument commence the day after registration. The note to clause 8 reproduces the Regulations’ three-year expiry rule for designations and declarations. Practically, organisations should not assume listings are permanent; they should implement periodic re-screening and maintain an audit trail that records the instrument’s effective date to reconcile actions taken while the entry was live.

8. Substantive reasons are summarised but not adjudicated

• The Schedules include brief "Additional Information" explaining why a person or entity is listed, for example roles in Crimea or the Donbas. These are statements of basis, not judicial findings, and the instrument does not provide the underlying evidence. Advisers should therefore treat those summaries as ministerial characterisations supporting the listing, and not as conclusive legal findings of fact.

9. Wide geographical and entity types

• The list includes banks, construction firms, defence manufacturers, state enterprises in Crimea, paramilitary groups and self-proclaimed "people’s republics", as well as individuals. This cross-sectional coverage increases the scope of commercial interactions that may be affected and complicates sectoral screening.

10. No procedural detail for contesting or delisting in this instrument

• The instrument does not set out any process for representations, delisting requests or merits review. Practitioners advising listed persons should locate procedural routes in the Regulations and in general administrative law sources, not in this instrument.

These "gotchas" are concrete operational risks. The cumulative effect is that automated ingestion of the instrument without human reconciliation, cross-checking against the Regulations for substantive prohibitions, and periodic re-screening for expiry and revocation will increase the likelihood of compliance errors.

This instrument is a list update. Compliance requires both technical list management and legal analysis within the Autonomous Sanctions Regulations 2011 framework. The instrument provides the updated content; it does not itself recite the operative prohibitions, so the first compliance step is to link this instrument to the applicable provisions in the Regulations and any implementing guidance from government agencies.

Immediate technical steps

1. Ingest the instrument promptly, effective the day after registration (clause 2)

• Update sanctions screening databases on the instrument’s commencement date. Replace the existing Schedule 1 of the 2014 List with the substituted Schedule 1 in Schedule 5. Ensure ingestion captures aliases, alt DOBs and entity addresses included in the Schedules.

2. Reconcile duplicates and aliases

• Normalise transliterations and aliases. Many persons have multiple name forms, "also known as" entries and alternate DOBs. Build or confirm fuzzy-match rules for Cyrillic-to-Latin transliteration variants and for alternate DOBs to reduce false negatives. Where names appear in multiple Schedules, ensure they map to a single canonical record to avoid duplicate blocking actions.

3. Track revocations and expiries

• Mark persons from Schedule 4 as revoked and remove or flag any internal blocking measures that are contingent only on listing. For all listings, track the three-year anniversary rule referenced in the instrument’s note to clause 8, and build calendar reminders to check whether renewals under subregulation 9(3) have occurred.

4. Cross-check legal consequences with the Autonomous Sanctions Regulations 2011

• The instrument does not specify prohibitions. Before taking enforcement or blocking action, confirm the precise regulatory consequences that flow from being a "designated" or "declared" person or entity under the Regulations. Apply only those actions authorised by the Regulations and any relevant departmental guidance.

Operational and legal safeguards 5. Update onboarding, transaction monitoring and KYC processes

• Amend client onboarding questionnaires and enhanced due diligence procedures to include the updated list. For existing customers, run a targeted re-screen against the substituted Schedule 1 and the other Schedules in this instrument.

6. Record decision rationale and audit trail

• Maintain detailed records of any decisions to refuse service, block transactions or freeze assets because of the listing, showing the exact match criteria used (e.g., DOB, alias), the instrument clause relied on, and the date and time of action. This will assist later review if delisting or revocation occurs.

7. Consider contractual and commercial consequences

• Review existing contracts with named entities and counterparties for material adverse consequences arising from continued designation or revocation. For contracts that require performance involving a designated entity, obtain legal advice before continuing performance. The instrument does not provide licences, so check the Regulations for any licensing or exemption mechanisms.

8. Liaise with legal counsel on disputed or borderline matches

• Where identity is uncertain because of similar names or incomplete biographic data, seek legal advice before taking irreversible steps. The instrument’s Schedules provide identifying details that should be used to resolve ambiguous matches, but where uncertainty remains, escalation to a legal team is prudent.

9. Monitor government guidance and subsequent instruments

• The instrument is part of a rolling list process. Watch for further instruments that either renew, amend or revoke entries. Because the instrument substitutes Schedule 1 of the 2014 List wholesale, subsequent instruments may perform incremental updates; continuous monitoring is necessary.

10. For listed persons: seek accurate channels to challenge listing

• The instrument does not outline review mechanisms. Persons who consider they have been wrongly listed should seek legal advice to identify the proper administrative or judicial routes. The instrument’s revocation clause shows that the executive can revoke listings, but the instrument does not identify the procedural steps for pursuing revocation.

Practical checklist for compliance teams

• Immediately replace the local 2014 Schedule 1 with the substituted Schedule 1 from Schedule 5.
• Ingest Schedules 1-3 and flag Schedule 4 revocations.
• Validate name matching algorithms against alias and alt DOB fields.
• Re-screen existing customers and counterparties, prioritising financial and supply‑chain exposures.
• Prepare de‑blocking procedures for any transactions or funds affected by Schedule 4 revocations.
• Document every screening match with the exact Schedule and clause relied on.
• Train frontline staff to escalate positives for legal review and to follow written procedures tied to the Regulations.
• Maintain a calendar for three-year expiry checks and for the instrument’s commencement date.

In short, complying with this instrument requires accurate data ingestion, cross-referencing with the substantive Regulations for permitted actions, careful identity matching given transliteration and alias issues, prompt operational changes for revoked entries, and an administrative regime for tracking periodic expiry and renewals. The instrument makes the list; the Regulations determine what to do about it.