Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Ukraine) Continuous Effect Declaration 2020 (No 1)

The instrument uses a small set of legal concepts drawn from the Autonomous Sanctions Regulations 2011 and the existing 2014 List. The instrument assumes familiarity with those concepts rather than restating their statutory definitions. Key concepts and how the instrument operates with them are as follows.

• Designated person and designated entity. The instrument refers repeatedly to “designated person” and “designated entity” entries as they appear in Part 1 and Part 2 of Schedule 1 of the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014. Sections 4 and 5 declare that the persons listed in Schedule 1 of the instrument and the entities listed in Schedule 2 are responsible for, or complicit in, the specified threat and that their prior designations continue to have effect. The instrument therefore changes the legal status of those listed under the existing List 2014 by extending their designation period.

• Declared person. Section 4 also references declarations of “declared person” in Part 1 of Schedule 1 of the 2014 List, and the instrument declares those declarations to continue. The instrument invokes subregulation 9(3) of the Regulations as its legal basis for making continuation declarations (s 3; ss 4-5).

• Continuation of effect. The instrument invokes the specific mechanism in subregulation 9(3) of the Regulations to prevent automatic expiry of a designation or declaration. The instrument’s own Note reproduces the operative expiry rule from subregulations 9(1) and (2): designations and declarations cease to have effect on the third anniversary of the day they took effect unless a declaration under subregulation 9(3) has been made, in which case they cease on the third anniversary of the most recent declaration. By making the declaration in this instrument, the Minister triggers that continuation mechanism.

• Revocation. Section 6 invokes subregulation 10(1) of the Regulations to revoke particular earlier designations/declarations as specified in Schedule 3. The instrument thus both prolongs the effect of some entries and removes others.

• Amendment of the List. Section 7 enacts Schedule 4, which contains the textual amendments to the 2014 List. Schedule 4 shows a number of precise substitutions, repeals and additions including augmented identifying particulars. Mechanically, these amendments alter the public List 2014 entries that compliance and enforcement parties will consult.

• Identifiers for compliance. Schedule 4, in replacing items in the 2014 List, supplies multiple search fields: aliases, alternative spellings, alternate dates of birth, places of birth, corporate addresses, registration identifiers (for example registration IDs, Tax ID Nos.), SWIFT/BICs, email addresses, websites and Legal Entity Identifier (LEI) data for a number of entities. Those particulars are part of the instrument and are the primary mechanism by which the state communicates who is covered.

The instrument does not itself reproduce the substantive prohibitions that attach to being a designated or declared person or entity. It therefore functions within the administrative architecture of the Regulations and the List 2014, operating to change who is on that list and the particulars recorded against them. The instrument explicitly relies on the Regulations’ continuation/revocation and expiry mechanics (subregulations 6(1), 9(3) and 10(1)), and the Note in the instrument highlights the automatic three-year expiry rule unless renewed by a declaration.

The instrument directly affects the legal status of the specific persons and entities enumerated in its Schedules and, indirectly, any Australian person or entity whose conduct is regulated by the Autonomous Sanctions Regulations 2011 and related instruments that implement sanctions against listed persons and entities.

Directly affected individuals. Schedule 1 lists 49 named individuals. Those names include Russian political figures, members of Russian federal bodies, Crimean political actors, individuals described as business associates, senior military figures and persons described as organisers or leaders of activities related to Crimea and separatist entities. Examples drawn from the Schedule and Schedule 4 amendments include Sergey Yur’yevich Glazyev, Andrei Aleksandrovich Klishas, Valentina Ivanovna Matviyenko, Dmitry Olegovich Rogozin, Vladislav Yur’yevich Surkov, Viktor Fedorovych Yanukovych, Viktor Volodymyrovich Medvedchuk, Arkady Romanovich Rotenberg, Gennady Nikolayevich Timchenko, and Colonel-General Alexander Dvornikov, among others. The instrument includes aliases, alternative transliterations and in many entries additional information describing roles relevant to the instrument’s stated purpose (for example “Former Presidential Adviser to President Putin. Publicly called for the annexation of Crimea” for Sergey Glazyev) in Schedule 4 substitutions.

Directly affected entities. Schedule 2 lists 11 named entities, including financial institutions such as Bank Rossiya, Invest Capital Bank, SMP Bank, and commercial and infrastructure enterprises such as Stroygazmontazh, Transoil, Stroytransgaz Group, The Volga Group, and Chernomorneftegaz. Schedule 4 supplies corporate addresses, registration numbers, Tax ID numbers, SWIFT/BICs, websites and, for some, control or ownership information (for example, noting “controlled by Arkady and Boris Rotenberg” or “owned or controlled by Gennady Nikolayevich Timchenko”).

Revoked listings. Schedule 3 lists two individuals whose designations and declarations are revoked by the instrument: Evgeni Viktorovich Bushmin and Valery Kirillovich Medvedev. For those two named individuals the instrument removes their prior designation/declaration under the List 2014.

Who bears regulatory obligations. The instrument does not itself specify which external actors must act differently, but the statutory context (the Regulations and the 2014 List) implies that Australian persons and entities who are subject to the autonomous sanctions regime must account for the updated list. Those parties include banks, financial intermediaries, importers and exporters, transport and logistics providers, professional services firms and other private sector actors who use the List 2014 in their sanctions screening and compliance processes. The instrument’s inclusion of multiple identifiers in Schedule 4 changes how those private-sector actors will identify covered persons and entities in their transaction screening, customer due diligence and risk assessments.

Decision-maker and timeline. The instrument is made by the Minister for Foreign Affairs (the instrument is signed by Marise Payne). It commences the day after registration (s 2). The Note in the instrument makes explicit that, absent continuing declarations, designations expire on the third anniversary of their coming into effect, so the continuations effected by this instrument are time-limited in accordance with the Regulations unless further declarations are made.

Geographic and sectoral reach. The listed persons and entities are associated with political, military and commercial activity related to Ukraine and Crimea. The entities listed include banks, construction and energy companies and aviation services firms. Those sectors are therefore the principal targets of the continuing designations in this instrument.

This instrument itself is a declaratory and amending instrument; it does not enumerate the full set of duties or civil/criminal penalties. Nonetheless it produces legal consequences by changing who is captured by the autonomous sanctions List 2014. The following are the key legally relevant duties, rights and administrative processes that the instrument affects or invokes, as set out in the instrument and its statutory references.

Who makes the decision. The Minister for Foreign Affairs is the decision-maker for making the instrument, exercising powers conferred by subregulations 6(1), 9(3) and 10(1) of the Autonomous Sanctions Regulations 2011 (s 3). The instrument itself is the expression of that executive decision.

Declaration and revocation powers. Section 4 uses the declaration power in subregulation 9(3) to declare that the persons in Schedule 1 continue to be designated and declared persons, and section 5 correspondingly declares the continuation of the entities in Schedule 2 as designated entities. Section 6 uses the revocation power in subregulation 10(1) to revoke the identification of the Schedule 3 persons in the 2014 List.

Rights of listed persons and entities. The instrument does not in its text specify appeal or review rights; it merely effects continuation or revocation. The Regulations under which it is made include mechanisms for expiry, continuation and revocation (as referenced in the instrument Note). Any substantive rights to review or challenge designations would be governed by the broader statutory framework, not by this instrument’s text.

Duties on third parties. The instrument does not restate the duties that arise from a person or entity being listed. Those duties,such as prohibitions on dealing, reporting obligations, asset-freezing measures, or travel restrictions,are elements of the autonomous sanctions regime residing in the Regulations and in related primary legislation and subordinate instruments. The instrument places third parties on constructive notice that the persons and entities listed in Schedules 1 and 2 are to be treated as continuing entries on the 2014 List for the period mandated by the Regulations.

Compliance particulars that the instrument supplies. Schedule 4 adds identifiers and details that change how third parties identify listed persons and entities in practice. These include: aliases and transliterations, alternative dates of birth, places of birth, corporate addresses, registration IDs and tax identifiers, SWIFT/BIC codes, LEI codes and websites. Those particulars are the practical inputs to compliance systems that feed automated screening and enhanced due diligence. The instrument thereby changes the operational duty for compliance officers: update lists, incorporate aliases/alternative transliterations, and use additional corporate identifiers supplied in Schedule 4.

Temporal duty to monitor. The instrument’s Note reminds readers of the automatic three-year expiry rule under subregulations 9(1) and (2). That rule creates a recurring duty on regulators and affected private parties to monitor for further declarations or revocations every three years for any given designation, since the Minister may make further continuation declarations (like this instrument) to prevent expiry, or may allow expiry or revoke a listing under subregulation 10(1).

What the instrument does not do. The instrument does not set out the prohibitions or the precise compliance steps to be taken by regulated persons. It does not itself provide for penalties or enforcement action; those are matters for the Regulations and other parts of the sanctions regime. The instrument is an administrative act that adjusts who is captured by those underlying obligations.

The instrument does not set out particular civil or criminal penalties or enforcement mechanisms within its text. It acts by continuing or revoking entries in the 2014 List and by amending that List. Enforcement consequences and penalties therefore arise from the Autonomous Sanctions Regulations 2011 and any related primary or subordinate legislation that implements prohibited conduct against listed persons and entities. The instrument explicitly cites its authority under subregulations 6(1), 9(3) and 10(1) of the Regulations (s 3), and the Note summarises the expiry mechanics from subregulations 9(1) and 9(2), but it does not replicate or restate penalty provisions.

What the instrument makes administratively enforceable. By declaring the continuation of designations and declarations or by revoking them, the instrument changes the set of persons and entities who will attract any prohibitions, asset-freezing measures, or other enforcement steps specified elsewhere. For enforcement agencies and compliance units, the amendment is the trigger to apply the relevant sanctions obligations in relation to the newly continued entries and to remove obligations in relation to revoked entries. The instrument’s Schedule 4 additions of identifiers and registration data are enforcement facilitators: they supply fields that regulators and reporting entities can use to match transactional data or asset information against the List.

Where to find penalty provisions. Because this instrument is an instrument made under the Autonomous Sanctions Regulations 2011, anyone seeking the operative penalty provisions must turn to the Regulations and any primary legislation referenced by the Regulations. The instrument itself provides the statutory cross-references that locate those provisions (s 3). The instrument’s Note expressly points to subregulations 9(1)-(2) and 9(3) and subregulation 10(1) as the regulatory mechanisms governing expiry, continuation and revocation.

Practical enforcement implications arising from the instrument. The most immediate enforcement implication is that, as of the instrument’s commencement (the day after registration, s 2), enforcement agencies and reporting entities must treat the Schedule 1 and Schedule 2 entries as continued designated/declared persons and entities for all purposes under the Regulations for as long as the continuation operates. Conversely, the two names in Schedule 3 should be treated as removed from the List 2014 as of commencement. Agencies that coordinate international financial sanctions, export controls, or criminal enforcement will need to update their systems and relevant watchlists with the Schedule 4 details to minimise false negatives during automated screening.

Limitations on the instrument’s enforcement content. Because the instrument does not itself create offences, a reader cannot infer from this instrument alone what penalties a contravention of a sanctions prohibition would attract. The appropriate course is to consult the Autonomous Sanctions Regulations 2011 and the broader statutory instrument package for those enforcement details.

This instrument functions as an implementing and list-management instrument within Australia’s autonomous sanctions architecture. Its interaction with other laws is primarily through the regulatory provisions it cites and the List 2014 that it amends.

Statutory basis and subordinate relationship. The instrument is made under subregulations 6(1), 9(3) and 10(1) of the Autonomous Sanctions Regulations 2011 (s 3). That places it as a subordinate instrument operating within the regulatory framework created by the Regulations. The Regulations themselves form part of the larger legal architecture that implements Australia’s autonomous sanctions, which will include relevant primary legislation and related subsidiary instruments. For the legal consequences that attach to a person or entity being “designated” or “declared”, one must consult the Regulations and any connected primary legislation.

Effect on the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014. Section 7 and Schedule 4 operate directly to amend the 2014 List. The instrument omits and substitutes numerous items, repeals certain entries and inserts expanded particulars. Once registered and commenced, the amended List 2014 will reflect the substitutions and repeals in Schedule 4. That has immediate effect for anyone who must consult the List 2014 as the authoritative list of designated/declared persons and entities for the Ukraine-related autonomous sanctions.

Expiry mechanics and relation to the Regulations. The instrument explicitly references the automatic three-year expiry mechanism in subregulations 9(1) and 9(2) of the Regulations (see the instrument’s Note). That mechanism means that designations and declarations have a statutory duration unless extended by a declaration under subregulation 9(3), which is the specific power used by this instrument to continue specified entries. Thus the instrument is an exercise of a statutory extension power, and it must be read in conjunction with the Regulations’ provisions governing duration and termination.

Administrative law and review. The instrument does not provide details on review rights. Any judicial review, merits review or other administrative law remedies for persons or entities affected by the instrument would arise under general administrative law principles and the available review routes in the legislation that governs the making of designations, and not from this instrument as a standalone matter. The instrument’s revocation provision (s 6) signals that administrative correction or removal is possible under the Regulations.

Interaction with criminal law, export controls and financial regulatory regimes. The instrument’s continuation of listings potentially engages other areas of law where listed status is consequential, such as prohibitions on dealing with listed persons (commercial, financial or property dealings), export/import controls, financial reporting and anti-money laundering regimes. The instrument itself does not specify or create those cross-domain prohibitions, but by amending the List 2014 it alters which persons and entities other Australian regulatory and enforcement regimes must treat as covered. Consequently, the instrument interacts operationally with other laws to the extent those laws import or reference the 2014 List.

International obligations and extraterritoriality. The instrument is presented as part of Australia’s autonomous sanctions policy in response to threats to Ukraine’s sovereignty and territorial integrity. The instrument does not explore or state how it aligns with treaty obligations or with foreign laws. Its immediate legal interaction is domestic: it adjusts the domestic List 2014 entries used by Australian authorities and private parties. Any international coordination effects are not specified in the instrument.

This instrument is itself an amending instrument for the Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Ukraine) List 2014. Schedule 4 of the instrument sets out the textual amendments. The amendment history recorded within the instrument is as follows.

• Broad substitution and repeal strategy. Schedule 4 contains a sequence of “Omit the items substitute” and “Repeal the item” directives that replace or remove entries in Part 1 (individuals) and Part 2 (entities) of Schedule 1 of the 2014 List. Specific table items are replaced with more detailed entries, and some entries are repealed outright.

• Part 1, items 1 to 21. Schedule 4 replaces entries for items 1 to 21 in Part 1 of Schedule 1. For example, the entry for Sergey Yur’yevich Glazyev is restated with alternative transliterations, a date and place of birth (01/01/1961, Zaporozhye), and “Additional Information” describing his former role as Presidential Adviser and reference to his public calls for annexation of Crimea. Other entries in this block (e.g. Andrei Klishas, Valentina Matviyenko, Yelena Mizulina) are likewise expanded with aliases, DOBs, places of birth and additional information including statements of public support for deployment of Russian forces or legislative sponsorship relevant to territorial changes.

• Repeal of some items. Schedule 4 instructs repeals for certain prior entries. For instance, Part 1 (table item 22) is repealed. Part 1 (table item 39) is also repealed. The instrument thereby removes prior entries at those positions.

• Part 1, items 23 to 38. Schedule 4 omits and substitutes items 23 to 38, again supplying fuller identifying particulars, aliases, DOBs and “Additional Information” notes linking persons’ activities to the Crimea/Ukraine context.

• Part 1, items 40 to 47. Schedule 4 repeats the substitution approach for items 40 to 47, adding and clarifying aliases, DOBs and additional information.

• Part 1, items 108 to 111. Schedule 4 omits items 108 to 111 and substitutes new entries specifying more detailed biographical and role-related data for Vladimir Vasilyevich Ustinov, Dmitry Ovsyannikov, Colonel-General Alexander Dvornikov and Colonel-General Andrei Kartapolov.

• Part 2, items 1 to 11. Schedule 4 omits and substitutes Part 2 table items 1 to 11 with fully specified entity entries. The new entries include alternate company names, addresses, registration IDs, tax numbers, SWIFT/BICs, websites, email addresses and, where relevant, notes as to ownership or control (for example, Bank Rossiya, Stroygazmontazh, Aquanika, Avia Group LLC, Stroytransgaz Group, The Volga Group, Transoil and Chernomorneftegaz).

• Effect on the 2014 List format and searchability. The amendments systematically add fields intended to help identify listed persons and entities for enforcement and compliance purposes. The inclusion of transliterations and multiple aliases in Schedule 4 is significant because it recognises the need to match varied spellings across different documents and data systems.

• Revocation list. Schedule 3 of the instrument contains specific revocations. Two named individuals are revoked from Part 1 of Schedule 1 of the 2014 List: Evgeni Viktorovich Bushmin and Valery Kirillovich Medvedev.

• Commencement timing. The instrument commences the day after registration (s 2). That means the amendments become operative immediately for the purposes of domestic regulatory and compliance systems aligned to the List 2014.

Taken together, these changes show a pattern of periodic list maintenance: continuation of prior designations by declaration, removal of particular prior entries, and augmentation of details for the remaining listed persons and entities to improve identifiability. The instrument itself is the formal step effecting those changes to the authoritative domestic sanctions list.

The instrument does not record any litigation history. It is a ministerial declaration and set of list amendments; the text contains no references to judicial decisions, merits review determinations or other litigation outcomes.

What is directly ascertainable from the instrument about possible legal contestation is limited to procedural mechanics implied by the Regulations. Section 6 provides for revocation under subregulation 10(1) of the Autonomous Sanctions Regulations 2011, which is an administrative mechanism to remove names from the List 2014. The instrument does not describe remedies available to affected persons or entities such as merits review or judicial review of the Minister’s decision; those matters would be governed by the relevant statutory framework, the Administrative Decisions (Judicial Review) Act or other applicable review mechanisms, and any such challenges would be external to the instrument itself.

Absent litigation recorded in the instrument, practitioners should note the following practice points implied by the regime set out in the instrument:

• Timeliness of challenges. Any person or entity seeking to challenge a designation, declaration or revocation that is reflected in the 2014 List as amended would need to identify the statutory review or judicial review avenues available under the governing legislation and regulations, and act promptly given the instrument’s immediate commencement and the expiry mechanics described in the instrument’s Note.

• Administrative reversal mechanism. The instrument shows that the Minister has mechanisms to revoke existing listings (s 6; Schedule 3). That indicates a remedial administrative route for removal of entries, but it does not record whether any particular remittal, application or process led to the revocations recorded in Schedule 3.

• Evidentiary record. The instrument’s Schedule 4 contains “Additional Information” fields for many listed persons and entities. That content constitutes the Ministry’s publicly stated grounds and identifiers for listing. For any future litigation or review, those statements and particulars would form part of the administrative record relied upon by decision-makers and potentially by reviewing tribunals or courts.

• No cases named. The instrument itself names no cases and cites no litigation precedent. Therefore, a researcher seeking litigation history must consult court records, tribunal databases and the wider administrative record outside this instrument.

In short, the instrument contains no litigation history and no statements about prior or ongoing litigation involving the listed persons or entities. Any litigation history relevant to the effect of these listings would exist outside the instrument and must be discovered through independent legal research of the applicable review and judicial systems and of the administrative records of the Department responsible for the sanctions List 2014.

Several practical and legal “gotchas” arise from the instrument’s content and mechanics. These are matters that create risk for regulated entities, compliance teams and listed persons, based strictly on the instrument’s text.

1. Continuation mechanism is time-limited and discrete. The instrument relies on subregulation 9(3) to continue designations, but the Note points out the three-year automatic expiry rule in subregulations 9(1) and (2) unless further declarations are made. Practitioners must not assume continuation is indefinite. Each continuation declaration resets the three-year clock. Failure to monitor for subsequent declarations or expiry will create risk of both over- and under-compliance.

2. Multiple aliases and alternate transliterations. Schedule 4 supplies long lists of aliases, alternative transliterations and alternative dates/places of birth for many individuals. That creates two issues. First, compliance systems relying on exact-string matching may miss covered individuals due to transliteration differences. Second, overly broad matching rules could generate false positives when common name elements match innocent third parties. The instrument intentionally gives multiple name forms; screening algorithms need to be tuned to capture true positives while minimising false positives.

3. Alternate dates and alternative places of birth. Several entries include alternative dates of birth and alternative places of birth. These alternates complicate identity matching and increase the need for enhanced due diligence when a potential match is close but not exact.

4. Detailed corporate identifiers and risk of misattribution. For entities the instrument lists addresses, registration IDs, tax IDs, SWIFT/BICs and LEI codes. These details improve identification, but they also carry the risk that a corporate group or subsidiary not listed could be mistakenly treated as sanctioned if naming conventions are similar. The instrument sometimes states an entity is “owned or controlled by” certain individuals or groups. Practitioners must be cautious when extrapolating listed status to related entities where the instrument does not expressly list them.

5. Revocations are narrow. Schedule 3 revokes the designation for only two named individuals. Revocation does not imply the person has no residual exposure in other lists or legal regimes. Users must ensure their systems remove the two names from the 2014 List but continue to check other sanctions lists and regulatory obligations.

6. The instrument does not recite prohibitions or penalties. Readers could mistakenly assume the instrument itself includes procedural details about enforcement, reporting, exemptions or licensing. It does not. To know what conduct is prohibited and what exceptions may exist, one must consult the Regulations and any related legislation, which are referenced by the instrument.

7. Commencement timing. The instrument commences the day after registration (s 2). Organisations that assume changes are effective on the date of signature or publication may be premature. Systems, legal opinions and transactional clearances should treat the day-after-registration commencement as the operative date.

8. Ambiguity as to scope of “responsible for, or complicit in”. Sections 4 and 5 state that each named person or entity “is responsible for, or complicit in, the threat to the sovereignty and territorial integrity of Ukraine.” That is a purpose statement and might be used in administrative materials as explanatory grounds. It does not, however, define the precise conduct that constitutes “responsible or complicit” for legal purposes. The scope of those phrases for the purposes of enforcement and review may be litigated or clarified only by reference to the Regulations and administrative record, not by the instrument alone.

9. Multiple identifiers may require system upgrades. The inclusion of SWIFT/BIC and LEI values, and of specific email addresses and websites, can improve detection but may require compliance systems be configured to cross-reference additional data fields beyond name, DOB and address. Smaller firms may face material compliance costs to integrate those identifiers into screening workflows.

10. Public-facing “Additional Information” as evidential source. The Schedule 4 “Additional Information” statements comprise public-facing justifications and role descriptions. Those statements may be relied upon by external audiences to form risk judgements. However, they are administrative summaries that may not be exhaustive. Practitioners should treat such entries as a starting point for due diligence rather than as conclusive legal determinations.

The instrument alters the authoritative sanctions List 2014 entries and supplies expanded particulars that compliance teams and regulated parties must incorporate. The following steps derive directly from the instrument’s mechanics and the particulars that it adds. They are practical actions grounded in the instrument itself.

1. Update the authoritative list immediately after commencement. The instrument commences the day after registration (s 2). Compliance teams must update their sanctions-screening lists and data feeds to reflect: the continued designation of all persons in Schedule 1, the continued designation of all entities in Schedule 2, and the revocation of the two names in Schedule 3. Do not rely on the instrument’s signature date; use the instrument’s commencement.

2. Incorporate aliases and alternative transliterations. Schedule 4 adds many alternate name forms, patronymics, and transliterations. Update matching rules to include the supplied aliases and transliterations as explicit search terms. Where the instrument supplies multiple name variants for a single person, ensure all variants are loaded into the screening database rather than relying on fuzzy matching alone.

3. Add alternate DOBs and places of birth to identity checks. The Schedule 4 entries sometimes include alternate dates or places of birth. Include those alternates in identity matching logic so that a potential match with an alternate DOB or POB is not overlooked.

4. Use corporate identifiers for entity screening. For listed entities, Schedule 4 often supplies addresses, registration IDs, Tax ID numbers, SWIFT/BICs, websites, email addresses and, in one case, an LEI. Add those identifiers to entity-screening profiles to reduce false negatives. Pay special attention to SWIFT/BIC and LEI entries, as financial counterparties use these codes in payment and messaging systems.

5. Remove revoked entries from positive-block lists but keep audit trail. Schedule 3 revokes two individuals. Remove those names from “hard block” lists that would prevent transactions, but retain a dated record of the removal and the instrument that effected it. This preserves an audit trail in case of future enquiries.

6. Review third-party relationships where listed entities are shown to be “owned or controlled by” named individuals. Schedule 4 contains statements of ownership and control (for example, that Invest Capital Bank and SMP Bank are controlled by Arkady and Boris Rotenberg, and that a number of entities are owned or controlled by Gennady Timchenko or the Volga Group). Where your organisation has commercial relationships with entities that the instrument names as controlled by listed persons, undertake enhanced due diligence to understand whether the specific counterparty is named in Schedule 2 or remains outside the list.

7. Adjust automated screening thresholds. Given the instrument’s multiplicity of aliases and transliterations, recalibrate automated screening to reduce the incidence of false positives. Configure alert triage processes so that match-weighting accounts for the multiple identifiers now provided in the amended List.

8. Monitor the three-year expiry cycle. The instrument’s Note stresses that designations and declarations cease to have effect on the third anniversary unless a declaration under subregulation 9(3) is made. Record the relevant three-year expiry dates for each continued designation and set reminders to check whether the Minister makes further continuation declarations before the expiry date.

9. Train relevant staff on the scope and limits of the instrument. Ensure frontline compliance staff, legal, trade operations and treasury understand that this instrument: (a) continues certain designations and revokes a small number of others; (b) does not itself set out prohibitions or penalties; and (c) supplies identifiers that are to be used in conjunction with the substantive prohibitions and licensing mechanisms in the Regulations. Emphasise that the substantive prohibited conduct is defined elsewhere and that this instrument changes “who” is covered.

10. Coordinate with banks and financial intermediaries. The inclusion of banking identifiers such as SWIFT/BIC codes and tax/registration numbers makes it critical for banks and payment service providers to incorporate these exact identifiers into payment screening and sanctions transaction monitoring. Ensure banking counterparties and upstream payment screening providers have applied Schedule 4 updates.

11. Keep documentary evidence of searches and decisions. Because the instrument is an administrative update to the 2014 List, record the searches, matches, decisions and any licences or government authorisations obtained in relation to covered persons and entities. The instrument itself will form part of the audit trail for why a particular person or entity was treated in a given way at a given time.

12. Do not assume the instrument exhausts all applicable lists. The instrument amends the Ukraine-related autonomous sanctions list. It does not purport to list persons or entities that may be covered under other Australian sanctions instruments or under foreign jurisdictions’ sanctions. Maintain comprehensive screening against multiple lists as required by your legal and regulatory obligations.

13. Consult the Regulations for prohibitions and licensing pathways. The instrument does not state what conduct is prohibited or whether there exist licensing or humanitarian exceptions. To determine whether a proposed transaction is permitted, consult the Autonomous Sanctions Regulations 2011 and any relevant primary legislation or guidance material from the Department responsible for sanctions.

14. Prepare procedures for dealing with ambiguous matches. Because the Schedule 4 entries supply many variants and alternative identifiers, create written procedures for escalation and for seeking official guidance or licences when the match is uncertain.

Following these steps will align compliance practices to the immediate technical changes the instrument effects: it does not remove the need to consult the Regulations for the operative prohibitions and licensing processes, and it does not obviate the need for legal advice where commercial or reputational risk is material.