Charter of the United Nations Act 1945 Listing (No. 2) 2020

The Listing rests on a small set of legal and administrative concepts stated in the instrument itself. Those concepts, and the precise language the instrument uses, are the anchor for interpreting what the Listing does and how it functions.

• Listing authority and statutory basis. The instrument is made under subsection 15(1) of the Charter of the United Nations Act 1945 (s 3). The instrument therefore asserts the domestic legal mechanism by which Australia implements certain Security Council decisions. The text repeats that the Listing is "made under subsection 15(1) of the Charter of the United Nations Act 1945" and records the Minister issuing the listing (front matter and ss 1-3).

• Standard of satisfaction. Section 4 records the Minister's mental standard: she is "satisfied on reasonable grounds" that the entities in Schedule 1 are those mentioned in paragraph 1(c) of UNSCR 1373 (2001). The instrument also directs the reader to regulation 20 of the Charters of the United Nations (Dealing with Assets) Regulations 2008 (Note 1) as the rule that requires the Minister's satisfaction. The particular phrasing "satisfied on reasonable grounds" is the operative evidential standard asserted by the instrument.

• Connection to an international instrument. The Listing explicitly states its purpose is "necessary to give effect to the decision of the United Nations Security Council in paragraph 1(c) of United Nations Security Council Resolution 1373 (2001)" (Schedule 1 header). The Listing therefore is presented as an implementation measure tied to a Security Council obligation.

• Identification of listed entities. Schedule 1 performs the identification function. It supplies a "Primary Name" for each entity, together with a non-exhaustive list of aliases and an address field. The two entries are: "Islamic State Somalia" (aliases and address: Puntland Region, Somalia) and "Jama'at Mujahideen Bangladesh" (aliases and address: Bangladesh). The instrument thereby defines the scope of the listing by these names and identifiers.

• Asset-related procedures and classifications. Schedule 2 sets out procedural options for persons or entities affected by a listing: a request for an unclassified statement of reasons, application for revocation, and application for a sanctions permit to use or deal with frozen assets or to make an asset available to a listed person. For asset dealings, the Listing requires applicants to specify whether the application relates to a "basic expense dealing, a contractual dealing or an extraordinary expense dealing" as defined in section 30 of the Regulations (Schedule 2). The Listing thereby signals that listed entities may have assets subject to freezing and that there exists a triage of permitted dealings governed by definitions in the Regulations.

• Administrative publication and transparency. Note 2 instructs that under regulation 40 of the Regulations, DFAT maintains and publishes a consolidated list of all section 15 listings on the internet at a specified URL (Note 2). The Listing therefore relies on an administrative mechanism for public disclosure and continuity of information beyond the Gazette instrument itself.

These are the primary, textually stated concepts in the Listing. The instrument does not itself restate operational details of the Act or Regulations beyond the references above; it functions as the ministerial declaration listing particular entities, and as a pointer to procedures and regulations that govern the consequences and follow-on processes.

The Listing identifies direct and indirect parties affected and provides the administrative channels available to those parties. The instrument does not purport to set out every legal consequence; instead it records identities and procedural access.

• Listed entities. The primary parties identified are the entities named in Schedule 1. Those names and associated aliases establish who is formally listed by this instrument: "Islamic State Somalia" (with a number of aliases including IS-Somalia, ISIS-Somalia, ISIL Somalia, ISS, among others, and an address indicated as Puntland Region, Somalia), and "Jama’at Mujahideen Bangladesh" (with aliases including, inter alia, Jamaat Mujahideen Bangladesh, Neo-JMB, ISIS Bangladesh, and an address indicated as Bangladesh). These entities are the subjects of the Minister’s satisfaction under s 15(1) of the Act (s 4; Schedule 1).

• Persons or entities holding or owning assets that may be frozen. Schedule 2 expressly contemplates "the owner or holder of a frozen asset" as an actor entitled to apply for permission to use or deal with that asset. The Listing therefore affects third parties who currently hold, possess, or control assets that are defined as frozen because of the listing of a person or entity.

• Anyone seeking to make an asset available to a listed person or entity. Schedule 2 states "Any person may apply for permission to make an asset available to a listed person or entity." That phrase captures potential lenders, counterparties or service providers who might otherwise be blocked by asset-freezing measures and who need a permit to proceed.

• The Minister for Foreign Affairs and the Department of Foreign Affairs and Trade (Australian Sanctions Office). The instrument is issued by the Minister (front matter and s 3). Schedule 2 directs requests and applications to the Director, Australian Sanctions Office, Department of Foreign Affairs and Trade, and to the Minister for revocation applications. Note 2 identifies DFAT as the agency maintaining the consolidated list. The Listing therefore implicates DFAT as the administering body and the Minister as the decision-maker for listings and revocations.

• Third parties who use the DFAT consolidated list for compliance. Note 2 directs users to DFAT’s consolidated list at the specified URL. Financial institutions, corporations, lawyers, accountants, compliance teams and journalists who use that consolidated list for screening and due diligence are implicated by the Listing’s publication.

• Potentially affected counterparties in jurisdictions outside Australia, to the extent they rely on Australian listings for screening. The instrument itself does not state extraterritorial effect; it does, however, create an Australian domestic listing which will be published on DFAT’s consolidated list.

The Listing does not itself state particular criminal penalties, licensing regimes or administrative sanctions within the text. It does, however, connect to asset-freeze and permit processes by reference to the Regulations and by naming permitted application routes. Therefore the immediate, concrete effects under the instrument are: persons named are placed on the Australian list; owners/holders of frozen assets and prospective counterparties must use the application mechanisms in Schedule 2 to seek permission for dealings; and DFAT and the Minister are the points of decision and administration.

The Listing identifies a small set of rights of listed persons and duties of the administering agency as expressed in the instrument. It does not restate the full package of duties and prohibitions that may derive from the Act or Regulations, but it sets out specific procedural rights and administrative duties.

Rights and procedural entitlements recorded in the Listing:

• Right to receive an unclassified statement of reasons. Schedule 2 states: "The Department of Foreign Affairs and Trade will provide a listed person or entity with an unclassified statement of reasons for his, her or its listing." The Listing then prescribes how requests may be submitted in writing to the Director, Australian Sanctions Office, or by email to ido@dfat.gov.au (Schedule 2). This is a procedural right to obtain an explanation in unclassified form.

• Right to apply for revocation. Schedule 2 gives a listed person or entity the right to apply to the Minister for Foreign Affairs to have the listing revoked. The application "must be in writing and set out the circumstances relied upon to justify the application" and must be submitted to the Minister via the Director, Australian Sanctions Office or by email. That creates a procedural channel and a minimal content requirement (set out the circumstances relied upon).

• Rights connected to asset permits. Schedule 2 permits "the owner or holder of a frozen asset" to apply for permission to use or deal with the asset and permits "any person" to apply for permission to make an asset available to a listed person or entity. The frozen-asset application must, where relevant, specify whether the application relates to a "basic expense dealing, a contractual dealing or an extraordinary expense dealing", as defined in section 30 of the Regulations.

Duties and administrative obligations implicated by the Listing:

• Minister’s satisfaction. The Minister records she is "satisfied on reasonable grounds" that the listed entities fall within paragraph 1(c) of UNSCR 1373 (s 4). The source also notes that under regulation 20 of the Regulations the Minister must be satisfied of the reference in para 1(c). That is an administrative constraint on the listing power, requiring a stated standard of satisfaction.

• DFAT’s publication duty. Note 2 states that under regulation 40 of the Regulations DFAT "maintains a list of all persons, entities, assets and classes of assets currently listed under section 15 of the Act" and has published this list at the specified URL. The Listing therefore records DFAT’s duty to maintain and publish consolidated listing information.

• Application formality requirements. Schedule 2 requires that requests for reasons, applications for revocation, and applications for a sanctions permit "must be in writing" and provides the postal and email addresses for submission. For frozen-asset permit applications, the Listing requires specification of the dealing type per section 30 of the Regulations. These are minimum formal requirements imposed on applicants.

What the Listing does not itself say about duties and prohibitions:

• The Listing does not restate the substantive prohibitions, criminal offences, or specific asset-freeze mechanics enacted by the Act or Regulations. It does not set out reporting duties, compliance obligations for banks, or enforcement procedures. Those particulars would be found in the Act and the Dealing with Assets Regulations, but they are not reproduced in this Listing.

In sum, the instrument records procedural rights (reasons, revocation application, permit application), sets minimal formal requirements for those procedures, and records the Minister’s threshold of satisfaction and DFAT’s obligation to publish the consolidated list. It leaves the enforcement and detailed operational duties to the underlying legislative and regulatory framework to which it refers.

The Listing itself contains no express statement of penalties, criminal sanctions, or a detailed enforcement regime. The instrument is a ministerial declaration that lists particular entities and sets out administrative routes for reasons, revocation and asset-dealing permits; it does not attempt to specify sanctioning penalties within the Gazette text.

What the Listing does make clear about enforcement-related matters:

• Asset freezing and permits are contemplated. Schedule 2 repeatedly refers to "frozen assets" and to applications for permission "to use or deal with the asset" or to "make an asset available to a listed person or entity." The presence of those application routes implies a regulatory framework in which assets of listed persons or entities can be frozen, but the Listing does not itself specify the mechanics of freezing, the immediate legal prohibition on dealing, or the sanctions for breach. Those operational elements will be defined in the Act and in the Charter of the United Nations (Dealing with Assets) Regulations 2008 (the Regulations). The Listing references s 30 of the Regulations for categorisation of dealings and regulations 20 and 40 for evidential and publication matters (Notes 1 and 2; Schedule 2). The Listing thereby points to the Regulations as the locus of operational detail.

• Administrative decision-makers. The Listing identifies the Minister for Foreign Affairs as the listing decision-maker (front matter, s 3) and the Director, Australian Sanctions Office as the administrative contact for requests and applications (Schedule 2). This places responsibility for applying or considering exemptions, revocation requests, or permits with DFAT and ultimately with the Minister.

• No penalty provisions in the Listing. Because the Listing does not state specific criminal offences, pecuniary penalties, or infringement processes, it leaves enforcement consequences to the Act and the Regulations. Readers must look to those primary instruments for the exact penal regime.

Implications for affected parties derived from the instrument:

• Third parties who hold or deal with assets designated as frozen will need to use the permit application processes identified in Schedule 2 to seek permission to continue specified dealings. The Listing requires written applications and the specifying of the dealing category when a frozen-asset application is lodged, which frames the procedural pathway to obtain relief from freezing measures.

• The absence of penalty text in the Listing creates an evidential gap in this instrument itself: the Listing does not describe the immediate legal consequences of a failure to obtain a permit or to comply with an asset-freeze, nor does it specify enforcement powers such as seizure, forfeiture, restraint, or criminal prosecutions. Those matters are therefore carried in the Act and Regulations and are not part of this Gazette instrument.

For practitioners and compliance officers, the Listing is an identification and procedural instrument. It signals that enforcement mechanisms (including freezing and the need for permits) exist and that DFAT is the administering agency, but it does not supply the statutory language of offences or penalties. Users of the Listing must consult the Charter of the United Nations Act 1945 and the Dealing with Assets Regulations 2008 for the precise enforcement provisions that the Listing operates within.

The Listing, by its own terms, is an implementation instrument that interacts directly with a limited set of named instruments and with the broader domestic regime established by the Act and the Regulations. Its text states the cross-references it relies on.

Direct textual cross-references:

• Charter of the United Nations Act 1945. The Listing is expressly made under subsection 15(1) of that Act (s 3). The listing itself therefore depends on the statutory authority conferred by the Act to list persons, entities or assets to give effect to United Nations Security Council decisions. The Listing does not reproduce subsection 15(1), but the instrument records the legislative locus of its authority.

• Charter of the United Nations (Dealing with Assets) Regulations 2008. The Listing cites two provisions of those Regulations by number: regulation 20 and regulation 40 (Notes 1 and 2). It also references section 30 in Schedule 2 when prescribing the need for applicants to specify whether a frozen-asset application relates to a basic expense, contractual, or extraordinary expense dealing. These references indicate the Listing is embedded in the regulatory scheme governing asset deals, the Minister's satisfaction standard, and DFAT's publication duties.

• United Nations Security Council Resolution 1373 (2001). The Listing repeatedly ties its purpose to paragraph 1(c) of UNSCR 1373 (2001). Section 4 expressly states the Minister’s satisfaction relates to paragraph 1(c) of the Resolution, and Schedule 1 asserts the listing of the named entities is "necessary to give effect to the decision" in that paragraph. The Listing thus operates as a domestic implementation measure for a Security Council decision.

What the Listing does not do in relation to other laws:

• It does not purport to displace, amend or restate the text of the Act or the Regulations. The Listing is narrowly an executive instrument effecting particular listings; it leaves the statutory duties, prohibitions, offences and enforcement mechanisms to the underlying statutory and regulatory texts.

• It does not reference other domestic statutes, such as financial services, anti‑money-laundering or criminal codes, within the Gazette text. The instrument’s cross-references are confined to the Act, the Dealing with Assets Regulations, and UNSCR 1373 (2001).

Operational interaction inferred from the text:

• Publication and compliance. Note 2 directs readers to DFAT’s consolidated list maintained under regulation 40 of the Regulations, with an explicit URL. That publication is the mechanism by which other domestic regulatory regimes, financial institutions, and private actors will know that an entity is listed for the purposes of screening and compliance. The Listing therefore interacts procedurally with other laws and private compliance systems by feeding into the consolidated list DFAT maintains.

• Administrative procedure and standards. The Listing’s reference to the Minister being "satisfied on reasonable grounds" and to the Regulations for dealing with assets indicates that decisions about listings, revocations and permits are to be made within a statutory-procedural matrix. The Listing operates as one decision within that matrix and must be understood together with the Act and the Regulations for full legal effect.

In short, the Listing functions as a node in a small network of instruments: it uses the Act for authority, the Regulations for procedural and definitional detail (notably asset-dealing categories and DFAT’s publication duty), and an identified UNSC resolution as the international obligation being implemented. The precise legal consequences for third parties depend on the content of the Act and the Regulations, which the Listing references but does not reproduce.

The instrument provides limited metadata on its own origins and gives no record of prior amendment other than its title. The text supplies the following points relevant to amendment history:

• Instrument title and date. The listing is named "Charter of the United Nations Act 1945 Listing (No. 2) 2020" (s 1) and is dated 15 January 2021 in the signature block signed by the Minister for Foreign Affairs. The title indicates it is the second listing instrument in the 2020 series, but the Gazette text itself does not include any history of earlier versions of this specific instrument.

• Commencement. Section 2 states the Listing "commences on gazettal." That fixes the commencement rule for this instrument: its legal effect begins when gazetted. The instrument does not supply the gazettal date beyond the signature date that appears in the instrument; it does not provide an expiry date or specified sunset clause.

• No textual amendments recorded within the instrument. The Listing contains no schedule or section that purports to amend or repeal any prior listings or instruments. It simply declares the new listing. There is no clause that rescinds earlier listings, modifies other instruments, or purports to amend the Act or the Regulations.

• Built-in revocation pathway. Schedule 2 describes a mechanism for a listed person or entity to apply to the Minister for revocation of the listing. That is a forward-looking administrative remedy available to listed persons; it is not an amendment history in the sense of recorded past amendments, but it establishes the domestic process through which the listing could be changed or removed.

• References to earlier regulatory instruments. The Listing’s title and cross-references imply it is part of a sequence of domestic actions taken under the Act and Regulations, but the text does not enumerate previous listings or amendments to the Act or Regulations. Note 2 indicates DFAT maintains a consolidated list of all persons, entities, assets and classes of assets currently listed under section 15 of the Act. That DFAT consolidated list is the place where a user would expect to find the chronological record or current status of listings; the instrument itself does not duplicate that history.

Consequently, as an historical record in the Gazette, the Listing is a single, dated ministerial action that takes effect on gazettal and provides no further internal amendment history. Any later amendment or revocation of this listing would be effected by a subsequent ministerial listing or instrument and would similarly be recorded in the Gazette and in the DFAT consolidated list. Readers seeking a sequence of changes or prior listings will need to consult DFAT’s consolidated list (Note 2) or subsequent/preceding Gazette notices; this particular instrument contains only the entry it creates and the procedural channels for seeking revocation.

The Listing contains no references to litigation, court decisions, or other adjudicative outcomes. It does not mention any judicial review proceedings, court challenges, or case law. The text is limited to the ministerial decision to list, the identity of the listed entities, and the administrative procedures available to listed persons or affected parties.

What the Listing records that is relevant to potential litigation pathways:

• Procedural entitlements that could give rise to administrative law issues. Schedule 2 provides for written requests for an unclassified statement of reasons and for written applications for revocation, and it prescribes submission channels (Director, Australian Sanctions Office and a ministerial route). Those procedural entitlements are the typical administrative steps that a person challenging a listing would be expected to exhaust or reference when seeking judicial review. The Listing’s specification that reasons will be provided in an unclassified form and that revocation applications must "set out the circumstances relied upon" establishes a minimum administrative process recorded in the instrument.

• Ministerial satisfaction standard. Section 4 records the Minister's satisfaction "on reasonable grounds" that the named entities are within paragraph 1(c) of UNSCR 1373 (2001). That articulation of the decision-maker’s standard is the factual predicate of a listing decision that could be challenged on administrative law grounds, such as failure to take into account relevant matters or lack of procedural fairness. This Listing does not itself provide records of any such challenges.

• No judicial outcomes cited. The Listing does not cite any precedents, nor does it report on prior litigation or tribunal decisions. It is therefore silent as to whether any prior or subsequent legal challenges have occurred against this listing or similar ones.

For readers interested in litigation history related to this or similar listings, the Listing points to DFAT’s consolidated list and the administrative contacts for reasons and revocation applications (Schedule 2). Any existing judicial review proceedings or appeals would not be recorded in this Gazette notice; they would appear in court records or public reporting of litigation. The Listing itself contains no litigation narrative or case references.

The Listing contains a few features, phrasing choices and references that create practical points of attention for practitioners, compliance officers and listed persons. These points are grounded in the instrument’s text and should be noted for operational use.

• "Satisfied on reasonable grounds" is the stated test. Section 4 records the Minister is "satisfied on reasonable grounds" that the Schedule 1 entities are within paragraph 1(c) of UNSCR 1373 (2001). That specific wording is the evidential standard the Minister uses in this Listing. Practitioners should note that the Listing invokes that standard; Schedule 2 provides for a request for an unclassified statement of reasons that will likely bear on how the Minister reached that standard. The Listing does not elaborate what material was relied on to reach satisfaction.

• The Listing does not set out prohibitions or penalties. The instrument contemplates frozen assets and permits, but it does not itself define what counts as a frozen asset, what dealings are prohibited, or what criminal or civil penalties may attach for non‑compliance. Those elements are referenced to the Act and the Dealing with Assets Regulations 2008, not stated here. Users must therefore consult the underlying statutory instruments to understand immediate legal prohibitions and penalties.

• Applications must be in writing and sent to specified addresses. Schedule 2 repeatedly requires that requests and applications "must be in writing" and supplies both a postal address and an email address (aso@dfat.gov.au). That is a low-threshold formality but one that practitioners must adhere to; informal phone enquiries or in-person submissions are not authorised by the Listing text.

• Asset-dealing applications must specify the dealing type per s 30 of the Regulations. Schedule 2 requires an applicant for a permit concerning a frozen asset to "specify whether the application relates to a basic expense dealing, a contractual dealing or an extraordinary expense dealing as those terms are defined in section 30 of the Charter of the United Nations (Dealing with Assets) Regulations 2008." The Listing therefore imports definitional detail from the Regulations; failure to identify the correct category in the written application could affect consideration. The Listing does not define these categories itself.

• The Listing provides aliases and addresses but no unique identifiers. Schedule 1 lists "Primary Name", "Aliases", and "Address" for each entity. Practitioners should note that the aliases list may not be exhaustive and that the addresses are broad (e.g. "Bangladesh", "Puntland Region, Somalia"). For screening purposes, reliance purely on the listed strings may miss variants; conversely, strings may capture unrelated persons with similar names. The Listing does not provide other unique identifiers such as registration numbers, dates of birth, corporate identifiers, or international reference numbers.

• Publication is via DFAT consolidated list. Note 2 informs users that DFAT maintains and publishes a consolidated list under regulation 40 of the Regulations, at a specified URL. Practitioners should not rely solely on the Gazette notice for ongoing compliance; the consolidated list is the operational register that will be updated as listings are added, amended or revoked. The Listing itself is a snapshot that commences on gazettal.

• The instrument is silent on timing and processing of applications. While Schedule 2 prescribes how to make applications (in writing, to an address/email), it does not state any statutory timeframes for decision-making, any fees, or any conditions attaching to permits. That procedural absence is material for time-sensitive transactions involving frozen assets.

• The instrument labels itself "(No. 2) 2020" but dated 15 January 2021. The title suggests it is part of the 2020 series; the signature block is dated 15 January 2021. Practitioners should confirm the gazettal date and consult DFAT’s consolidated list to establish the operative date for compliance obligations.

These are not speculative risks; they are practical points that flow from the Listing’s text and omissions. Each is relevant for parties screening for listed entities, preparing applications for permits or revocation, or advising clients who may be affected by the listing.

The Listing lays down a limited set of procedural steps and contacts that constitute the compliance pathways it creates. The following are concrete actions based on the instrument’s text and procedural prescriptions.

1. Confirm whether an entity is listed and check aliases and address fields.

   • Consult Schedule 1 of the Listing for the exact "Primary Name" and the list of aliases for each listed entity. The Listing provides aliases for "Islamic State Somalia" and "Jama’at Mujahideen Bangladesh," and gives broad address fields (Puntland Region, Somalia; Bangladesh).
   • For operational screening, follow Note 2 and check DFAT’s consolidated list at the URL supplied in the Listing for the authoritative and current register of all section 15 listings. The Listing itself is a gazetted entry; the DFAT consolidated list is where ongoing updates will appear.

2. If you are a listed person or entity and you need reasons or want to apply for revocation, submit written materials to DFAT.

   • To obtain an unclassified statement of reasons, send a written request to the Director, Australian Sanctions Office, Department of Foreign Affairs and Trade at the postal address given in Schedule 2, or by email to aso@dfat.gov.au. The Listing states DFAT will provide an unclassified statement of reasons to a listed person or entity.
   • To apply for revocation, submit a written application to the Minister for Foreign Affairs, c/o the Director, Australian Sanctions Office, Department of Foreign Affairs and Trade (postal or email as above). The Listing requires the application to "set out the circumstances relied upon to justify the application." Ensure the submission clearly identifies the listed name, the grounds relied upon, and any supporting documentary material.

3. If you hold a frozen asset or wish to make an asset available, prepare a written application for a sanctions permit.

   • The owner or holder of a frozen asset may apply for permission to use or deal with the asset in a specified way. Any person may apply to make an asset available to a listed person or entity (Schedule 2).
   • For frozen-asset applications, the Listing requires that the application "specify whether the application relates to a basic expense dealing, a contractual dealing or an extraordinary expense dealing" as defined in section 30 of the Regulations. Therefore, identify which of those categories (per s 30) your application falls under and state it explicitly in the written submission.
   • Submit the application in writing to the Director, Australian Sanctions Office (postal address or email aso@dfat.gov.au). The Listing does not indicate a prescribed form, fee or decision timeframe; include full details of the asset, the proposed dealing, identity of the parties, and any legal arguments or contractual obligations that support the requested permit.

4. Use the DFAT consolidated list as the primary operational register for screening and compliance.

   • Note 2 indicates DFAT maintains a consolidated list under regulation 40 of the Regulations and publishes it online. For continuous compliance screening in banking, trade, contracting, or fund management activities, incorporate the DFAT consolidated list into screening processes rather than relying solely on individual Gazette notices.

5. Respect the formal requirements the Listing prescribes.

   • All requests and applications under Schedule 2 "must be in writing." Use the postal and email addresses given to ensure the submission complies with the formal requirement in the Listing.
   • When applying for reasons, revocation or a permit, explicitly identify the instrument (this Listing), the listed name under which you are seeking relief, and the contact details of the applicant.

6. If advising clients, record the limits of the Listing’s content and the need to consult the Act and Regulations.

   • The Listing does not itself spell out the prohibitions, sanctions or timeframes. Proper legal advice or compliance work should reference the Charter of the United Nations Act 1945 and the Charter of the United Nations (Dealing with Assets) Regulations 2008 to determine immediate legal prohibitions, potential offences, and the full decision-making framework for permits or revocations. The Listing points to those instruments by citation but does not reproduce their operative language.

7. Keep documentary records of all submissions and communications with DFAT.

   • Because the Listing provides only postal and email submission routes and does not prescribe processing times or forms, maintain thorough documentation of any application or request made under Schedule 2. This is a practical compliance step grounded in the Listing’s silence on procedural timing and formality.

These steps flow directly from the Listing’s text. Practitioners should treat the Listing as creating listing status and procedural routes but must consult the Act and the Regulations for the precise obligations, prohibitions, and potential penalties that govern conduct in relation to listed persons, entities and frozen assets.