How do I screen a client against Australian sanctions lists?

Sanctions screening is a legal obligation separate from — but closely linked to — your AML/CTF customer due diligence. Dealing with a sanctioned person or entity exposes your firm to serious criminal liability, regardless of whether you knew they were sanctioned.

Which lists do I need to screen against?

• Australian Sanctions Office (ASO) list: Maintained by the Department of Foreign Affairs and Trade (DFAT), this is the primary list for Australian law. It includes autonomous Australian sanctions and those imposed under UN Security Council resolutions. Available at dfat.gov.au
• United Nations Security Council consolidated list: All UN member states are required to implement UNSC sanctions. This list overlaps significantly with the ASO list but should be checked independently
• OFAC SDN list (where relevant): If you have US-connected clients, transactions in USD, or US correspondent bank relationships, screening against the US Office of Foreign Assets Control (OFAC) Specially Designated Nationals list is strongly recommended

When to screen

Screening must occur at two stages:

• Onboarding: Before providing any designated service to a new client
• Ongoing: At regular intervals throughout the relationship, and whenever there is a new sanction designation relevant to your client population (lists are updated frequently — sometimes daily)

What to do on a match

If a client matches a sanctions listing, you must not deal with them. This means freezing any assets you hold for them and not providing any services. You must report the match to AUSTRAC and to DFAT. You must not tip off the client that they have been identified. Seek legal advice immediately — sanctions obligations are strict liability and there is no 'de minimis' exception.

Documenting your screening

Every screening check — including the date, the list version used, and the result — must be documented and retained for seven years. AUSTRAC and DFAT may request evidence that you screened clients on specific dates.