Notice of Changes to the Consolidated List – 2 June 2026
DFAT updated the Consolidated List on 2 June 2026 to reflect the following changes:
- The addition of three persons and four entities subject to targeted financial sanctions, and the declaration of travel bans for the individuals as per the Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Thematic Sanctions) Amendment (No. 1) Instrument 2026 – Federal Register of Legislation
The previous notice incorrectly linked to a previous instrument. Please disregard.
The updated Consolidated List can be downloaded from the following page: Consolidated List | Australian Government Department of Foreign Affairs and Trade.
Guidance on how to interpret the Consolidated List can be found here: Guide to Australia’s Consolidated List | Australian Government Department of Foreign Affairs and Trade
If you have any queries, please contact the Australian Sanctions Office atsanctions@dfat.gov.au.
Australian Sanctions Office
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Australian Sanctions Office | Regulatory and Legal Policy Division
Department of Foreign Affairs and Trade
Category: Thematic Sanctions
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OFFICIAL
Notice of Changes to the Consolidated List – 2 June 2026
DFAT updated the Consolidated List on 2 June 2026 to reflect the following changes:
- The addition of three persons and four entities subject to targeted financial sanctions, and the declaration of travel bans for the individuals as per the Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Thematic Sanctions) Amendment (No.3) Instrument 2025.
The updated Consolidated List can be downloaded from the following page: Consolidated List | Australian Government Department of Foreign Affairs and Trade.
Guidance on how to interpret the Consolidated List can be found here: Guide to Australia’s Consolidated List | Australian Government Department of Foreign Affairs and Trade
If you have any queries, please contact the Australian Sanctions Office atsanctions@dfat.gov.au.
Australian Sanctions Office
_______________________________
Australian Sanctions Office | Regulatory and Legal Policy Division
Department of Foreign Affairs and Trade
What are thematic sanctions? Claude explains:
Australia’s Thematic Sanctions: A Plain-Language Guide
What Are “Thematic” Sanctions, and Why Do They Matter?
Most people think of sanctions as being tied to a specific country — Australia restricts dealings with Russia, Iran, or North Korea. Those are country-specific sanctions, and Australia has plenty of them.
But since December 2021, Australia has had a second, fundamentally different type: thematic sanctions. Instead of targeting a country, thematic sanctions target a type of behavior — no matter where in the world that behavior happens.
Unlike country-specific autonomous sanctions, thematic autonomous sanctions do not require sanctionable conduct to have a particular geographic nexus. In plain terms: if someone in Japan, Brazil, or the United States does something that falls under a thematic category, Australia can potentially sanction them. The offending conduct, not the person’s nationality or location, is what triggers eligibility.
This is a significant expansion of Australia’s toolkit. Before 2021, Australia could only sanction someone if their behavior was connected to a specific designated country or situation. Now it can act against individuals and organizations anywhere in the world — provided the conduct fits the theme.
The Legal Foundation
Australia’s sanctions system rests on two main laws:
- The Autonomous Sanctions Act 2011 — the primary legislation giving the government the power to create sanctions regimes
- The Autonomous Sanctions Regulations 2011 — the subordinate rules that set up individual regimes and list designated persons
The thematic powers were added by the Autonomous Sanctions Amendment (Magnitsky-style and Other Thematic Sanctions) Act 2021, which commenced on 8 December 2021 and amended the Autonomous Sanctions Act to ensure that autonomous sanctions regimes can be either country-specific or thematic.
The law takes its popular name from Sergei Magnitsky, a Russian tax lawyer who was detained and died in custody after exposing a massive corruption scheme. His case inspired a global movement of targeted sanctions laws designed to hold corrupt officials and human rights abusers personally accountable — freezing their assets and banning them from travel — rather than punishing entire countries.
Three Active Thematic Regimes
The Act includes an illustrative list of themes that sanctions can address: proliferation of weapons of mass destruction; threats to international peace and security; malicious cyber activity; serious violations or serious abuses of human rights; activities undermining good governance or the rule of law, including serious corruption; and serious violations of international humanitarian law.
Three of these themes have been converted into active regulatory regimes, meaning the government can now designate specific individuals and entities under them.
1. Human Rights Sanctions
This is Australia’s flagship thematic regime and the one that has been used most actively.
The regulations allow the Minister to impose sanctions on a person or entity the Minister is satisfied has committed a serious violation or serious abuse of one of the specified rights.
What counts? The framework covers abuses of internationally recognized rights — things like torture, arbitrary detention, extrajudicial killing, and enforced disappearances. Importantly, it’s not just perpetrators who can be targeted: those who facilitate, finance, or profit from serious abuses are also potentially in scope.
While there is increased utilization of these sanctions in relation to human rights violations in the Israel–Palestine conflict, there has been a notable drop-off in any usage in relation to corruption, with the last set of still-in-force corruption sanctions dating back to 2022.
Real-world examples: Australia’s first thematic designations honored Sergei Magnitsky himself — the government imposed targeted sanctions and travel bans against 14 Russian individuals responsible for the serious corruption he exposed and a further 25 Russian perpetrators and accomplices of his abuse and death. More recently, Australia has used human rights sanctions in response to the situation in the West Bank.
2. Corruption Sanctions
Australia established a thematic autonomous sanctions regime in relation to serious corruption on 21 December 2021. Unlike a country-specific autonomous sanctions regime, a thematic autonomous sanctions regime applies to sanctionable conduct wherever it occurs in the world.
The application of sanctions under the thematic corruption sanctions framework is reserved for the most serious acts of corruption. Examples of sanctionable conduct include (but are not limited to): serious corruption which results in a country’s population being deprived of vital public resources; the misappropriation of state property of significant value as part of a systemic fraudulent scheme.
This isn’t meant to catch ordinary commercial bribery or run-of-the-mill fraud. Think kleptocracy — officials who loot public resources on a grand scale, or those who systematically exploit state power for personal enrichment in ways that harm whole populations.
A practical note: the Minister may only list a person or entity if satisfied, based on all relevant matters with regard to the facts and circumstances of each case, the person or entity meets the listing criteria in the Regulations. The Minister then exercises a discretion whether to list or not in the context of Australia’s overall national interest. That “national interest” qualifier is meaningful — Australia doesn’t operate its sanctions in isolation, and geopolitical considerations shape how actively this regime is used.
3. Cyber Sanctions
Australia established a thematic autonomous sanctions framework in relation to significant cyber incidents on 21 December 2021. Unlike a country-specific autonomous sanctions framework, a thematic autonomous sanctions framework applies to sanctionable conduct wherever it occurs in the world.
This regime targets individuals and organizations behind major malicious cyber operations — attacks on critical infrastructure, large-scale data theft, ransomware operations affecting essential services, and similar incidents. The target can be a state-backed hacker group, a criminal syndicate, or an individual operator.
In February 2025, the Minister for Foreign Affairs announced further cyber sanctions in response to the Medibank Private cyberattack. Medibank was a major Australian health insurer whose data was stolen and published by a Russian-linked ransomware group — the designation was a direct, named response to a specific incident affecting Australian citizens.
What Sanctions Measures Actually Look Like
Being designated under a thematic regime means two things:
Targeted financial sanctions (asset freeze): Any assets the designated person or entity holds in Australia — bank accounts, property, investments — are frozen. Australians and Australian entities are prohibited from making assets available to the designated person. This covers direct and indirect dealings.
Travel ban: Designated individuals are prohibited from entering Australia.
Both measures are listed on Australia’s Consolidated List, maintained by the Department of Foreign Affairs and Trade (DFAT). The Consolidated List covers all Australian sanctions designations — UN-mandated, country-specific, and thematic alike — in one searchable database.
Who Runs This?
Two government bodies share responsibility:
DFAT (Department of Foreign Affairs and Trade) manages the overall sanctions policy, maintains the Consolidated List, and handles licensing (permits for otherwise-prohibited activity in limited circumstances).
The Australian Sanctions Office (ASO), which sits within DFAT and was established on 1 January 2020, is Australia’s dedicated sanctions regulator. It handles compliance monitoring, enforcement, and public guidance.
Designations are formally made by the Minister for Foreign Affairs, who must be satisfied on the evidence that listing criteria are met — and must then exercise discretion to list (or not) based on Australia’s national interest.
In Practice: How Actively Has Australia Used These Powers?
Candidly, not as aggressively as some advocates have hoped. There continues to be a steady but minimal use of Magnitsky-style sanction instruments since the introduction of the regulations in December 2021, with Australia incrementally using these powers more throughout 2024, with five of the nine instruments being issued between November 2023 and June 2024.
Australia’s sanctions regime over the first six months of 2025 has been squarely utilized in relation to Russia (85.78%) and the remainder peppered towards ISIL (Da’esh) and Al-Qaida, UN 1373 (2001), and Magnitsky-style sanctions.
The thematic programs exist and are operative — but the bulk of Australia’s day-to-day sanctions activity remains Russia-focused country-specific designations.
What’s Changing: An Active Review Period
Australia’s thematic sanctions framework has been under significant scrutiny. Multiple reviews have recently concluded, including DFAT’s “Review of Australia’s Autonomous Sanctions Framework” (commenced January 2023, concluded October 2024), a Defence and Trade References Committee review on Australian support for Ukraine, a Foreign Affairs, Defence and Trade Reference Committee inquiry into Australia’s sanctions regime, and a Human Rights Subcommittee review specifically of the thematic sanctions framework — providing a starting point for an array of potential legal and policy changes.
With a $26.4 million boost in DFAT’s sanctions compliance monitoring and enforcement budget in 2024–25, employing robust compliance programs is now more important than ever.
Reform recommendations are on the table. Legislative changes are under government consideration. This is a framework in active development, not a settled system.
What This Means for Compliance
If your organization operates internationally — in trade, financial services, professional services, or supply chains — here’s the practical takeaway:
Screen against the Consolidated List. All thematic designees appear there alongside country-specific targets. There’s no separate list to check; one database covers everything.
Geographic blind spots can still bite you. Because thematic sanctions have no country nexus requirement, a counterparty in a jurisdiction not subject to country-specific Australian sanctions could still be designated if they’re implicated in human rights abuses, corruption, or a major cyber incident.
Watch for allied coordination. Australia increasingly aligns its thematic designations with the US, UK, and EU. The Australian Government is expected to continue to align some of these sanctions measures with policy decisions of other key jurisdictions. A multilateral action often signals that Australia will follow — sometimes simultaneously.
Enforcement is tightening. The budget increase and the attention from multiple parliamentary inquiries signal that the Australian Sanctions Office is building toward more active compliance monitoring. Internal sanctions programs that were adequate in 2022 may need updating.
This guide reflects the framework as of mid-2025 through early 2026. Given ongoing government reviews and anticipated legislative reforms, practitioners should monitor DFAT’s sanctions website for updates.