We previously discussed the Ukraine-related sanctions measures in Australia on February 23, February 25, March 1 and March 15. Since then, Australia has extended its sanctions to designate additional individuals and Russian financial institutions.

On 17 March 2022, Australia designated 11 additional Russian financial institutions on the basis “that each entity is, or has been, engaging in an activity or performing a function that is of economic or strategic significance to Russia”.[1] These institutions include:

  • The Russian National Wealth Fund and Russian Ministry of Finance. The Australian Foreign Minister announced that the addition of these entities means that “Australia has now targeted all Russian government entities responsible for issuing and managing Russia’s sovereign debt.”[2]
  • Russia’s two largest lenders, Sberbank and VTB Bank, both of which are subject to certain sanctions announced by the US and UK in late February.

The Australian designations take effect on 18 March 2022. This contrasts with the position in other jurisdictions such as the UK, which has introduced a wider spectrum of sanctions in respect of financial institutions, including asset freezes in relation to some banks and correspondent banking restrictions in relation to others. Certain general licences have also been issued permitting some wind-down of transactions in relation to certain institutions. This reinforces the need for businesses to consider the specific sanctions currently in place across each relevant sanctions regime.

Australia also designated 2 Russian oligarchs who “play key roles in Russian entities in the energy sector and support the Russian Government in furtherance of its economic and strategic priorities”. The Australian Foreign Minister stated that the oligarchs were “two billionaires with links to business interests in Australia.”[3] The designations against these individuals also take effect on 18 March 2022.