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5 Law, Tech. & Hum. 165 (2023)
Automating Sanctions Compliance: Aligning Regulatory Technology, Rules and Goals

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Volume  5 (2) 2023


LAW,  TECHNOLOGY AND HUMANS
https://doi.org/10.5204/thj.2506


Automating Sanctions Compliance: Aligning


Regulatory Technology, Rules and Goals



Oliver Hackney
Australia
Anna  Huggins
Queensland University of Technology, Australia



Abstract


Keywords: Sanctions regulation; compliance; RegTech; automation.


1.  Introduction


The raft of sanctions introduced by governments throughout the world in response to the Russia-Ukraine conflict and other
situations of international concern underscore the importance of compliance with sanctions regulations. In the Australian
regulatory context, for example, the Federal Government has adopted a broad sanctions package in response to the Russia-
Ukraine conflict, including targeted financial sanctions and travel bans against Russian military personnel, oligarchs, key
government  officials, members of the Russian Security Council, key financial institutions, pro-Kremlin propagandists,
Belarusian military and government personnel, and organisations involved in the supply of weaponry to Russia or surveillance
technology used to persecute protestors.1 These sanctions sit alongside 23 other active sanctions regimes the Australian
Government  has imposed  in response to situations of international concern.2 This recent spate of activity highlights the
expanding sanctions regulatory requirements and the need for organisations to adapt their compliance approaches to satisfy the
evolving legal requirements.


The authors gratefully acknowledge the helpful comments of the anonymous reviewers and the funding received from the Human Technology
Law Centre at Queensland University of Technology.
1 See Autonomous Sanctions Amendment (Russia) Regulations 2022 (Cth); Autonomous Sanctions Amendment (Ukraine Regions) Regulations
2022 (Cth); Autonomous Sanctions (Designated Persons and Entities and Declared Persons Russia and Ukraine) List 2014 (Cth);
Autonomous Sanctions (Import Sanctioned Goods Russia) Designation 2022 (Cth); Autonomous Sanctions (Export Sanctioned Goods
Russia) Designation 2022 (Cth). The Russian Government has also imposed sanctions on Australian military personnel, journalists,
academics and business officials accused of furthering Australia's 'anti-Russia policy line': Ministry of Foreign Affairs of the Russian
Federation, Foreign Ministry Statement.
2 Department of Foreign Affairs and Trade, Australia and Sanctions.

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                 Licence. As an open access journal, articles are free to use with proper attribution. ISSN: 2652-4074 (Online)


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© The Author/s 2023