Document Feedback - Review and Comment

Step 1 of 4: Comment on Document

How to make a comment?

1. Use this Protected Document to open a comment box for your chosen Section, Part, Heading or clause.

2. Type your feedback into the comments box and then click "save comment" button located in the lower-right of the comment box.

3. Do not open more than one comment box at the same time.

4. When you have finished making comments proceed to the next stage by clicking on the "Continue to Step 2" button at the very bottom of this page.


Important Information

During the comment process you are connected to a database. Like internet banking, the session that connects you to the database may time-out due to inactivity. If you do not have JavaScript running you will recieve a message to advise you of the length of time before the time-out. If you have JavaScript enabled, the time-out is lengthy and should not cause difficulty, however you should note the following tips to avoid losing your comments or corrupting your entries:

  1. DO NOT jump between web pages/applications while logging comments.

  2. DO NOT log comments for more than one document at a time. Complete and submit all comments for one document before commenting on another.

  3. DO NOT leave your submission half way through. If you need to take a break, submit your current set of comments. The system will email you a copy of your comments so you can identify where you were up to and add to them later.

  4. DO NOT exit from the interface until you have completed all three stages of the submission process.


Interim International Sanctions Compliance Policy

Section 1 - Introduction

(1) International sanctions are non-military measures imposed by Australia on other countries in situations of international concern. Sanctions aim to limit adverse consequences of the situation, influence behaviour and penalise those responsible.

(2) There are two sanctions regimes in Australia – the United Nations Security Council (UNSC) sanctions regime and the Autonomous Sanctions Regime. These are given effect through various laws that prohibit, amongst other things:

  1. dealing with ‘designated persons or entities’;
  2. supplying export-sanctioned goods to sanctioned countries; and
  3. providing technical advice, assistance or training that assists with the manufacture or use of ‘export sanctioned goods' in a sanctioned country or on behalf of a person or entity in the sanctioned country.

(3) This policy must be read in conjunction with any procedures which support this policy.

Top of Page

Section 2 - 1 Policy Scope


(4) This policy covers University compliance with the following: –

  1. Autonomous Sanctions Act 2011 (Cth) and subordinate legislative instruments;
  2. Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Regulations 2008, (regulations 7 and 8);
  3. Charter of the United Nations Act 1945 (Cth) and subordinate legislative instruments;
  4. Customs Act 1901 (Cth), Customs (Prohibited Exports) Regulations 1958 and the Defence and Strategic Goods List - November 1996.

(5) Other related legislative frameworks include:

  1. Crimes (Biological Weapons) Act 1976 (Cth);
  2. Chemical Weapons (Prohibition) Act 1994 (Cth);
  3. Defence Trade Controls Act 2012 (Cth);
  4. Weapons of Mass Destruction Act (Prevention of Proliferation Act) 1995 (Cth).
Top of Page

Section 3 - 2 Policy Intent

(6) This policy will ensure the University takes reasonable precautions, and exercises due diligence, to avoid contravening Australian Sanctions Laws.

Top of Page

Section 4 - Policy Provisions/Principles

General Principles

(7) University will take reasonable precautions and exercise due diligence to avoid contravening a sanctions measure or a condition of a sanctions permit.

(8) Risk Management – The University will apply a risk-based approach to compliance with Australian Sanctions Laws. Compliance actions in relation to an activity will be proportionate to the risk of the activity breaching the laws. The University will consult the Department of Foreign Affairs and Trade (DFAT) about any proposed high-risk action prior to taking the action. Where DFAT advice indicates the action may breach an Australian Sanctions Law, the University will seek a sanctions permit for the action.

(9) University will not deal with ‘designated persons or entities' under Australian Sanctions Laws, unless authorised to do so by a sanctions permit.

(10) University will not supply export-sanctioned goods unless authorised to do so by a sanctions permit.

(11) University will not provide sanctioned services, unless authorised to do so by a sanctions permit.

Top of Page

Section 5 - Responsibilities


(12) The Vice-Chancellor will ensure that the University develops and implements procedures, consistent with the principles mentioned in clause 7-11, for each of the following areas of University activity:

  1. enrolling students;
  2. employing staff;
  3. hosting visitors to the University;
  4. entering agreements (including international partnerships);
  5. academic collaboration (including knowledge-sharing);
  6. applying for research funding;
  7. any other area the Vice-Chancellor deems appropriate.

Responsibilities of all University Staff

(13) All University staff are responsible for complying with Australian Sanctions Laws, in accordance with procedures under this policy.

Transitional Provisions

(14) This policy has been implemented by the Executive Committee on an interim basis pending approval by the Council, and will be presented to the next Council meeting following interim approval. This policy is required to provide strategic direction University wide as to the need for compliance with the legislation referred to.

(15) The transitional guidelines give some direction to both compliance on an interim basis, and to collaboration for developing appropriate procedures.

(16) Following interim approval all staff responsible for any aspects of University business noted in clause 12 will be informed of the creation of this policy.

(17) Until such time as procedure and guidelines are developed to fully support this policy, all staff must exercise appropriate due diligence when considering any matter the subject to their authority that may fall within the scope of this Policy; and

(18) Where there is potential for an issue arising, or uncertainty as to status, the matter shall be referred to the International Compliance Coordinator who will determine what information needs to be collected and assist the decision maker to determine whether or not a notification should be made.

(19) This Policy must be reviewed and in final form within twelve months of the date of its endorsement by the Executive Committee.