The Australian Sanctions Office (ASO) has released 8 new advisory notes to assist financial service providers in understanding their sanctions risks.
The advisory notes include:
- Sanctions risks of specific banking services
- Sanctions circumvention using cryptocurrency – ASO/AUSTRAC co-badged
- Sanctions risks from misuse of AI and new technologies
- Sanctions risks of remittance account compromises
Key points include:
- Cryptocurrencies are considered “assets” under Australian Sanctions Laws. This means providing cryptocurrency (or providing crypto services) to a sanctioned individual or entity is a sanctions contravention.
- With respect to trade finance, the ASO has highlighted the risks relating to book transfers, Nostro Vostro accounts and netting arrangements.
- Falsifying the nature, origin or destination of goods is a common tactic in trade-based money laundering and sanctions evasion. The use of AI technology may increase the sophistication of deceptive conduct used to circumvent trade-based sanctions and export controls. AI may assist in producing realistic fraudulent documents, such as bills of lading, certificates of origin and packing lists, and is a well-established method of sanctions evasion.
The ASO has updated the following public guidance notes:
Guidance Note – Digital Currency Exchanges
Guidance Note – Financial transactions involving designated persons and entities
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Author: David Jacobson
Principal, Bright Corporate Law
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About David Jacobson
The information contained in this article is not legal advice. It is not to be relied upon as a full statement of the law. You should seek professional advice for your specific needs and circumstances before acting or relying on any of the content.
