DFAT Sanctions Check — What It Means and What to Do on a Match
The DFAT Consolidated Sanctions List is Australia's official register of entities, individuals, and vessels subject to targeted financial sanctions. Here's what a Gumshoe sanctions result means and how to respond.
What is the DFAT Consolidated Sanctions List?
The DFAT Consolidated Sanctions List is maintained by Australia's Department of Foreign Affairs and Trade and lists all individuals, entities, and vessels subject to targeted financial sanctions under Australian law. It combines:
- Autonomous Australian sanctions — unilateral measures imposed by Australia targeting specific regimes or situations (Russia/Ukraine, Iran, DPRK, Myanmar, Syria, Belarus, Zimbabwe)
- UN Security Council measures — mandatory financial sanctions adopted by Australia under the Charter of the United Nations Act 1945
The list is updated continuously and contains over 3,700 entries including named individuals, corporate entities, and specific vessels.
What does a Gumshoe sanctions check do?
Gumshoe checks the entity name you search against the full DFAT Consolidated Sanctions List using a fuzzy name-matching algorithm. The similarity threshold is set at 0.65, which means it will catch common name transliterations, misspellings, and known aliases — not just exact matches.
We source the data via the OpenSanctions mirror of DFAT data, which provides structured bulk access to the DFAT list and is updated weekly.
What does a FAIL result mean?
A FAIL result means the entity name you searched returned a match in the DFAT Consolidated Sanctions List above the similarity threshold. This is a serious compliance alert.
Under the Autonomous Sanctions Act 2011 and related regulations, it is a criminal offence to:
- Deal in assets of a sanctioned entity or individual
- Make assets available to a sanctioned entity or individual
- Provide a service to or for the benefit of a sanctioned entity or individual
Penalties can include imprisonment of up to 10 years and/or fines. The Australian Sanctions Office at DFAT enforces these measures.
What should I do if there is a match?
- Do not proceed with the transaction or engagement until you have legal advice
- Review the match carefully — Gumshoe returns the matched name and listing information so you can assess whether it is the same entity
- Contact legal counsel — if the match is confirmed, you must not engage without specific authorisation or a permit from the Australian Sanctions Office
- Consider reporting — if you suspect a sanctions breach has occurred, you may need to report to AUSTRAC and the Australian Sanctions Office
What does a PASS result mean?
A PASS result means no entry in the DFAT Consolidated Sanctions List matched the entity name above the threshold at the time of the check. It does not guarantee the entity is not sanctioned — name matching has inherent limitations, and the list changes. For high-risk transactions, additional screening against OFAC (US Treasury) and EU sanctions lists may also be warranted.