Separate the two questions
AUSTRAC includes targeted financial sanctions in its customer due diligence guidance. This does not make AML and sanctions a single regime. A customer risk assessment asks questions about the relationship and potential misuse. A sanctions review asks whether a relevant prohibition, designation or permission applies. The current sanctions law and responsible authority must be consulted for that decision. This page explains the boundary. It does not publish a sanctions list, decide an ownership threshold or state that an AML check gives permission to transact.
- Activity
Describe the customer and proposed service.
- AML review
Assess the relevant customer and service risks.
- Sanctions review
Check the separate applicable legal question.
- Recorded outcome
Do not substitute one approval for the other.
Keep two decisions visible
Illustrative workflow. Read the page and current primary guidance for conditions and exceptions.
Decision checkpoints. Read the conditions for each point in the text below.
Treat a screening alert as information
In an illustrative workflow, a name-screening alert is an item to resolve. The reviewer compares reliable identifiers and documents the basis for a match or mismatch. A similar name alone is not the same as confirmed identity. Conversely, no name alert does not establish that every relevant sanctions question has been answered. The procedure should identify the limitations of the data and matching method. This example does not recommend a vendor, score or automatic approval rule.
Worked example: a common-name match
Imagine a customer shares a common name with a listed person. The example reviewer checks reliable date-of-birth and other identifying information through the approved process. The review may establish that they are different people, or it may leave the issue unresolved. The record should preserve the basis for that conclusion. It should not label the customer sanctioned merely because software displayed an alert. If the match cannot be resolved, the reviewer follows the escalation route instead of changing the spelling to suppress the alert.
Keep approvals attached to the correct decision
The example business keeps the sanctions review and AML risk decision as separate records with cross-references. An approval in one process should not silently close the other. The record identifies who assessed each issue and which source version informed the decision. If the relevant list or law changes, the business can locate affected decisions. This is a proposed record design, not a legal retention schedule. It helps explain which question was answered and prevents a general compliance label from hiding an unresolved issue.
Get help with a specific sanctions question
Use current sanctions guidance and legislation for a live decision about a prohibition, asset, service or permit. Specialist advice may be needed where ownership, control or several jurisdictions are involved. The example covers information handling only. It does not describe asset-freezing duties or the full range of sanctions measures. Check the relevant customer controls and current official material before making a sanctions decision.