Sanctions permits, issued by the Minister for Foreign Affairs or their delegate, authorise activities that would otherwise contravene Australian sanctions laws. Different sanctions frameworks impose different criteria for the grant of a permit. The relevant sanctions framework will identify what activities can be authorised under a permit.

The criteria for sanctions permits under UNSC sanctions frameworks vary, as do the range of activities that the Minister can authorise. These activities tend to be more limited than those which can be authorised under autonomous sanctions frameworks. Additionally, some of the UNSC sanctions frameworks require the Minister to notify or receive the approval of the UNSC before granting a sanctions permit.

The ASO advocates for proactive risk management rather than relying on permits. Sanctions permits are generally appropriate only when there is a clear likelihood of a sanctions contravention occurring. For broad or non-specific sanctions risks, it's better to manage compliance through reasonable precautions and due diligence to prevent issues before they arise. To enable due consideration of any permit application, ASO must be provided sufficient detail of a specific contravention to which the application relates.

What is the 'national interest' test?

All permits issued under autonomous sanctions frameworks must meet the same criteria, in particular that the Minister must not grant the permit unless the Minister is satisfied that granting the permit is in the 'national interest'.

This generally requires the Minister to be satisfied that the grant of a permit is beneficial, or advantageous, to the national interest. It requires a consideration of whether something is advantageous to the nation as a whole, as opposed to only a particular company, group or section within the nation, or to a particular region or locality.

Applications for a sanctions permit can be made through Pax Portal When applying for a sanctions permit you will need to include information about the proposed activity. For example:

• a detailed description of the goods and services involved, including the technical specification for your goods (this information should match any supporting documentation such as Purchase Orders or Defence End Use Statements)
• a detailed description of the end use of the goods or services
• a detailed information on the end user and any other relevant parties to the proposed activities including end user certification
• the intended transport pathway for any goods and services you propose to provide, from you, through any intermediaries, to the end user.

You must ensure that the information you provide to the ASO is accurate and complete. It is a serious criminal offence to give false or misleading information in connection with the administration of sanctions laws. A sanctions permit will be treated as never being granted if false or misleading information was contained in the application for the permit.

Class-based permits

The Minister for Foreign Affairs has granted class-based permits authorising certain activities that would otherwise be prohibited under the Autonomous Sanctions Act 2011and the Autonomous Sanctions Regulations 2011. Class-based permits apply to the class of persons authorised in the permit and described as 'permit holders' and authorises them to undertake activities described in the permit.

Please note, for those who intend to rely on the permits, each permit sets out specific conditions, including reporting requirements. We recommend you read the terms of the permit carefully to ascertain whether it might apply to you, and ensure you understand any compliance obligations under the permit.

Intellectual Property (IP) Rights

SAN-2024-00140 - Permit authorising transactions to make certain assets, available to, or for the benefit of, certain designated entities for the purposes of IP protection made under the law of the Russian Federation and/or Eurasian Patent Convention (2 August 2024).

Legal Services

SAN-2024-00138 - Permit authorising making assets available to persons or entities designated under the Autonomous Sanctions Regulations 2011, and the use of, or dealing with 'controlled assets', where doing so is associated with the provision of legal and ancillary services (issued 30 October 2024).

Oil and Petroleum Price Caps

Australia, together with G7 countries and the European Union, has imposed a price cap on seaborne Russian-origin crude oil since December 2022. These measures constrain Russian revenues that could otherwise be used to fund Russia's war of aggression against Ukraine while maintaining global oil flows and protecting energy security. On 18 September 2025, the Foreign Minister announced a lowering of this cap to USD47.60 per barrel (from USD60), following similar actions by the European Union, the United Kingdom, Canada, Japan and New Zealand.

The price caps on high value Russian-origin refined petroleum products (USD100 per barrel) and low value Russian-origin refined petroleum products (USD45 per barrel) have remained unchanged since February 2023.

Australian entities and individuals may apply for a sanctions permit issued by the Minister for Foreign Affairs or her delegate that authorise activities that would otherwise contravene Australian sanctions laws. Permits support the implementation of Australia’s Oil Price Cap on Russian oil and refined petroleum products.  In approved cases, permits allow Australian individuals and companies to provide certain services relating to finance, insurance and transportation of Russian oil and petroleum products where other countries purchase these products below the price cap. Australia however, maintains a total ban on the importation of these goods.

General permits - that previously authorised Oil Price Cap related activities - have now expired. It is an offence to engage in sanctioned activities in the absence of a permit.

PAX Portal

The Pax Portal, managed by the Australian Sanctions Office (ASO), is the platform for submitting general enquiries and applying for sanctions permits. We aim to respond promptly; however, complex queries and applications may take longer to address.

Please note that the ASO does not provide legal advice, or tailored guidance on hypothetical activities. It is your responsibility to ensure compliance with Australian sanctions laws and determine if a permit is required, including seeking independent legal advice when required.

Timeframes

You should allow a minimum of three months for ASO to process an application, especially for complex activities and activities in high-risk countries or regions.

You should note any critical commercial deadlines in your application. The ASO will endeavour to prioritise applications with commercial deadlines, but there is often limited scope to reduce the time it takes to finalise the process.

The time taken to receive a response will depend on a range of factors, including:

• the complexity of your application
• whether all relevant information has been provided, including supporting documentation
• whether you respond promptly to any request for further information or documentation
• the time it takes to check the information you have given us
• the time it takes to get information from other Australian Government agencies or foreign governments (if necessary)
• the time it takes to consult, notify, or receive approval from the relevant United Nations Security Council sanctions committee (if necessary)
• whether your proposed activity is taking place in a high-risk country or region, which will require a higher degree of risk management
• our current caseload, as high caseloads can cause delays.