The Minister for Foreign Affairs has granted general permits authorising certain activities that would otherwise be prohibited under the Autonomous Sanctions Act 2011 (Cth) and the Autonomous Sanctions Regulations 2011 (Cth). General permits constitute blanket authorisation for the activities described in the permit, and apply to the class of persons described in the permit as the 'permit holder.'

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 making assets available to persons or entities designated under the Autonomous Sanctions Regulations 2011 (Cth) in connection with the protection of intellectual property under the laws of the Russian Federation or the Eurasian Patent Convention (2 August 2024). This permit replaces permit SAN-2022-00061 which expired on 25 May 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’, in connection with legal services, settlement of legal proceedings, and payment of legal costs (issued 30 October 2024). This permit replaces SAN-2022-00079 which was revoked on 30 October 2024. 

Oil and Petroleum Price Caps

SAN-2023-00094 - Permit authorising the transport by ship of Russian refined petroleum products purchased at or below a price cap (issued 15 February 2023).

SAN-2023-00096 - Permit authorising the transport by ship of Russian oil purchased at or below the price cap (issued 15 February 2023).

Australia uses sanctions permits to implement price caps on Russian oil and refined petroleum products (Oil and Petroleum Price Caps). On 2 December 2022, G7 countries plus Australia agreed to a price cap of USD 60 per barrel of seaborne Russian-origin crude oil. On 4 February 2023, G7 countries plus Australia agreed to price caps of USD 100 per barrel for high value and USD 45 per barrel for low value Russian-origin refined petroleum products. The price caps have two key objectives: constraining Russian revenues that could otherwise be used to fund Russia's war of aggression against Ukraine; and maintaining global oil flows and protecting energy security.

Two general permits that previously authorised the provision of financial assistance and financial services in relation to Russian oil and refined petroleum products under the price caps (SAN-2022-00086 and SAN-2023-00095) were due to expire in December 2024 and February 2025. All entities that previously advised of their reliance on these two permits were contacted by the ASO to arrange for replacement permits to be issued and the two general permits were revoked in December 2024.

Australia remains committed to implementing the Oil and Petroleum Price Caps alongside G7 partners. Entities can apply for a sanctions permit to authorise the transportation of Russian oil and petroleum products, and associated financial assistance and services, consistent with Oil and Petroleum Price Caps policy. ASO reminds entities that these activities are prohibited under Australian sanctions law if the entity does not hold a permit.