HDR United Nations and Autonomous Sanctions Compliance Procedure

Intent and Scope

This procedure must be followed for Higher Degree by Research applicants and candidates from countries with a United Nations Sanction and/or an Australian Autonomous Sanction (UNAS) regime in place.  The sanctions are Australian Federal law and substantial fines and penalties, including prison time apply for a breach of the sanctions. The sanctions regimes are managed by the Department of Foreign Affairs and Trade (DFAT) and there are specific sanctions in place for each country.

Definitions

Terms mentioned in this Procedure and not defined here are defined in the Policy Glossary of Terms for Policies in the Learning and Teaching domain of the University Policy Library and in the HDR Requirements.

‘Sanctions’ refers to the United Nations and Autonomous Sanctions as Australian sanctions law, as managed by the Department of Foreign Affairs and Trade

Procedure

Compliance at Application

1. On receipt of a complete application for a Higher Degree by Research by an international applicant the Graduate Research School will check the following against the DFAT Consolidated List http://dfat.gov.au/international-relations/security/sanctions/Pages/consolidated-list.aspx
   1. Applicant’s name
   2. Names of any listed referees or academic advisors
   3. Names of any listed co-authors of publications
   4. Institutions attended
   5. Names of any listed employers or sponsors.
2. If any of 1.1a to 1.1e do appear on the DFAT Consolidated List, this is recorded on APP-FORM-02 and the application is referred to the Manager, International Compliance who will advise the GRS if the application should proceed or not. If the checks at 1.1 do not return a positive result, the application can proceed to the next step.
3. The Graduate Research School will check if the applicant is from a country which has a sanctions regime in force by checking the DFAT Sanctions regimes page: https://www.dfat.gov.au/international-relations/security/sanctions/sanctions-regimes
4. If the country is not on the sanctions regimes website, the application can proceed as per the HDR Application and Offer Procedure.  If the country is on the sanctions regime website, this is recorded on APP-FORM-02 and the Graduate Research School will initiate URA-FORM-01 United Nations and Autonomous Sanctions Risk Assessment Form.
5. The prospective Primary Advisor of the applicant must assess the application and proposal in conjunction with the sanctions for the applicant’s country of citizenship, and have a conversation/interview with the applicant to discuss the points in Question 2 in URA-FORM-01, after which the primary advisor must make an assessment as per URA-FORM-01.
6. The final outcome of the application is indicated on the form, and can be either that the application should proceed or be declined as per the HDR Application and Offer Procedure.
7. Any signatory of URA-FORM-01 can decline the application at any stage of the application process.
8. If it is determined by URA-FORM-01 that there is a risk of breaching sanctions but it is still preferred that the project proceed, a project will normally only be permitted to proceed if a sanctions permit is granted by the Minister for Foreign Affairs.  This permit must be obtained by the prospective Primary Advisor via the Online Sanctions Administration System: https://pax.dfat.gov.au/sncPortal/s/

Continued compliance

1. Once an applicant from a sanctioned country has been enrolled, the candidate’s Advisors, the Graduate Research School and International Compliance, have a responsibility to ensure that the candidate and their research remains compliant with the sanctions.
2. A candidate’s compliance with the sanctions may be affected by the following:
   1. Changes to the sanctions regime for that country, made by the United Nations or the Australian Department of Foreign Affairs and Trade or
   2. Changes to the research project of the candidate
3. If sanctions for countries are changed or introduced, International Compliance must inform the Manager, Graduate Research Operations as soon as possible, who will relay the information to the Primary Advisor of any affected HDR candidates.  The Primary Advisor must take make any required changes to ensure compliance.
4. If changes are proposed for a candidate’s research the Primary Advisor must assess whether the changes will affect compliance with any UNAS sanctions the candidate may be subject to, by using URA-FORM-01.
5. Any changes to the research project must not be implemented until the required checks have been undertaken and the approval of the Dean, Graduate Research given in writing.

Related policy instruments

Schedules/Appendices

Administration

NOTE: Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.

Approval Details

Revision History