Insight alert: Sanctions Tracker – Enforcement Action by the Australian Federal Police

Introduction

The Australian Federal Police (AFP) has charged the director of a registered remittance company for allegedly remitting approximately $649,000 to sanctioned Iranian banks, in contravention of Australia’s autonomous sanctions regime. 

The prosecution is an example of criminal enforcement under the Autonomous Sanctions Act 2011 (Cth), and follows a sustained increase in regulatory scrutiny of remittance service providers by the Australian Sanctions Office (ASO) and the Department of Foreign Affairs and Trade (DFAT), and may signal a broader expansion of sanctions enforcement activity.

AFP Enforcement Action

In October 2025, the AFP charged the director of a registered remittance company with contravening section 16(1) of the Autonomous Sanctions Act 2011 (Cth) (the Act), alleging that between 2021 and 2023 the company remitted a total of $649,307 to sanctioned Iranian banks across approximately 543 transactions. 

In July 2025, search warrants were issued against the individual's home and business premises. Digital examination of devices obtained during these searches allegedly revealed evidence of the impugned transactions.

Transactions with Iranian designated persons and entities are prohibited under the Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Iran) List 2012, including by operation of regulation 14 of the Autonomous Sanctions Regulations 2011 (Cth), which prohibits the direct or indirect making available of assets to, or for the benefit of, a designated person or entity without authorisation.

Section 16(1) of the Act creates a general offence for contravening a sanctions law, carrying a maximum penalty of 10 years’ imprisonment and/or a fine equal to the greater of 2,500 penalty units ($825,000) or three times the transaction value. 

These events follow an increased focus on remittance providers by the ASO and DFAT. 

Read the full article here