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ASO changes its mind – decides to hit Russian banks harder

Designation for targeted financial sanctions rather than specification for investment restrictions of four Russian financial institutions


On 25 February 2022, the Australian Sanctions Office announced on its website that the Minister for Foreign Affairs intended to specify an additional four entities, all Russian financial institutions, for investment restrictions under regulation 5B, paragraph (6)(a) of the Autonomous Sanctions Regulations 2011 (the Regulations). The four entities were:


  • Cetelem Bank
  • Russian Agency for Export Credit and Investment (EXIAR)
  • Otkritie Bank
  • Russian Direct Investment Fund (RDIF)


On 2 March 2022, the Minister for Foreign Affairs instead decided to designate the four entities under item 6A of regulation 6 of the Regulations. Following registration of the Autonomous Sanctions (Designated Persons and Entities and Declared Persons—Russia and Ukraine) Amendment (No. 3) Instrument 2022, the entities are now designated for targeted financial sanctions. The designations took effect on 3 March 2022, and the DFAT Consolidated List was updated accordingly (as circulated earlier today). 


Targeted financial sanctions impose broader restrictions than investment restrictions. Accordingly, we will no longer proceed to specify the four entities under regulation 5B, paragraph (6)(a) of the Regulations.


Australian Sanctions Office

Australian Sanctions Office and Transnational Crime Branch | Regulatory Legal Division

Department of Foreign Affairs and Trade +61 2 6261 3830

Categories: Australia Sanctions Office (ASO) updates Autonomous Australian sanctions DFAT Updates Russia sanctions Sanctions Lists


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