Corporate crime, sanctions

There were a number of corporate crime regulatory developments in 2025, in bribery, sanctions, and whistleblowing. These developments include:

• There was the introduction of an autonomous sanctions framework for Afghanistan;¹ easing of the autonomous sanctions on Syria's financial and energy sectors;² and sanctions on Iran, following its non-performance of commitments under the Joint Comprehensive Plan of Action.³
• The Australian Sanctions Office (ASO) released a number of guidance and advisory notes aimed at helping businesses comply with Australian sanctions laws. These cover a broad range of industries and topics, such as mining and machinery exports, proliferation financing risks, de minimis quantities of Russian-origin oil products, as well as exports to Russia and specified regions of Ukraine.⁴
• There was the inclusion of certain positive obligations on reporting entities in relation to sanctions policy / screening in the upcoming AML/CTF Rules (see 'Anti-money laundering' for more information).⁵ These obligations require reporting entities to:
  • include measures in their AML/CTF programs to ensure assets are not made available to, nor are dealings engaged with, designated persons;
  • establish, on reasonable grounds, that neither the customer nor any associated persons (ie their beneficial owners, any person they are acting on behalf of / person acting on their behalf) are designated persons before providing a designated service; and
  • implement sanctions screening processes to monitor the designation status of customers and associated persons, and detect potential breaches of sanctions laws throughout the business relationship.
• There was the passage of legislation introducing a beneficial ownership disclosure regime, which will require unlisted companies to maintain verified registers of beneficial owners, commencing in December 2026.⁶
• The AFP, following a coordinated investigation with AUSTRAC, charged an individual for allegedly sending AU$650,000 to sanctioned Iranian banks via a remittance company. In response, AUSTRAC suspended the company’s registration and the ASO issued warning letters to remittance providers nationwide.⁷ This has been Australia's most coordinated enforcement activity in the sanctions space to date.
• The Federal Court fined TerraCom $7.5 million for whistleblower victimisation—the largest whistleblower penalty imposed in Australia to date—regarding an employee's disclosure about alleged lab result manipulation.⁸
• The National Anti-Corruption Commission (NACC), following a joint investigation with the AFP, secured a conviction of a corrupt Western Sydney Airport official who solicited a bribe of approximately $200,000 during a contract procurement process.⁹
• The AFP established Taskforce Solaris, a dedicated multidisciplinary team focusing on preventing, detecting and investigating foreign bribery and grand corruption.¹⁰
• Organised crime remains an enforcement priority for the AFP, with it having announced a multi-agency strike team targeting 'double dealers' working for organised crime as part of Operation Proctor.¹¹

The AFP, ASIC, APRA, ASO, ACCC, and state and Territory police forces and anti-corruption commissions are the key regulators. The majority of offences at the federal level are referred to the Commonwealth Director of Public Prosecutions. NACC will likely also increasingly take on an investigation and enforcement role, as it moves from its initial 'triage phase' to a more active investigation and public enforcement phase of work.