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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.
Regulatory focus on remittance providers
In June 2024 (updated in September 2025), the ASO and DFAT issued a Guidance Note highlighting the heightened risk that remittance providers may indirectly facilitate a breach of the Autonomous Sanctions Act 2011 (Cth). The guidance emphasized the importance for:
- robust customer and transaction screening programs for suspicious or high-risk transactions;
- ongoing monitoring of higher-risk jurisdictions and counterparties; and
- effective staff training and internal escalation procedures.
Further, in November 2025, the ASO issued an Advisory Note warning that remittance accounts may be compromised through deception, fraud or the voluntary sharing of credentials, and then exploited to facilitate sanctions breaches, exposing account holders to potential legal liability.
Together, these publications underscore the expectation that remittance service providers maintain continuously updated and risk-based sanctions compliance frameworks.
Possible expansion of enforcement action
At the hearing before the Foreign Affairs, Defence and Trade Reference Committee on 15 November 2024, the AFP and DFAT confirmed that, at the time:
- The AFP had four active sanctions investigations on foot.
- DFAT had 21 sanctions compliance matters under review.
The prosecution referred to above is the first publicly disclosed enforcement action for breaches of Australia's sanctions regime since the Senate Committee and, may foreshadow a broader escalation in regulatory and sanctions enforcement action.
The enforcement action also follows a significant increase in government resourcing. In the 2024-2025 budget, the Australian Government committed $26.4 million to support sanctions enforcement, and in October 2025, the ASO issued a number of warning letters to remittance companies across Australia in response to 'concerns regarding their financial activities'.
The AFP charges also precede upcoming reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), previously discussed here and here. These changes will impose more significant obligations on businesses that provide value transfer services to collect and verify key information about certain transfers.
This prosecution is notable given the historically limited use of criminal enforcement powers under Australia's autonomous sanctions regime, despite the substantial expansion of sanctions since 2022.
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