Draft policy
Sanctions Compliance Policy.
The Foundation must not knowingly make funds, assets or services available in breach of applicable Australian sanctions laws, permit conditions or other binding restrictions.
ScreeningPerform proportionate screening of partners, key counterparties and payment recipients before material transactions or engagements.
EscalationPause a transaction when a potential match, restriction or uncertainty is identified and obtain appropriate compliance or legal advice.
PermitsWhere activity relies on an exemption or permit, record the basis, conditions, notifications and supporting due diligence.
No circumventionDo not split, disguise, reroute or structure payments to evade sanctions or screening controls.
RecordsKeep screening results, decisions, approvals and supporting records for an appropriate period.
Important: sanctions requirements can change. This draft does not replace current legal or specialist compliance advice.