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Compliance
October 4, 20269 min read

Sanctions hit mid-matter: what you stop doing

A sanctions hit mid-matter means you stop the step your program says you stop. You do not finish the matter because the documents were already drafted.

Quick answer

Screening against the DFAT consolidated list is the firm’s check, done the way the program describes. A hit is a pause and an escalation, not a maybe-later, and who you may tell if a suspicion is also in play is a separate rule. This page does not clear a name and it does not reproduce AUSTRAC’s sanctions guidance. The firm suite is A$0.

People search “DFAT sanctions list check” when a two-partner firm is halfway through a matter and a name matches a targeted financial sanctions designation. Checked against AUSTRAC’s targeted financial sanctions page on 4 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. How screening fits the firm’s ordinary checks is sanctions screening in Australia. What you must not tell a customer is what not to tell a client. The sector map is /tranche-2.

A hit is a stop, not a footnote

Targeted financial sanctions are not the same task as ordinary identity verification. AUSTRAC’s page is the compliance frame for designated persons. This page does not reproduce it and does not list names. A DFAT sanctions list check that returns a match mid-matter is a reason to pause the step the program forbids you to continue.

The two-partner firm writes who is told internally, who may approve any next step, and that the matter does not drift to completion while someone “looks into it next week”. If a suspicion is also formed, what the client may be told is the tipping-off page. This page does not script that conversation.

  • Pause the named step. Settlement, a transfer, or further instructions wait. A drafted document is not a reason to finish.
  • Escalate inside the firm. The person the program names sees the hit the same day. A match left in an inbox is not an escalation.
  • Do not clear it in the corridor. A similar name is still a match until the program’s process says otherwise. This page does not teach that process.
  • Keep the customer-check link separate. Emailing a KYC link does not resolve a sanctions hit. Do not describe the hit as a failed identity check.

What stops, in plain words

Staff need a short card. The card is a stop sign. It is not a legal opinion on the designation.

A mid-matter stop card for a law firm. This table does not reproduce AUSTRAC’s sanctions guidance or the DFAT list.

EventWhat you stopWhat you do not do
A match on the screening the program requiresThe next step the program says must not proceedFinish because the contract is already drafted
You are unsure it is the same personStill pause, and escalateDecide in the corridor that the name is common
A suspicion is also formedFollow the report path as well as the sanctions pathTell the client which list they matched
The matter is only a quote, not yet a designated serviceDo not start the service the program blocksTreat a quote as permission to ignore the match

Where the mid-matter hit stops

This page is the pause. It is not the screening product note and it is not the tipping-off rule. Those are sanctions screening in Australia and what not to tell a client.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Use KYB when the customer is a company or a trust. Clearing a sanctions hit is not included in the firm suite, and the suite does not tell you the designated person is safe to act for. Confirm the live amounts on FreeAML pricing. FreeAML does not clear a sanctions hit or decide that you may continue the matter.

Frequently Asked Questions

Pause the matter. Do not treat a hit as a pricing question.

The firm suite is A$0. The client pays a customer check the program requires. A sanctions hit is not cleared by that check.

Open the Tranche 2 guide

Questions: team@freeaml.com.au