Sanctions screening in Australia versus a bundled check

A search for “sanctions screening australia” mixes two products: a screen you run while you identify someone, and the duty to notice if that person is designated later. They are not the same purchase. Checked against AUSTRAC’s page on persons designated for targeted financial sanctions on 2 October 2026 (page last updated 3 September 2026), and against DFAT’s Consolidated List. This is general information, not legal advice. This page does not reproduce either page. How the screen sits inside a full check is what an AML check covers. The sector map is /tranche-2.

What the Australian duty actually asks

AUSTRAC says you establish on reasonable grounds, before the designated service starts, whether any of these are designated for targeted financial sanctions: the customer, a beneficial owner (except in limited circumstances the page notes), a person the customer is receiving the service for, and a person acting for the customer. You also check whether any of them become designated during the relationship, and you monitor for potential breaches of sanctions laws. The list you use is the one DFAT publishes. Sanctions change often. Their page says to use the latest list. Names, especially names translated into English, can be spelled more than one way.

• The list is DFAT’s. The Australian Sanctions Office maintains the Consolidated List of persons and entities designated under Australian sanctions laws. A foreign vendor’s watchlist is not a substitute you can assume is that list. Ask what was screened.
• A match is a stop. You must not deal with assets the designated person owns or controls, or make assets available to them, without a permit. AUSTRAC’s page describes contacting the Australian Sanctions Office, reporting to the AFP, and a suspicious matter report where you suspect a sanctions contravention. This page does not reproduce those steps.
• The firm decides. A possible name match is not a finding that the client is the listed person. Someone at the firm has to look. The software does not clear a match by itself.
• Low risk is not “skip it”. AUSTRAC says it may be appropriate to screen low-risk customers against the Consolidated List as part of delayed initial CDD. That is a timing note. It is not an exemption from the question.

A bundled screen versus a monitoring product

Some vendors sell sanctions screening as its own subscription, and some sell ongoing monitoring of PEP, sanctions, and adverse media as a second meter. Read that meter before you treat a logo as “screened”. A bundle can be the honest shape: one check, one result, one file. It becomes misleading when the bundle is described as if the firm is watching the Consolidated List every day after that.

How FreeAML bundles the screen

A FreeAML verification bundles the sanctions screen with the identity or entity check. It is not a standalone sanctions product, and it is not sold as ongoing monitoring. The firm emails the request. The client completes it. The result, including a possible sanctions or PEP match, sits on the customer file for the firm to assess. The firm suite is A$0. The check is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. Confirm the live inclusions and amounts on FreeAML pricing. Each further person the program requires is a separate check.

That is as far as the bundle goes. FreeAML does not replace DFAT’s Consolidated List, does not subscribe the firm to DFAT’s updates, does not decide a match, does not freeze an asset, and does not contact the Australian Sanctions Office or lodge a suspicious matter report. If the risk is high, the extra work is still enhanced customer due diligence. The new-matter order of jobs is the customer due diligence checklist. The path to the check itself is /aml-check.

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