Do sole traders need to comply with Australian sanctions law + screening (DFAT)?

Yes. Looking in the 8 industries it can reach and every size band, the engine's answer for a sole trader is: yes.

Do businesses with 1–5 employees need to comply with Australian sanctions law + screening (DFAT)?

Yes (1–5 employees, turnover $100K–$1M).

Who must comply with Australian sanctions law + screening (DFAT)?

What the obligation is

Australian sanctions law prohibits dealings with designated persons + entities. Screening required.

Autonomous Sanctions Act 2011 + Charter of the United Nations Act 1945 + their regulations prohibit dealings with designated persons + entities. DFAT Consolidated List maintained. Sanctions breaches = strict liability criminal offence.

The applicability test

Applies when the business has an AML/CTF designated service or international activity or crypto / DCE activity. Where the business has an AFSL, check whether you deal with overseas parties or designated persons.

How the regulator frames it: All Australian persons + entities + persons in Australia.

What triggers it: Dealings + transactions.

Jurisdiction: Commonwealth law, so the test is the same in every state and territory.

Which industries are in or out

Outcome across the 35 industries Rules Mate maps (8 of 35: yes; 27 of 35: no).

Industry	Answer
Real estate agents	Yes
Accountants & bookkeepers	Yes
Lawyers & solicitors	Yes
Conveyancers	Yes
Trust & company service providers	Yes
Precious metals & stones dealers	Yes
Banks & ADIs	Yes
Gambling & wagering	Yes
No	27 other industries

Business structure and size

Structure does not change the answer in the 8 industries it can reach: for every structure the answer is "yes".

Size does not change the answer in the 8 industries it can reach: at every size band the answer is "yes".

Worked examples

Each line is one run of the Rules Mate applicability engine for a single business profile, with the reason the engine gives:

Pty Ltd company in real estate agents with 6–19 employees, turnover $1M–$3M: applies. Tranche 2 industry (Real estate agents) — AML/CTF reporting entity from 1 July 2026.
Pty Ltd company in fintech (non-bank) with 6–19 employees, turnover $1M–$3M: does not apply. Requires an AML/CTF designated service or international activity or crypto / DCE activity.

Answers that bring it into scope

Starting from a small or large professional services company that does not otherwise meet the test, each of these single facts changes the engine's answer:

The business holds an Australian financial services licence (AFSL): it becomes worth checking, because it applies only if you deal with overseas parties or designated persons.
The business deals in crypto-assets or runs a digital currency exchange: it then applies (digital currency exchange / virtual asset services — AML/CTF reporting entity).
The business makes or receives international funds transfers: it then applies (makes or receives international funds transfers).
The business is foreign-owned: it then applies (foreign-owned).
The business sells to international customers: it then applies (international customers).

When you need to check further

The engine shows this obligation as "check whether this applies" when a business has an AFSL. It then applies only if you deal with overseas parties or designated persons. That fact is not something Rules Mate can infer from industry, structure or size.

What you must do, and when

When due: Continuous screening.
Frequency: Ongoing
Evidence to keep: Sanctions screening tool integration; DFAT Consolidated List checks; risk assessment.
Status: Current
Priority: Critical

Penalty for not complying

Maximum penalty: Criminal — up to 10 years imprisonment + corporate penalties.

Criminal liability

Breaches can be prosecuted as criminal offences, not only civil contraventions.

Audit or assurance level

Rules Mate has not yet classified the audit or assurance level for this obligation. Any audit, review or certification requirement is set by the regulator source listed below.

What usually applies alongside it

Across the 1,890 business profiles Rules Mate evaluates, these obligations apply to most of the businesses this one applies to, and are far more common among them than among businesses generally:

Where it sits in the corpus

Rules Mate tracks 1 published obligation tagged "sanctions", 1 of them rated critical. For a professional services Pty Ltd company with 6–19 employees operating in every state, 0 of those apply outright. This obligation is rated critical priority and carries criminal liability, and is an ongoing duty.

Regulator, legislation and tools

Free tools that help with this obligation:

Compliance calendar builder

Run the compliance journeyAnswer a short questionnaire about your business and get the obligations that apply to you, with the reason each one applies.

Questions

Who must comply with Australian sanctions law + screening (DFAT)?: Applies when the business has an AML/CTF designated service or international activity or crypto / DCE activity. Where the business has an AFSL, check whether you deal with overseas parties or designated persons.
Do sole traders need to comply with Australian sanctions law + screening (DFAT)?: Yes. Looking in the 8 industries it can reach and every size band, the engine's answer for a sole trader is: yes.
Do businesses with 1–5 employees need to comply with Australian sanctions law + screening (DFAT)?: Yes (1–5 employees, turnover $100K–$1M).
When is "Comply with Australian sanctions law + screening (DFAT)" due?: Continuous screening.

Sources

Official source

Computed by the Rules Mate applicability engine from the published obligation corpus; facts last checked 3 October 2026. Rules Mate is not a law firm and this is general information, not legal advice. Confirm your position with the regulator source or a qualified adviser before acting.