Policy

Sanctions and export compliance.

An intermediary can be exposed for facilitating a dealing without ever touching goods or money. We screen accordingly.

Draft: pending legal review. Published in draft while Austera Global is being established. It reflects how we operate from the outset and will be reissued once reviewed by an Australian legal adviser.

Reference: AUS-TRC-STA-015
Derived from: AUS-CMP-POL-007 · AUS-CMP-POL-006
Status: Draft, legal review pending
Applies to: Every transaction

Sanctions screening

The Australian Sanctions Office, within the Department of Foreign Affairs and Trade, maintains the Consolidated List of persons, entities and vessels subject to Australian sanctions. Australian Government guidance is clear that a person should not facilitate a dealing involving sanctioned assets by others, including by brokering or helping to arrange one.

	Question	Our position
	What we screen	The buying entity, its parent and ultimate owner, the site operator, the individuals we deal with, any intermediary introduced into a transaction, the destination country, and freight and vessel parties where known
	When we screen	Before first contact, again before we introduce a buyer to a supplier, and again before shipment
	Against what	The DFAT Consolidated List, the destination country's own regime, and other regimes where a nexus exists
	Staleness	A screen is treated as stale after 90 days and re-run
	On a match	Any match, partial match, or inability to resolve identity stops the transaction. We do not proceed, we do not seek a permit, and we do not check with the counterparty

Images are illustrative. Not Austera Global-owned facilities or sites.

Export controls

Australia’s Defence Export Controls regulates military and dual-use goods, software and technology under the Defence and Strategic Goods List. A permit is required to export, supply, publish or broker controlled items unless an exemption applies. Some industrial equipment has dual-use relevance depending on its materials and specification.

We do not assess export-control status ourselves

We are not qualified to, and saying otherwise would be exactly the kind of technical claim we refuse to make.
Every supplier we appoint provides a written declaration of the export-control status of each product line we may represent.
Where an item is controlled, the supplier holds the permit and we do not proceed until it is in place.
We record the declaration and any permit reference in the transaction file.

What we decline

We will say that we are declining, and why, so far as we are permitted to

Any transaction involving a sanctioned or restricted party, or a party we cannot verify
Any transaction where the end use or end user cannot be established
Any request to route goods, documents or payment in a way that obscures the parties
Any request to understate or misdescribe goods or values on documentation
Any transaction involving controlled goods without the supplier's permit in place
Any transaction where an integrity or bribery red flag is unresolved

Other obligations we operate under

	Area	Position
	Australian Consumer Law	We make no technical or performance claims. Claims originating from a supplier are repeated only from a written register they have approved, always attributed
	Electronic marketing	We contact named individuals at published business addresses about matters relevant to their role. We do not buy, scrape or bulk-send to contact lists, and every message identifies us and offers a way to stop
	Modern slavery	We are below the Australian mandatory reporting threshold and do not claim to be a reporting entity. We include supply-chain conduct expectations in supplier arrangements
	Customs and freight	We are not a customs broker or freight forwarder and give no advice on classification, duty, origin or carriage

Images are illustrative. Not Austera Global-owned facilities or sites.

Screening and export control are two of the gates a buyer is assessed against before an introduction; the full set, including which are terminal, is set out on buyer verification. For the broader route by which we work with an international buyer, see our work with international buyers and distributors.