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International Compliance Reviews

The University must comply with legislative requirements when interacting with certain foreign individuals and entities.  Failure to do so may lead to serious consequences.

Examples of legislative requirements imposed upon the University include:

  1. Sanctions imposed by the United Nations Security Council and Australia;
  2. Defence Trade Controls;
  3. Foreign Influence Transparency Scheme; and
  4. Indonesian Foreign Research Permits when conducting research in Indonesia.

These requirements must be considered wherever ECU engages with foreign nationals or entities and overseas based individuals or entities.  This includes, for example, potential employment of individuals from sanctioned countries, agent contracts and any agreement with foreign individuals or entities and overseas based individuals or entities.

The International Compliance Review process has been developed to ensure that the University reviews the compliance risks posed by our various interactions with foreign individuals and entities. The International Compliance Review process provides for the engagements listed below.

All University activities (research and other University agreements, collaborations, and other engagements) with foreign individuals and entities are subject to international compliance obligations. Prior to any school, centre or any other area of the University entering into an agreement or other arrangement with a foreign individual or entity staff are required to complete an International Compliance Review - Foreign Engagements (ICR-FE) form and submit the completed form to Legal and Integrity for review.

Onshore Higher Degree by Research Students

Research staff need to be aware that the research proposals of higher degree by research (HDR) students from sanctioned countries need to be assessed to ensure that their intended HDR topics do not contravene the UNSC or Australian Autonomous sanctions. To assist in this process the University has developed a form, the International Compliance Review - Higher Degree by Research (ICR-HDR) form which outlines the possible sanctions applicable to students from sanctioned countries. It is recommended that Supervisors review this material prior to agreeing on a particular research topic with the student.

Supervisors need to ensure that they complete the International Compliance Review - Higher Degree by Research form for all HDR applicants from sanctioned countries.  The Form shall be signed by the relevant Associate Dean (Research), endorsed by the relevant Executive Dean and then be sent to the Senior Deputy Vice-Chancellor for approval.

Offshore Higher Degree by Research Students

The same sanctions that apply to onshore HDR students apply to offshore HDR students from sanctioned countries. Supervisors need to ensure that the International Compliance Review - Higher Degree by Research form is completed for all HDR applicants from sanctioned countries and approved by the relevant approvers.

Staff presenting at international conferences need to be aware that the same sanctions that apply in Australia will apply to them at any international destination. In presenting staff may not provide technical advice, assistance or training to a person from a sanctioned country on any of the sanctioned themes and may not deal with any person or entity.

Staff need to consider whether their intended presentation would breach any of the UNSC or Australian Autonomous sanctions. If their presentation could be in breach of any of the sanctions they will have to make reasonable enquiries with the organisers of the conference about who will be attending and then decide whether they should proceed with the presentation. These steps should be documented in an official ECU records file for audit purposes.

In relation to defence trade controls staff need to consider the following:

  • The supply of presentations containing Defence and Strategic Goods List technology to conference organisers located overseas may require a permit (for example by email).
  • Taking out presentations from Australia to an overseas location containing Defence and Strategic Goods List technology in a tangible form, for example printed hard copies or stored on a laptop, may require an export permit.

Staff travelling to sanctioned countries need to be aware of the sanctions that apply to that country and need to take the sanctions into consideration when planning their travel program. Staff should contact the Manager, Legal and Integrity prior to their travel to a sanctioned country if they have any queries.

The University will review all proposed employments of individuals from sanctioned countries. This will include full time, part time, sessional, adjunct and any other appointments to positions at ECU. The International Compliance Review – Staff Employments (ICE-SE) form is to be used to review all employment applications received from individuals from sanctioned countries.

The Department of Foreign Affairs and Trade (DFAT) maintains a list of all persons and entities who are subject to targeted financial sanctions under Australian sanctions law. Those listed may be Australian citizens, foreign nationals, or residents in Australia or overseas.  The list is referred to as the “Consolidated List”.

The ICR-FE and ICR-SE processes require a review of the DFAT Consolidated List. The University has developed a Consolidated List Review Form (CLRF) to make it easier for staff to conduct the DFAT Consolidated List review. Staff shall complete the CLRF and attach the completed CLRF to the ICR-FE or ICR-SE form before submitting both to Legal and Integrity for review.

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