Ensures compliance with autonomous sanctions legislation in relation to international HDR applicants and candidates.
This process also sets out detailed process requirements in relation to sanctions assessment of HDR related matters at RMIT, whether at the time of initial application for entry or when there is a planned change of topic or program.
This process belongs to the Higher degrees by research policy.
2.1. Where an application is received from a prospective international student the International admissions system will record whether the applicant is from a sanctioned country. A list of sanctioned countries is published and maintained by DFAT.
2.2. If the applicant is from a sanctioned country the SGR admissions officer assesses the application against the DFAT Consolidated List to check whether the applicant is specifically listed, or is associated with a ‘designated person or entity’. This process is called a Person and Entity check and is recorded in section 1 of the Sanctions Assessment Form - HDR applicants <hyperlink>.
2.3. If it is apparent that the applicant is a dual citizen of a sanctioned country and a non-sanctioned country the SGR admissions officer will undertake a Person and Entity check.
2.4. Where an applicant:
2.4.1. is listed
2.4.2. is sponsored by a person/entity
2.4.3. is currently undertaking a qualification at a University
2.4.4. is currently employed by a person/entity
2.4.5. has previously studied a postgraduate (coursework or research) qualification at a University and, or
2.4.6. has previously been employed by a person/entity
on the Consolidated List, the application is considered high risk and must be denied.
2.5. If the applicant is from former Yugoslavia, Guinea-Bissau, Iraq, South Sudan or Yemen, only section 1 of the Sanctions Assessment Form - HDR applicants is required to be completed.
2.6. For applicants from all other sanctioned countries, where no connection to the Consolidated List is found, the SGR admissions officer forwards the Sanctions Assessment Form - HDR applicants to the relevant School Selection Officer for an assessment of the proposed research against the applicable sanctions measures.
2.7. As soon as possible, or within two weeks of receiving the form, the relevant School HDR Supervisor completes Sections 2 and 3 of the Sanctions Assessment Form - HDR applicants and returns it to the SGR where it is checked for completeness, including signatures.
2.8. Completed forms are submitted to the Secretary of the Sanctions: HDR Evaluation Committee (SHEC) via the email@example.com email account for processing.
2.9. The SHEC will review the completed Sanctions Assessment Form - HDR applicants <hyperlink> and any further information it may require, and will determine whether an application for HDR study is high or low risk of contravening sanctions legislation.
2.9.1. Individuals whose proposed research is deemed to be high risk of breaching a sanctions measure will be denied candidature in the area of their proposed research. Denied applicants are not restricted from reapplying for admission into an RMIT program with an alternative research proposal.
2.9.2. the Committee may determine that there is a high risk of breaching sanctions legislation where the proposed research involves:
a) arms or related materiel or technology capable of dual use or military applications, and/or if applicable;
b) the maintenance, manufacture or use of an export sanctioned good
2.9.3. In assessing whether the proposed research involves dual-use or military technology, the Committee will consider:
a) whether the proposed research could produce outcomes that are applicable to a military application, and;
b) the DFAT test for determining whether a good is classed as arms or arms related material.
2.10. The Committee may at its discretion seek further advice or clarification from DFAT in assessing the risk proposed by the research. The Secretary of the Committee will liaise with the Department on such requests.
2.11. The final decision of the Committee will be provided in writing to the relevant admission officer by the Secretary of the SHEC as soon as possible.
2.12. On receipt of the decision the SGR admission officer:
2.12.1. undertakes a second Person and Entity check if more than 6 months has passed since the first check,
2.12.2. enters the selection decision in the International admissions system, including any reason(s) if the application was denied, and
2.12.3. provides the applicant with written confirmation of the selection decision using the appropriate Sanctions Communication Template.
2.13. Where an applicant from a sanctioned country is admitted, the project, project requirements and research environment will be monitored by the Senior Supervisor to ensure ongoing compliance with sanctions requirements.
2.13.1. Any changes to the project that may affect compliance must be immediately reported to the Dean/Head of School and the Associate Deputy Vice-Chancellor, Research Training and Development.
2.14. Decisions made by the SHEC to deny an application may be reviewed in accordance with the Admission and credit policy and associated processes.
3.1. This section excludes candidates from those sanctioned countries where there are no restrictions on the provision of training to nationals from that country, as identified in 2.2.2.
3.2. In cases where a candidate, who has previously undergone sanctions assessment, requests a change to their research topic or program, the sanctions evaluation process must be repeated.
3.3. As soon as possible after the proposed change is identified, the HDR Coordinator completes the Sanctions Assessment Form – current HDR candidates in collaboration with the Senior supervisor.
3.4. The HDR Coordinator returns the completed form to the Secretary of the Sanctions: HDR evaluation Committee (SHEC) via firstname.lastname@example.org for processing. The completed form must be endorsed by the Dean/Head of School prior to submission.
3.5. The next steps in the process repeat sections 2.5 to 2.7 in the previous section.
3.6. The final decision of the Committee will be provided in writing to the Coordinator, HDR Candidature Management by the Secretary of the SHEC as soon as possible after the meeting.
3.7. The Coordinator, HDR Candidature Management, advises the candidate, Dean/Head of School, HDR Coordinator and the Senior supervisor of the outcome of their request in writing, including any reason(s) why a request was denied.
4.1. Where an amendment is made to the Australian Sanctions Framework, CRR will assess the changes and identify whether currently enrolled HDR candidates may be affected.
4.2. Where it is deemed that an individual or cohort of candidates may be affected by changes to legislation, the Coordinator, HDR Candidature Management (on advice from CRR), will provide a list of potentially affected candidates to the Secretary of the SHEC for submission to the Committee.
4.3. The Committee will assess the list to determine whether any candidates are affected by the changes. The Committee may request further information from the School or Senior Supervisor in undertaking this assessment.
4.4. Where the Committee determines that a candidate is affected by changes to legislation, the Secretary will submit an application to the Department of Foreign Affairs and Trade to allow the candidate to continue their studies. If this application is rejected on the basis of the current research project (see 2.5.2 and 2.5.3), the candidate will be required to change their research topic prior to the next milestone in consultation with their Senior supervisor.
Status & details
Custodian: Associate Deputy Vice-Chancellor, Research Training and Development
Operational responsibility: School of Graduate Research
Effective from: 20 February 2018
Last updated: 20 February 2018
Document reference: POL/2018/00028