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Throughout 2006, Commissioner Terence Cole QC conducted an inquiry into the involvement of Australian companies in the United Nations' Oil-for-Food Programme in Iraq. The inquiry generated headlines about sanctions-busting behaviour on the part of AWB Limited and whether or not government ministers knew or should have known what was happening during the life of the Programme from 1996 to 2003. An element of the scandal that has received little attention is whether AWB Limited's behaviour was actually that extraordinary, given its status as a private company whose obligation to its shareholders was to maximise profits and which, had it not complied with the Iraqi government's demands to bypass the sanctions regime, could have cost the company a very important market. Drawing on the sanctions literature, this paper examines an essential problem at the heart of sanctions implementation; namely, that while states sign on to these international obligations, it is private companies and individuals that generally bear their cost. The paper considers legislative changes prompted by Commissioner Cole's Report but emphasises their limitations. A key and persistent difficulty for Australia and other states is that enforcing their international obligations depends on the goodwill and integrity of private actors. [ABSTRACT FROM AUTHOR]

In 1999, the Australian government privatised the statutory Australian Wheat Board and created AWB Limited, transferring the Board's assets and its export monopoly to a grower-controlled company. In 2000, allegations surfaced that AWB Limited had made payments to Saddam Hussein's Iraqi regime in order to secure lucrative wheat exports worth $500 million per annum. Such actions violated the terms of the United Nations' Oil-for-Food Programme and became one of the biggest corporate scandals in Australian history. It also placed considerable pressure on senior ministers in John Howard's coalition government who were vulnerable on a number of issues, including the existence of numerous warning signs and the extent of ministerial awareness. The purpose of this article is to outline and examine the federal government's role in managing the ensuing blame game. It utilises literature on policy fiascos and blame management to create a conceptual framework that is then applied to the unfolding dynamics of the AWB Limited case. It examines issues such as the roles played by the Cole Inquiry and the political language of ministers in steering blame away from ministers and towards AWB Limited and the UN. [ABSTRACT FROM AUTHOR]