National Competent Authorities
The Ministry of Foreign Affairs and Trade (MFAT) is the national competent authority for sanctions in New Zealand.
Sanctions Lists
Guidance
Russia sanctions (including FAQs)
Compliance, due diligence and understanding evasion risk in the Russia sanctions context
Russia sanctions latest updates
Russia sanctions designation notices
Russia Sanctions Regulatory Charter
A Review of the Russian Sanctions Regulatory Framework
Post-Implementation Review: Russia Sanctions Act 2022 and Russia Sanctions Regulations 2022
Guidance Note: Banking transactions (updated 12 September 2022) [PDF 947 KB]
Guidance Note: Duty holder reporting under the Act, 21 February 2023 [PDF 1.1 MB]
Guidance Note: Export prohibitions on dual use items [PDF 1.1 MB]
Guidance Note: Permitted activities including exemptions [PDF 717 KB]
Guidance note: Russian energy products [PDF 728 KB]
Guidance Note: Trade measures [PDF 871 KB]
Guidance Note: Update to Exporters [PDF 114 KB]
Guidance for the Transport Sector on Sanctioned Aircraft and Ships [PDF 184 KB]
Licensing
Applications for sanctions exemptions must be made using this application form. Applications are considered by either the Minister of Foreign Affairs or the Secretary of Foreign Affairs and Trade.
The following criteria will be considered when applications are assessed:
– the purpose of the Russia Sanctions Act 2022 and Russia Sanctions Regulations 2022
– risk of an exemption benefitting a sanctioned person or entity
– any harm if an exemption is not granted
– the accuracy of facts and law
– other factors material to the application
– principles of natural justice or procedural fairness.
Requests for guidance on whether general exceptions apply to certain circumstances may be made to the New Zealand Sanctions Unit at russiasanctions@mfat.govt.nz.
Apply for an exemption, amendment or revocation
Guidance Note: Permitted activities including exemptions [PDF 717 KB]
Reporting
Reporting obligations apply to “duty holders”. A duty holder is a reporting entity under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 and those listed in the Russian Sanctions Regulations 2022 who trade in certain commodities with a total value of $10,000 or more (see reporting guidance for list of the commodities).
Duty holders must report when they have reasonable grounds to believe that they are in possession or control of sanctioned assets or are providing services to designated persons and when there is a change in the nature or purpose of the business relationship or assets held for a designated person or any suspicious sanctions-related activity. If duty holders are unsure whether to report or not, they may contact the MFAT sanctions team (sanctions@mfat.govt.nz) for guidance.
When reporting, MFAT encourages duty holders to “provide any information they deem to be relevant in the circumstances.”
Guidance Note: Duty holder reporting under the Act, 21 February 2023 [PDF 1.1 MB]
Export controls
Guidance Note: Export prohibitions on dual use items [PDF 1.1 MB]
De-listing
Applications for an amendment or revocation of a designation must be sent to sanctions@mfat.govt.nz using this application form. Applications are considered by either the Minister of Foreign Affairs or Secretary of Foreign Affairs and Trade.
Judgments
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Targa Capital Ltd. v Westpac New Zealand Ltd. [2023] NZHC 230
