Russia Sanctions

New Zealand has imposed sanctions on Russia in response to their illegal invasion of Ukraine.

Our sanctions are aligned with those of like-minded countries from Asia Pacific and Europe, and together aim to exert pressure on Russian to change course by limiting their ability to finance and equip the war in Ukraine.

The Russia Sanctions Act 2022 and its Regulations place a range of obligations on New Zealanders by prohibiting or restricting engaging in specific activities. They also require New Zealanders to report any suspicious activity.

On these pages, find out more about what sanctions are, who they target, how you can comply with the Act and Regulations, and where you can find help.

All information on these pages is provided as general guidance and does not constitute legal advice. Please seek your own legal advice about sanctions related issues.

Latest updates

Keep up to date with changes to the regulations as we continue to respond to Russia’s illegal invasion of Ukraine.

Find out more

Sanctions register

The sanctions register is published to help New Zealanders comply with Russia sanctions and is regularly updated.

Search the register

Apply for an exemption, revocation or amendment

If you have a humanitarian need, or any other reason, you can apply for an exemption, revocation or amendment.

Apply now

Need help?

Find out who to contact if you have a query.

Contact us

Latest updates

Keep up to date with changes to the regulations as we continue to respond to Russia’s illegal invasion of Ukraine.

  • 27 September: Regulations amended to designate 19 individuals who are political elites and members of President Putin’s inner circle.
  • 20 September: Technical updates made to Register to remove duplicate entry.

Russia Sanctions Register: Updated 27 September 2022

What are sanctions?

Sanctions are a way New Zealand can express serious concern for a violation of international law. They are a common global tool that seeks to influence foreign governments and individuals to change their behaviour without using armed force.

There are different types of sanctions, which place restrictions or prohibitions on activities between New Zealanders – individuals or businesses – and foreign states.

Common sanctions measures are:

  • Restrictions on trade in goods and services.
  • Restrictions on engaging in commercial activities.
  • Targeted financial sanctions (including asset freezes) on individuals and entities.
  • Travel bans on individuals.

What is the aim of sanctions?

Sanctions are designed to exert pressure on Russia to change its course of behaviour, including by interrupting economic relations and trade. They are most effective when they complement or reinforce sanctions by other countries.

The Russia Sanctions Act 2022(external link), passed unanimously by Parliament on 9 March 2022 gives the Minister of Foreign Affairs the ability to impose sanctions in response to threats to the sovereignty or territorial integrity of Ukraine or another country.

Sanctions prevent New Zealand individuals, entities and financial institutions from having dealings with sanctioned persons, assets and services. This ensures that New Zealanders do not support, whether inadvertently or not, Russia’s illegal invasion of Ukraine.

Who do the sanctions target?

Sanctions target individuals and entities – businesses and organisations – that are of economic or strategic importance to Russia. Sanctions can also apply to assets and services that are designated under the Act (see Schedule 2 of the Russia Sanctions Regulations 2022(external link)).

Since March 2022, sanctions have been placed on over 1,000 individuals and entities of strategic or economic importance to the Russian government.

Under the Russia Sanctions Act, New Zealand has:

  • Applied the full range of sanctions on hundreds of individuals, including President Putin and permanent members of the Security Council of the Russian Federation, members of the State Duma and Federation Council who voted in favour of the recognition the independence of the Donetsk and Luhansk, political, economic and military elites, occupation officials, and disinformation and malicious cyber actors.
  • Sanctioned the branches and independent arms of service of the Russian Armed Forces, including logistical support.
  • Sanctioned defence entities that are part of Russia’s military industrial complex, freezing their assets, prohibiting financial dealings, and banning any related aircrafts and ships from entering New Zealand.
  • Sanctioned key state-owned entities that provide export revenue to Russia, freezing their assets, prohibiting financial dealings, and banning any related aircrafts and ships from entering New Zealand.
  • Sanctioned key banks and financial entities, freezing their assets, prohibiting financial dealings, and banning any related aircrafts and ships from entering New Zealand.
  • Banned Russian and Belarussian government and military aircraft and ships from entering New Zealand.
  • Applied a 35% tariff on all imports of Russian origin and prohibited the export of certain goods to Russia and Belarus, including products that are closely connected to strategic Russian industries.
  • Banned the import of gold of Russian origin.

View the sanctions register

Who must comply with the sanctions?

  • All New Zealanders no matter where they are in the world.
  • All individuals in New Zealand (including those ordinarily resident in New Zealand).
  • All businesses and organisations (entities) operating in New Zealand.

New Zealanders in Russia may continue using services of a sanctioned company, where necessary, for personal or household purposes, e.g. utility services.

There are civil and criminal liabilities for those who do not comply with the sanctions. Please see What you need to do – Complying with sanctions for more information.

Are there any exceptions?

Yes, in certain circumstances.

  • If you have a legitimate need to engage with a sanctioned individual or entity, there are some situations in which dealing with sanctioned persons, assets or services is allowed (Regulation 12), for example, if you were owed payment before the date the individual or business was sanctioned
  • The sanctions do not apply in relation to humanitarian organisations carrying out their humanitarian activities (Regulation 18).
  • You can request an exemption on the basis of humanitarian need or for any other reason, in relation to particular events or dealings in relation to persons, assets or services.

Apply for an exemption

What is prohibited by the sanctions?

There are currently seven types of prohibitions:

Travel bans
  • Designated individuals are prohibited from traveling to, or transiting through New Zealand. The sanction may also affect an individual’s visa status if they already have a visa.
Transport bans
  • All Russian and Belarussian military and government owned or controlled aircraft and ships are banned from New Zealand airspace and waters.
  • Aircraft and ships owned, operated, or chartered by sanctioned individuals cannot enter New Zealand.
Assets (asset freeze)
  • Asset freezes stop New Zealanders and New Zealand-based businesses, individuals and entities dealing with the assets of sanctioned individuals and entities. This prohibition does not apply to securities (as defined in the Regulations).
  • One effect of asset freezes is that designated individuals and entities and their associates are prevented from using any assets they hold in New Zealand. This includes bank accounts and personal property.
  • Asset freezes also prohibit New Zealanders and New Zealand-based businesses, individuals and entities from entering into financial transactions with, by, or on behalf of sanctioned individuals and entities.
  • Where a duty-holder (as defined under the AML/CFT Act) is in possession or control of assets and suspects on reasonable grounds that these assets may be subject to sanctions measures, they have a duty to report it to the Police.

Note: asset freezes are not the same as asset seizures. There is no ability to seize assets in the Russia Sanctions Act.

Securities
  • New Zealanders and New Zealand-based businesses are prohibited from dealing with a security of a sanctioned person if doing so would result in the sanctioned person acquiring the security, owning or controlling the security, or would otherwise be for the benefit of a sanctioned person.
  • The prohibition does not prevent a New Zealander from holding or disposing of such a security (as long as it is not to a sanctioned person).
Services
  • This is a measure that prohibits, amongst other things, services being extended to, offered to, or received from sanctioned individuals or entities.
  • Where a duty-holder is dealing with services and suspects on reasonable grounds that the services may be subject to the sanctions measures, they have a duty to report it to the Police.
Exports
  • New Zealand has prohibited the export of certain goods to Russia and Belarus, including products that are closely connected to strategic Russian industries. Banned exports are listed in the sanctions register.
Imports
  • New Zealand has prohibited the import of gold of Russian origin.

What other trade measures are in place?

  • There is a 35% tariff on all imports of Russian origin. This does not include low value goods of less than NZ$1,000. In 2019 and 2020 goods of less than NZ$1,000 made up less than 0.02% and 0.03% of total imports (by value) from Russia.
  • Goods intended for the Russian and Belarus military, security, and police sectors are banned from export(external link).
  • New Zealand also maintains a comprehensive export control scheme for the export of other controlled goods to Russia and Belarus.

When do these measures end?

  • The Russia Sanctions Regulations expire at the close of 17 March 2025.
  • The tariff increase on imported Russian goods (under the Tariff Act 1988) expires on 5 November 2022.

What other sanctions has New Zealand imposed?

In addition to sanctions imposed under the Russia Sanctions Act, New Zealand implements all sanctions imposed by the United Nations Security Council in regulations under the United Nations Act 1946.(external link)

What you need to know – Complying with sanctions

The Russia Sanctions Act 2022 and its Regulations must be complied with by:

  • All New Zealand citizens no matter where they are in the world.
  • All individuals in New Zealand (including those ordinarily resident in New Zealand).
  • All businesses and organisations (entities) registered or operating in New Zealand.

We encourage a self-compliance approach so have provided New Zealanders with information and guidance to help you comply.

We also encourage you to report any issues, suspicous activity or suspected breaches, with the confidence that you won’t automatically be penalised, as long as it was not a direct attempt to violate sanctions.

It is a criminal offence to breach a sanction in the Act. For individuals, this is punishable by up to seven years’ imprisonment or a fine not exceeding $100,000. For an entity, this is punishable by a fine not exceeding $1 million.

We recommend checking the sanctions register for updates regularly, and subscribing to receive notifications when there are updates.

For specific advice regarding your business or activity, we encourage you to seek independent legal advice.

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