Overview of Sanctions against Russia

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

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.

The Act and its Regulations place a range of obligations on New Zealanders persons (including and New Zealand-based businesses, individuals and entities) by prohibiting or restricting specific activities. New Zealand has imposed seven types of prohibitions: travel bans; transport bans; prohibitions relating to assets, securities, services; and measures relating to exports and imports. In addition to sanctioning individuals and entities from Russia, New Zealand has placed sanctions on individuals and entities from Iran, North Korea and Belarus that are assisting Russia in its aggression.

Under the Russia Sanctions Act, New Zealand has:

Applied a full range of sanctions on over 1,800 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 of 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, key state-owned entities that provide export revenue to Russia, and key banks and financial entities. These sanctions include prohibitions on financial dealings and bans on any related aircraft and ships from entering New Zealand.
Banned Russian and Belarusian government and military aircraft and ships from entering New Zealand.
Applied a 35% tariff on all imports of Russian origin.
Banned the import of oil, gas, coal and gold of Russian origin.
Prohibited the export of a range of goods to Russia and Belarus, including products that are closely connected to strategic Russian industries.
Banned the export to Russia of certain luxury goods, and the import of certain luxury goods of Russian origin.
Banned the export to Russia of oil exploration and oil production goods.
Implemented the G7-plus oil price cap on Russian-origin oil.

Frequently asked questions

What are sanctions?

Sanctions are a way for New Zealand to express serious concern about a violation of international law. They are a common global tool that seeks to influence foreign governments, entities 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?

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.

Since March 2022, sanctions have been placed on over 1,000 individuals and entities of strategic or economic importance to the Russian government.
In addition to sanctioning individuals and entities from Russia, New Zealand has placed sanctions on individuals and entities from Iran, North Korea and Belarus involved in supporting Russia’s illegal war of aggression against Ukraine.

You can access the list of designated individuals and entities in our Sanctions Register.

Who must comply with the sanctions?

The obligations in the Russia Sanctions Act and its Regulations apply to “New Zealand persons” which means:

All individuals in New Zealand regardless of their nationality or resident status.
All New Zealanders (citizens and those ordinarily resident in New Zealand) no matter where they are in the world.
All New Zealand businesses and organisations no matter where they are operating in the world.
All overseas businesses registered in New Zealand in respect of their activities connected to New Zealand. This includes the overseas activities of a New Zealand branch.

New Zealand enforcement agencies will look for a connection to New Zealand – such as actions by a New Zealand citizen or a New Zealand branch – when considering enforcement action relating to overseas activities.

There is an exception that allows New Zealanders in Russia to use the services of a sanctioned company, where necessary, for personal or household purposes, e.g. utility services. There are some other exceptions that could also apply – find out more about permitted activities [PDF, 717 KB].

There are civil and criminal liabilities for those who do not comply with the sanctions.

What is prohibited by the sanctions?

There are currently seven types of prohibitions:

Travel bans	Designated individuals are prohibited from travelling 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 Belarusian military and government owned or controlled aircraft and ships are banned from New Zealand airspace and ports. Aircraft and ships owned, operated, or chartered by sanctioned individuals cannot enter New Zealand.
Assets	New Zealanders and New Zealand-based businesses, individuals and entities are prohibited from dealing with the assets of sanctioned individuals and entities. This prohibition does not apply to securities (as defined in the Regulations). One effect of this prohibition is that designated individuals and entities and their associates are prevented from using any assets they hold in New Zealand (essentially an asset freeze). This includes bank accounts and personal property. New Zealanders and New Zealand-based businesses, individuals and entities are also prohibited from entering into financial transactions with, by, or on behalf of sanctioned individuals and entities. In addition, New Zealanders and New Zealand-based businesses, individuals and entities must not deal with any asset if doing so would be for the benefit of a sanctioned person. Where a duty-holder (as defined under the Anti-Money Laundering and Countering Financing of Terrorism 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.
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	New Zealand 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 sanctions measures, they have a duty to report it to the Police. New Zealand has implemented the G7 Plus oil price cap by prohibiting certain services in relation to maritime transport of Russian origin oil and oil products unless the oil is purchased below the specified price.
Exports	New Zealand has prohibited the export of a range of goods to Russia and Belarus, including products that are closely connected to strategic Russian industries. The export prohibitions on certain luxury goods, and some oil exploration and oil production products only apply to Russia. Banned exports are listed in the sanctions register. The export bans apply broadly and include, for example, goods received in a third country for on-forwarding to Russia or for the benefit of Russia. Outside of the Russia Sanctions Act, goods intended for the Russian and Belarus military, security and police sectors are banned from export (see here for further information). New Zealand also maintains a comprehensive export control scheme for the export of other controlled goods to Russia and Belarus. More information on New Zealand’s export control measures is available here. See [link to Information for Importers and Exporters] for further information.
Imports	There is a 35% tariff on all imports of Russian origin. This is not normally applied to goods in low value consignments of less than NZ$1,000. New Zealand has prohibited the import of: Gold of Russian origin Oil, gas and coal of Russian origin (guidance on determining the origin of energy products is available here) Certain luxury goods of Russian origin (including caviar, vodka, cigars, perfumes, jewels, and precious metals). See Information for Importers and Exporters for further information.

What is the oil price cap?

New Zealand is part of a coalition of countries implementing the G7 Plus price cap on Russian-origin oil.

The oil price cap works by prohibiting services supporting the maritime transport of Russian-origin oil unless the oil was purchased at or below a specified price (called the G7 P plus price cap). This aims to reduce Russia’s earnings from its export of oil, whilst maintaining the supply of Russian oil to world markets and reducing upward pressure on international oil prices.

New Zealand implemented the cap in April 2024 through the Russia Sanctions Regulations, prohibiting certain services in relation to maritime transport of Russian- origin oil and oil products unless the oil is purchased below the price cap. This applies even where there is no sanctioned person or business involved. The four prohibited services are brokering, financing, financial assistance and insurance. New Zealand has also imposed an import ban on coal, oil and gas products of Russian origin.

MFAT issued a guidance note in June 2024 concerning prohibited services for maritime transport of Russia oil - available here.

Complying with sanctions – What you need to know

Complying with sanctions – What you need to know?

We encourage a self-compliance approach, so have provided New Zealanders with information and guidance [link to Guidance page] to help you comply.

We also encourage you to report any issues, suspicious activity or suspected breaches, with the confidence that you won’t automatically be penalised, provided there was no deliberate attempt to violate sanctions.

If you see suspicious activity or suspect a breach:

File a non-emergency report with the Police online. Select the option for ‘Russia Sanctions breach’: 105 Police Non-Emergency report
Or if you are a duty holder (as defined under the AML/CFT Act), report suspicious activity and suspected sanctions breaches through the goAML portal.

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 regularly 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.

What sanctions have been imposed on Belarus?

A number of Belarusian individuals and entities are sanctioned (check the sanctions register).

Certain export prohibitions apply to Belarus as well as Russia. The HS codes and descriptions for prohibited items can be found in the sanctions register.

These sanctions recognise that Belarusian leaders and defence entities are supporting Russia’s aggression against Ukraine.

The 35% import tariff, import prohibitions, export prohibitions on certain oil exploration and oil production goods, and the export prohibitions on luxury goods only apply to Russia.

Are there any exceptions?

When do these measures end?

What other sanctions has New Zealand imposed?

What about foreign sanctions laws?

New Zealand sanctions are aligned with those of like-minded countries from Asia- Pacific, Europe and North America, including Australia, Japan, the United Kingdom, the European Union, the United States and Canada. Together we aim to exert pressure on Russia to change course, by limiting its ability to finance and equip the war in Ukraine.

In addition to considering New Zealand sanctions, it is important you consider the wider legal and commercial context of your trade and investments. It may be necessary to seek your own legal advice on the sanctions laws of other countries, including the United States, which might apply to your specific context. For example, violating foreign sanctions laws, such as those of the United States, can have serious legal and financial consequences even for those not resident in or citizens of the United States.

You may also wish to consult in advance with your financial institution to ensure that any payments from Russia can be accepted, as some banks have made the commercial decision to restrict their dealings with Russia due to US and other countries’ sanctions laws. The New Zealand Government is not in a position to provide advice on the implications of US other countries’ sanctions laws.

Find out more about the sanctions imposed on Russia by our like-minded partners:

Australia
Canada
European Union
- Sanctions adopted following Russia's military aggression against Ukraine
- EU restrictive measures against Russia over Ukraine (since 2014)
Japan
United Kingdom
United States of America
- Sanctions and Export Controls on Russia
- Office of Foreign Assets Control – Sanctions Programs and Information

Is travel between Russia and New Zealand affected by the sanctions?

Sanctioned individuals and their associates may not travel to New Zealand. Non-sanctioned Russian passport holders may travel to New Zealand if the relevant visa requirements are met.

New Zealand passport holders require a Russian visa to visit Russia. However, travel by New Zealanders to Russia is strongly discouraged at this time. As at June 2025, New Zealanders are advised 'Do not travel' to Russia due to the impacts the armed conflict with Ukraine has had, including on commercial flight availability and access to financial services. There is also potential for the security situation to deteriorate further with little warning.

Please check the SafeTravel website to see the New Zealand Government's most up to date travel advice.

How has Russia responded?

In response to the measures by New Zealand, Russia has put New Zealand on a list of countries that commit so-called ‘unfriendly’ acts against Russia. Measures include:

Debts from Russians to creditors from these countries can now only legally be paid in Rubles rather than foreign currency.
Citizens and companies from these countries face higher barriers when moving their capital out of Russia.
Business deals, with these countries will require approval from a commissions for monitoring foreign investment, managed by the Russian Ministry of Finance.

What has the impact of the trade measures been?

Before the invasion, Russia made up 0.13% of New Zealand’s total goods imports; and 1% of overall New Zealand exports. Crude oil was our main import until the closure of Marsden Point, and dairy was our single largest export product. New Zealand imports of Russian products mainly consist of fertilisers, building materials and copper wire. Within these sectors, trade with Russia made up less than 10% of total imports before the invasion.

Since Russia’s invasion, there has been a significant decrease in imports from, and exports to Russia, as New Zealand’s trade sanctions have taken effect and businesses have made their own decisions about whether to remain in the Russian market. Up to date trade statistics are available on the Stats NZ website.

Placing a punitive tariff of 35% on goods of Russian origin denies foreign exchange to the Russian Federation to help finance their aggression. It also closes off New Zealand from the possibility of Russian products being unloaded on New Zealand and undermining other similar efforts by our partners. While our trade with Russia is relatively small, our trade measures send a strong signal of our condemnation of the Russian Government’s actions in Ukraine.

As with other members of the international community who have taken such action, we consider these trade measures are consistent with WTO rules, and are warranted in response to Russia’s war of aggression in Ukraine. World Trade Organisation (WTO) rules include a national security exception which enables WTO Members to take ‘any action’ they consider necessary to protect their essential security interests ‘in time of war or other emergency in international relations’.

International sanctions have had a broader impact on supply chains and shipping routes. Many of the major shipping lines have suspended deliveries of non-essential goods to Russia itself. While freight connections for essential goods may still be functioning, there are blockages elsewhere in the system. Measures imposed by others like sanctions, restrictions on financial transfers, and restrictions at ports may impede flows of freight.

Has the Russia Sanctions Act been reviewed?

In early 2023, the Ministry of Foreign Affairs and Trade (MFAT) commissioned an independent review of the Russia Sanctions regulatory framework (including related policies, processes, systems and controls). The review was undertaken by David Smol and the Review Report is available here.

A Statutory Review of the Russia Sanctions Act (RSA) as required by section 29 of the RSA. The review is currently underway, focused on examining the operation and effectiveness of the RSA. The Terms of Reference are available here.

Submissions closed in December 2024.

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