In late 2024 MFAT launched the Statutory Review of the Russia Sanctions Act (RSA) as mandated in section 29 of the RSA. The Review was undertaken by MFAT senior officials, on behalf of the Minister of Foreign Affairs. The review considered:
- The operation of the RSA since it entered into force on 9 March 2022.
- The effectiveness of the RSA, and whether it is fit for purpose?
- Whether the RSA strikes the appropriate balance between the risk of sanction evasion in New Zealand and the RSA’s compliance costs?
- Whether the RSA achieves its statutory purposes?
Broader questions, such as the merits and efficacy of sanctions generally, and whether New Zealand should have a general autonomous sanctions regime were outside the scope of the Review.
Stakeholders were invited to provide feedback on the RSA and Russia Sanctions Regulations (RSR) across eight topics. Public consultation was open between 29 October – 16 December 2024. MFAT received sixteen written submissions from a broad range of stakeholders. Officials also consulted relevant government agencies to identify operational issues.
The review was completed in June 2025 and provided their findings and recommendations in the Report of the Statutory Review of the RSA. In November 2025 the Minister of Foreign Affairs presented the Report to Parliament.
Overall, the Statutory Review has found that the RSA and its regulations are fit for purpose and are working as intended. The Report contains a set of 29 recommendations (see pp 17-19 of the Report) to enhance the operation and effectiveness of the RSA. These include recommendations for some targeted amendments to the RSA and RSR as well as updates to public guidance.
The Sanctions Unit has commenced a work programme to implement those recommendations as appropriate.