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The Russia Sanctions Act imposes obligations on ‘duty holders’ as reporting entities under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the AML/CFT Act) or any other person declared a duty holder by subsequent regulations.
The Regulations have declared a number of people as duty holders. See Regulation 19(external link) for details.
Summary of obligations for duty holders
There are three types of obligation imposed on duty holders: assets and services obligations, reporting obligations and due diligence/monitoring obligations.
Assets and services obligations |
The Russia Sanctions Act imposes a range of prohibitions on dealing with assets and services:
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Reporting obligations | Under the AML/CFT Act, duty holders are required to report certain suspicions to the Police in relation to certain assets, services and persons. The list of designated assets, services and persons are set out in the Regulations and in the sanctions register. AML/CFT duty holders report suspicious sanctions-related activity through the goAML(external link) portal, using the same process as for AML/CFT suspicious activity reports. If you are not a duty holder for AML/CFT purposes report using the process outlined on the Police 105 website(external link). |
Due diligence obligations | While duty holders have specific obligations in the Act, all New Zealand persons who may deal with restricted persons, assets and services must ensure that they are not in breach of the sanctions. This will involve some level of due diligence checks, depending on the type and risk of activity, to ensure the individuals or entities connected with a proposed activity are not subject to relevant sanctions. |
Guidance and useful links
- Guidance note: Duty holder reporting under the Act [PDF, 1.1 MB]
- Guidance note: Banking transactions [PDF, 947 KB]
- Guidance note: Understanding Evasion Risk and Due Diligence in the Russia Sanctions Context [PDF, 772 KB]
- Guidance note: Impact of Russia Sanctions on AML/CFT reporting entities – AML/CFT supervisors(external link)
- Sanctions Alert – March 2022: Russia Sanctions Act passed under urgency – Police(external link)
- Sanctions Alert – March 2022: Russia Sanctions Regulations 2022 enacted – Police(external link)
- Access GoAML – Financial Intelligence Unit (FIU) | New Zealand Police(external link)