MFAT: Russia sanctions update for DIA duty holders

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5 September 2023.

The Russia sanctions regulatory system has now been in place for 18 months. As stewards of the system, the Sanctions Unit at the Ministry of Foreign Affairs and Trade continue to remind New Zealanders of the importance of complying with the sanctions.

What you need to do

Duty holders for AML/CFT purposes are also duty holders under the Russia Sanctions Act 2022. The Act imposes three types of obligation on duty holders.

1. Freezing obligations: If you are a duty holder and have a sanctioned asset under your control or you are currently providing services to a sanctioned individual or entity, you must cease all activity by either freezing the assets and/or stopping any transactions or services involving the sanctioned individual or entity.
2. Reporting obligations: Duty holders are required to report sanctions-related 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 Russia Sanctions Regulations and in the sanctions register. Duty holders must report suspicious sanctions-related activity and suspected sanctions breaches via thegoAML portal. You can also use the Police 105 website, selecting the option for ‘Russia sanctions breach’. 
3. 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 need to satisfy themselves that they will not breach 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.