The Russia Sanctions Register is the Ministry of Foreign Affairs and Trade's (MFAT) list of every person, entity, ship and asset sanctioned under New Zealand's Russia Sanctions Act 2022. If a supplier or customer is on it with an asset freeze, a New Zealand business cannot deal with their assets or pay money for their benefit.
For the basics of how sanctions lists work, start with what a sanctions list is.
How does New Zealand impose sanctions?
New Zealand has two routes. MFAT's UN sanctions page describes both.
- UN sanctions. MFAT says: "We implement sanctions imposed by the UNSC in regulations made under the United Nations Act 1946." Each UN regime gets its own set of regulations. MFAT's page lists current regulations for regimes including North Korea, Libya, Somalia, South Sudan, the Al-Qaida and Taliban regime, Iran (2025) and Haiti (2026). MFAT also says "A breach of the sanctions regulations is a criminal offence."
- The Russia Sanctions Act 2022. Parliament passed it unanimously on 9 March 2022, according to MFAT's overview of sanctions against Russia. It gives the Minister of Foreign Affairs "the ability to impose sanctions in response to threats to the sovereignty or territorial integrity of Ukraine." The actual measures sit in the Russia Sanctions Regulations 2022.
Does New Zealand have a general autonomous sanctions law?
No. Australia can sanction people for serious corruption or human rights abuses without a UN decision, as our guide to Australia's Consolidated List explains. New Zealand has no law of that kind.
MFAT puts it this way. In addition to UN sanctions, "New Zealand has standalone legislation to impose sanctions independent of the UNSC" that applies "in response to military actions by Russia (and others) in Ukraine or any other country". That is the Russia Sanctions Act.
MFAT's statutory review of the Act, presented to Parliament in November 2025, found the Act and its regulations "are fit for purpose and are working as intended." It made 29 recommendations. It also said that whether New Zealand should have a general autonomous sanctions regime was outside its scope.
MFAT's UN page also mentions travel bans on people linked to the Lukashenko regime in Belarus and on Myanmar's military leaders. MFAT describes both as travel bans.
Who must comply with New Zealand's Russia sanctions?
MFAT's overview says the sanctions apply to:
- "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."
Size makes no difference. A sole trader in Napier is covered in the same way as a bank in Auckland.
What does the Russia Sanctions Act prohibit?
The Regulations set out several kinds of sanction. The register shows which ones apply to each entry, in columns for travel ban, asset freeze, aircraft ban, ship ban, service prohibition and dealing with securities.
For a business paying suppliers and invoicing customers, the asset and service rules matter most. MFAT's overview says New Zealanders and New Zealand businesses:
- "are prohibited from dealing with the assets of sanctioned individuals and entities"
- "must not deal with any asset if doing so would be for the benefit of a sanctioned person"
- are "prohibited from entering into financial transactions with, by, or on behalf of sanctioned individuals and entities"
Services are covered too. The overview refers to services "extended to, offered to, or received from sanctioned individuals or entities."
MFAT sums up the effect on the sanctioned side: designated individuals and entities "and their associates are prevented from using any assets they hold in New Zealand (essentially an asset freeze)." Its financial sector page adds that this "includes bank accounts and personal property."
Check which measures apply to the entry before you act. Not every listed person is under an asset freeze, and the Act allows some exceptions and case-by-case exemptions. Where the asset and dealing prohibitions apply, do not pay a listed supplier, even for work already done. Do not supply a listed customer, and do not route either through someone else.
Trade measures
The Act also restricts trade. MFAT's overview says "There is a 35% tariff on all imports of Russian origin" and that "The export bans apply broadly." The register's Trade Measures sheet lists the banned goods by Harmonised System (HS) code. A separate sheet covers services linked to the oil price cap.
What is in the Russia Sanctions Register?
MFAT's register page says it holds the "names and details of sanctioned individuals and entities, ships", along with the type of sanction and trade measures. MFAT says you "can search and filter the list."
The workbook has five sheets:
| Sheet | What it holds |
|---|---|
| Russia Sanctions Register | Individuals, entities, banks and classes of sanctioned assets, with the sanctions that apply to each |
| Ships | Sanctioned vessels by IMO number, with former names |
| Trade Measures | Import and export bans and the tariff, by HS code |
| Trade Measures - Oil Price Cap | Petroleum products under the oil price cap service ban |
| Exemptions | Exemptions MFAT has granted, by regulation number |
The main sheet starts with a short legend. The column headings begin on row 8. Each entry can carry a first, middle and last name, aliases and alternate spellings, date of birth, address, place of birth, up to three citizenships, a passport number, and a column for associates and relatives.
The file we downloaded on 16 October 2026 was the one MFAT's page dated 9 September 2026. Its main sheet held 1,389 individuals, 512 entities, 17 banks and 7 classes of ships and aircraft linked to Russia. Every individual, entity and bank in it was marked "Yes" for asset freeze. The Ships sheet listed 210 vessels.
Where do you download it?
The register is a single Excel (XLSX) file, about 21 MB, linked from MFAT's Russia Sanctions Register page. It downloads without an account. The same page lists the designation notices as PDFs and links to an email subscription for updates.
How often does the register change?
MFAT says the register is "regularly updated as the sanctions regime matures and responds to the invasion of Ukraine." It gives no fixed schedule.
MFAT's latest updates page shows the pace in 2026:
- 20 February 2026: 23 individuals, 13 entities and 100 vessels designated. The oil price cap was lowered to 44.10 USD.
- 7 May 2026: 11 entities and 9 individuals designated.
- 7 August 2026: 9 entities and 24 individuals designated.
- 3 September 2026: some of the 7 August amendments came into force, and the register was updated.
That is roughly one round every two to three months. A contact you cleared in June can be listed in August, so recheck after each update. The Regulations themselves were extended on 21 February 2025 to 17 March 2028.
What are the reporting duties?
The duty to report falls on "duty holders". MFAT's guidance, Reporting under the Russia Sanctions Act (version 2.0, 7 August 2026), defines them as:
- reporting entities under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (AML/CFT Act)
- traders who buy or sell certain goods with a total value of $10,000 or more, including jewellery, watches, precious metals and stones, art, cultural artefacts, motor vehicles and ships
A duty holder must report if it suspects on reasonable grounds that it holds or controls assets that are designated, or owned or controlled, directly or indirectly, by a designated person. The same applies if it is dealing, or about to deal, with designated services or services for a designated person.
The guidance sets two obligations. First, freeze: stop all activity with the asset or the service. Second, report the details.
The deadline is short. MFAT's guidance says the Act requires duty holders to report "no later than 3 working days" after forming the suspicion.
Reports go to the Police Financial Intelligence Unit (FIU). Duty holders with a goAML login file a Suspicious Activity Report or Suspicious Transaction Report through goAML. Those without one use the Police 105 website and choose the "Russia Sanctions breach" option. An urgent matter can be reported to Police verbally first. The duty holder must then file the written report with the FIU as soon as practicable.
MFAT's examples cover real estate agents, accountants, lawyers and banks. If your accounting practice is an AML/CFT reporting entity, this duty applies to you. Our guide to sanctions compliance for accountants covers how screening fits into client onboarding.
If you are not a duty holder
MFAT's guidance says: "If you are not a duty holder, you are not required to report information relating to Russia sanctions." You can still report a suspected breach through the Police 105 website. The ban on dealing with sanctioned assets applies to everyone in scope, whether or not you have to report. General questions go to MFAT at [email protected], according to its who to contact page.
What are the penalties?
MFAT's overview says: "It is a criminal offence to breach a sanction in the Act."
| Who | Maximum penalty |
|---|---|
| Individual | Up to seven years' imprisonment or a fine not exceeding NZ$100,000 |
| Entity | A fine not exceeding NZ$1 million |
There is no size threshold. The penalties apply to a small business in the same way as a large one.
What should a New Zealand business on Xero check?
- Export your contacts. Pull suppliers and customers from Xero, with names and addresses. Our guide on how to check Xero contacts against sanctions lists walks through the export step by step.
- Download the latest register. Check the date next to the file on MFAT's page before you start.
- Search the main sheet. Search by surname, or by the main word of a company name, rather than the full name. Search the alias column too. Russian names are transliterated in more than one way, so try spelling variants.
- Check owners and directors. MFAT's guidance asks duty holders to identify "associated entities" and consider whether dealings "relate to, or benefit" a sanctioned person. Look up who owns your larger overseas contacts, and check the associates and relatives column.
- Check ships and goods if you trade. Freight and shipping businesses should search the Ships sheet by IMO number. Importers and exporters should check the Trade Measures sheet for their HS codes.
- Compare before you decide. Treat a name hit as a lead. Compare date of birth, citizenship and address before you call it a match.
- Record the check. Note the date, the file version, what you searched and the result, including clean results.
For a likely match, stop the payment or supply. Get legal advice before you release anything. If you are a duty holder, the 3 working day reporting clock starts when you form the suspicion.
The Russia register is one list among several. A New Zealand business that trades with Australia, the UK, the EU or the US can be caught by their lists too. Our guide to Australia's Consolidated List covers the closest neighbour.
Sanctions Verified, opening to QuickBooks Online and Xero users, will screen your contacts against MFAT's Russia Sanctions Register alongside OFAC, UK, EU, UN and Australian lists. It downloads MFAT's file daily, rechecks a contact when it changes or turns up on a new bill or invoice after a list update, and keeps a dated record of each check. Until it launches, the manual steps above do the job.
This guide is general information, not legal advice.
