The regime is effective and aligned with international frameworks.

Agreed - Early complexity has largely been resolved, and the regime is maturing well.

No expansion of AML/CFT Supervisors’ roles. 

Inter-agency overlaps (e.g. MFAT–Customs) should be clarified.

We support MFAT retaining oversight. 

We recommend joint MFAT–Customs guidance. 

We agreed that AML/CFT Supervisors should not have an express role under the RSA.

Update and clarify guidance on reporting obligations under the RSA. 

Retain the current SAR threshold and 3-day reporting timeframe. 

Avoid introducing dual reporting to both Police and MFAT; instead, enable automated sharing of SARs between agencies. 

Introduce proportionate pecuniary penalties for failure to report under Regulation 11(4). 

Maintain the current definition of duty holders and avoid extending reporting obligations to non-duty holders. 

List sanctioned associates and relatives by name to reduce compliance burdens and improve clarity. 

Amend the RSA to confirm that designation notices are not secondary legislation.

Agreed - Retain the current SAR threshold and 3-day reporting timeframe.

We oppose dual reporting to Police and MFAT; automated FIU sharing of SARs with MFAT is preferable, with early MFAT involvement essential for managing frozen funds.

We support proportionate pecuniary penalties for failure to report under Regulation 11(4).

We support maintaining the current definition, but agree that targeted obligations for high-risk non-duty holders may be appropriate

We strongly support removing the ‘associate’ concept and listing known individuals by name to reduce compliance burdens.

Agreed - Designation notices should not be treated as secondary legislation.

Align the definition of “New Zealand person” across the RSA and RSR. 

Provide guidance on cross-border application and enforcement. 

Amend RSA to clarify enforcement jurisdiction over individuals found in New Zealand.

Agreed - Align the definition of ‘New Zealand person’ across the RSA and RSR.

We support additional guidance to clarify cross-border application and enforcement, especially as global designations increase.

Agreed - regulation should focus on entities with a clear New Zealand nexus, to avoid conflict of laws scenarios.

We recommend creating an exemption for offshore conduct subject to foreign sanctions laws.

Update the Regulatory Charter and enforcement guidance to clarify agency roles and responsibilities. 

Empower MFAT to compel information from duty holders and share relevant data with other compliance agencies. 

Consider expanding civil enforcement tools to include pecuniary penalties, enhancing flexibility and deterrence.

Agreed - Clearer guidance on agency roles is needed.

We support expanding civil enforcement tools, but do not support MFAT being granted statutory information-gathering powers

We support expanding civil enforcement tools to include pecuniary penalties. The current regime lacks flexibility and deterrence, relying too heavily on criminal proceedings, which are rarely pursued due to evidentiary and diplomatic constraints. As a result, enforcement actions to date have been limited.

Civil enforcement under sections 21–23 of the RSA should be strengthened in future legislative updates.

Amend section 13 to expressly enable the Minister to initiate a review of a sanctions decision and grant an exemption, recommend an amendment or revocation, without having received a request. 

Amend section 13(1) to remove ‘on the basis of humanitarian need’ to clarify the broad circumstances in which an affected person or entity can apply for an exemption, amendment, or revocation. 

Expressly state in the RSA that there is no right to natural justice before a sanction is imposed.

Update existing guidance to explain the scope and application of the section 13 exemption power.

Agreed - Amend section 13 to allow the Minister to initiate reviews and grant exemptions without a formal request.

Removing the “humanitarian need” qualifier would clarify the broader grounds for exemptions.

We support introducing a permit system to authorise otherwise prohibited conduct, aligning New Zealand with international practice.

Updated guidance on section 13 would be helpful.

Clarify the implicit duty to freeze under regulations 10 and 11, with practical guidance for different asset classes. 

Refine definitions and terminology used in export prohibitions, including clearer guidance on “Russian origin.” 

Exclude goods exported from Russia prior to 1991 from import restrictions. 

Exempt medicines and medical equipment from export prohibitions. 

Strengthen monitoring for sanctions evasion and expand prohibitions where gaps are identified.

We strongly support clearer freezing obligations under regulations 10 and 11, with practical guidance for different asset classes.

Agreed - Refine definitions, exempt pre-1991 Russian goods, and exclude medical items.

We support enhanced monitoring and targeted expansion of prohibitions where gaps are identified.

Publish clearer public guidance on key definitions raised during consultation. 

Ensure consistent use of terminology, replacing “sanctioned” with “designated” throughout the RSR to align with the RSA.

We support consistent terminology but recommend using ‘sanctioned’ throughout the RS Regime to align with international practice.