1. Does New Zealand have a sanctions regime in place?
As a member of the UN, New Zealand is obliged to implement the resolutions of the UNSC in respect of sanctions regimes. In New Zealand these sanctions regimes are implemented by regulations made under the United Nations Act 1946 (the “1946 Act”). Copies of the relevant regulations can be found on the Ministry of Foreign Affairs & Trade (“MFAT”) website: https://www.mfat.govt.nz/en/peace-rights-and-security/un-sanctions/ and are published in the government Gazette.
2. Does New Zealand implement UN sanctions?
3. Does New Zealand implement an autonomous sanctions regime?
New Zealand does not have an autonomous sanctions regime as such, though from time to time it may implement its own sanctions – for example, following the 2006 coup in Fiji, New Zealand put travel sanctions in place (these were lifted in 2014).
4. What is the nature of the sanctions regime in New Zealand?
Each set of regulations differ, however, they generally prohibit:
- all persons and entities in New Zealand,
- New Zealand citizens overseas; and
- entities incorporated under New Zealand law but operating outside of New Zealand.
from knowingly transferring, paying for, selling, assigning, disposing of or otherwise dealing with any asset, money or security that is owned or controlled by a Designated person or held by a specified entity and which is within New Zealand. Other restrictions in respect of trade and travel are also included within the relevant regulations.
5. Does New Zealand maintain a list of sanctioned individuals and entities?
The MFAT does not maintain a consolidated list of individuals/entities designated by the UN. The MFAT website instead provides links to the lists published by the UN.
6. Are there any other lists related to sanctions?
Yes. The New Zealand Police maintain lists of designated terrorist entities including, lists associated with Resolution 1373 and with Resolutions 1267/1989/2253 and 1988. See: https://www.police.govt.nz/advice/personal-community/counterterrorism/designated-entities/lists-associated-with-resolutions-1267-1989-2253-1988; and https://www.police.govt.nz/advice/personal-community/counterterrorism/designated-entities/lists-associated-with-resolution-1373.
7. Does New Zealand have a licensing or authorization system in place?
8. What are the consequences for a breach of sanctions in New Zealand?
Breaching regulations made under the 1946 Act is a criminal offense (section 3 of the 1946 Act). The penalty for breaching sanctions are as follows:
- for an individual – up to 12 months imprisonment or a fine not exceeding $10,000; and
- for a corporate entity – a fine not exceeding $100,000.
9. Who are the relevant regulators in New Zealand and what are their contact details?
Ministry of Foreign Affairs and Trade (“MFAT”)
Private Bag 18 901 Wellington New Zealand T: (+64) 4 439 8000 F: (+64) 4 472 9596
E: firstname.lastname@example.org (Legal Division)
Contributor law firm
The Bayleys Building
36 Brandon Street
T: (+64) 4 472 7471 F: (+64) 4 472 7871 email@example.com
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