United Nations Sanctions Act 1946 / Russia Sanctions Act 2022¶


Regulator	Ministry of Foreign Affairs and Trade
Jurisdiction	NZ
Status	live
Applicability	Platform

New Zealand's financial sanctions obligations derive from two instruments administered by the Ministry of Foreign Affairs and Trade (MFAT). The United Nations Sanctions Act 1946 gives effect to UN Security Council binding resolutions in domestic law, including targeted financial sanctions and arms embargoes. The Russia Sanctions Act 2022 established a separate autonomous sanctions regime following the invasion of Ukraine and created the legal basis for MFAT to designate individuals and entities independently of a UN resolution.

Reporting entities (including registered banks) must screen customers, counterparties, and payment beneficiaries against the NZ Consolidated Sanctions List — which incorporates UN Security Council designations, Russia Autonomous Sanctions designations, and any other autonomous designations made under the Act — and must not deal with, or make assets available to, a designated person or entity. There is no minimum-value threshold; all transactions involving a designated party are prohibited.

The Russia Sanctions Act 2022 is supplemented by the Counter Terrorism Financing Act (FATF R.6 and R.7 obligations) and the Terrorism Suppression Act 2002. For operational purposes, these are all satisfied through the same sanctions screening programme — AML-007.

Compliance register¶

This register maps every material obligation under the Acts to the platform control or institutional process that satisfies it. It is the static traceability layer for the Totara compliance report — dynamic data (module build status, test evidence, control test dates) is overlaid at runtime.

Scope legend¶

Symbol	Meaning
🤖 Automated	Platform enforces or performs the obligation. Primary control mode is GATE, AUTO, CALC, or ALERT. Human action is not required in the normal case.
📊 Evidenced	Platform captures the evidence trail automatically. Human compliance decision sits on top. Primary control mode is LOG.
🏛 Institutional	Obligation is met by a process entirely outside the platform — training programmes, board governance, HR, legal. Platform may generate evidence inputs but does not own the process.
N/A	Obligation does not apply to this deployment configuration.

Build legend¶

Symbol	Meaning
✅	Module built and deployed
🔨	Module planned — not yet built (`build_status: Not started`)
❌	Uncontrolled gap — no module attributed

Screening obligations¶

Obligation	Scope	Policy	Platform controls	Build
Screen all customers and counterparties against the NZ Consolidated Sanctions List at onboarding and on an ongoing basis	🤖 Automated	AML-007	MOD-013 (GATE) — no payment to or from a confirmed sanctions match; hard gate, not advisory; sanctions hit blocks activation and payment	🔨
Continuous rescreening — re-screen existing customers when a new designation is added to any list	🤖 Automated	AML-007	MOD-014 (AUTO) — existing customers rescreened against new designations without manual trigger; no gap between list update and rescreening	🔨
Pre-payment sanctions screen — screen all payment beneficiaries before funds are committed	🤖 Automated	AML-007	MOD-020 (GATE) — sanctions screening is a mandatory pre-payment gate; cannot be bypassed regardless of account relationship	🔨
Correspondent and intermediary screening — screen all payment routing counterparties	🤖 Automated	AML-007	MOD-154 (GATE) — every correspondent and named intermediary screened before routing; sanctions hit blocks payment regardless of prior approval	🔨
Tipping-off prohibition — must not inform a designated person that they have been screened or that a freeze has been applied	🤖 Automated	AML-007	MOD-013 (GATE) — freeze and block operations occur at the system layer; no notification is generated to the customer when a sanctions block is applied	🔨
Proliferation financing — screen against UN Security Council PF designation lists (FATF R.7)	🤖 Automated	AML-007	MOD-013 (GATE) — PF designation list coverage included in the sanctions screening engine alongside UN and NZ lists	🔨

Evidence and audit obligations¶

Obligation	Scope	Policy	Platform controls	Build
Record false positive adjudication — document the reasoning when a potential match is determined not to be a designated person	📊 Evidenced	AML-007	MOD-015 (LOG) — false positive decisions recorded with analyst ID, reasoning, and list reference; auditable by MFAT	🔨

Institutional obligations (not platform scope)¶

The following obligations are the responsibility of the institution, not the platform. The platform may generate evidence inputs but does not own these processes.

Obligation	Owner	Platform evidence input
Report to MFAT when a sanctions match is confirmed or an asset freeze is applied	Chief Compliance Officer	MOD-013 generates the sanctions hit record; human compliance officer makes the MFAT notification
Respond to MFAT requests for information about designations	Chief Compliance Officer	MOD-015 provides the adjudication log and match record for disclosure to MFAT
Maintain MFAT notification register	Chief Compliance Officer	Institutional record; platform provides the source data via MOD-013 and MOD-015
Train staff on NZ sanctions obligations and updates	Chief Compliance Officer / Chief People Officer	Institutional LMS; not platform scope

Coverage summary¶

Area	Total obligations	Platform automated 🤖	Platform evidenced 📊
Screening	6	6	0
Evidence and audit	1	0	1
Total	7	6 (86%)	1 (14%)

All obligations have attributed controls. All attributed modules are currently build_status: Not started — the compliance position will update as modules are built and deployed.

Policy	Title
AML-007	Sanctions Screening Policy

See NZ AML/CFT Act 2009 for the primary AML/CFT framework. See D03 AML / Financial Crime for the full risk domain.

Official documentation¶

Policies referencing this standard¶

AML-007 — Sanctions Screening Policy

Compiled 2026-05-22 from source/entities/regulations/nz-sanctions-act.yaml