Financial Intelligence Unit Conference - Russia sanctions

Foreign Affairs


Whakataka te hau ki te uru,

Whakataka te hau ki te tonga.

Kia mākinakina ki uta,

Kia mātaratara ki tai.

E hī ake ana te atakura.

He tio, he huka, he hauhū

Tihei Mauri Ora!

Tena koutou katoa.


Tēnā koutou katoa

Thank you for inviting me to join you here today.

Te Papa Tongarewa means ‘container of treasures,’ or in full, ‘container of treasured things and people that spring from mother Earth here in Aotearoa New Zealand’.

In many ways the name is relevant to today’s conference. Te Papa is a mirror. It reflects our country’s past, present and future, our people, our identity, our values, our connections to this land, and our place in the world. 

Our response to Russia’s illegal invasion of Ukraine is a reflection of those values we uphold and how we seek to assert what we stand for.

We have been unequivocal in choosing to stand firm with those who share our commitment to the international rule of law, state sovereignty and human rights.

Being clear on what we stand for matters. Knowing that we are a trusted and reliable friend willing to stand up for our values matters.

This is especially so when the rules and norms of international law are breached, and the threat of instability, insecurity and war hang over us.

How and why we responded to Russia’s invasion of Ukraine

We have embarked on a completely new area for our country, never having a country-specific sanctions regime until now.

It’s been a journey, and one that a number of you here in this audience have traversed along with us.

I want to reflect a little on how we arrived here.

On 24 February, Russia broke international law by invading its neighbour Ukraine.

It invaded on three fronts, representing the biggest attack by one state against another in Europe since World War II.

Russia’s invasion has caused the biggest humanitarian crisis on the continent since 1945.

It has taken a deep toll on people and their communities, and such actions have mobilised many likemindeds across our international community.

There’s a temptation by some to characterise Russia’s actions as the West versus Russia, or democracy versus autocracy.

But what it really comes down to is simple, and it’s something that New Zealanders instinctively get: one sovereign country invaded another.

A country with a permanent seat at the United Nations Security Council and nuclear weapons in its arsenal invaded, by land, air and sea, its smaller, democratic neighbour.

This is unacceptable.

Russia’s invasion presented a direct attack on the UN Charter and the rules-based international order.

These recognise that each country, no matter its size, wealth or power, has an inalienable right to have its territorial integrity and sovereignty respected.

That the power of the large should be moderated to protect the interests of the small. That we should resolve issues peacefully and fairly.

I cannot overstate how dear these principles are to us. As a small trading nation, we rely disproportionately on the rules-based order for our own security and prosperity.

Russia’s invasion is an affront: To Ukraine. To us. To the international community. To our multilateral institutions.

New Zealand has always been a believer in multilateral tools and diplomacy.

We looked to the UN Security Council for a swift and appropriate response. Regrettably, Russia’s abuse of its veto power prevented that from happening.

Drawing on our values, we have instead responded autonomously, as a nation.

We are providing military assistance to support Ukraine’s right to defend itself.

In the UK, we are training Ukrainian troops and supporting intelligence efforts.

We have deployed our people and our assets to facilitate the flow of supplies to Ukraine.

We have provided humanitarian assistance to refugees and those still inside Ukraine.

We are also making a significant contribution to the international legal efforts to hold Russia accountable, and we are supporting Ukraine at the International Court of Justice.

The thinking behind sanctions

Just prior to Russia’s illegal invasion of Ukraine I was in Paris attending an Indo-Pacific summit.  And it was evident across the EU and other likemindeds collective, decisive actions by way of sanctions were needed to respond to Russia. 

We implemented unilateral sanctions for the first time ever.

The purpose of our sanctions is to join with others to put pressure on Russia to change its behaviour, including through limiting President Putin’s ability to finance and equip his war. 

Prior to the Russia Sanctions Act, the Government could only give effect to sanctions that were authorised by the Security Council.

That doesn’t mean we couldn’t do anything in the wake of Russia’s invasion – we can and we did, for example by imposing travel bans, and expanding our export controls.

But this wasn’t nearly enough.

Two weeks after the invasion, all members of our Parliament from across the political spectrum adopted, under urgency, the Russia Sanctions Act.

One week later, I announced our first tranche of sanctions.

Since that time, Aotearoa New Zealand has rolled out 14 rounds of sanctions.

The framework for sanctions allows us to evolve dependent on the situations on the ground in Ukraine.

It provides us with the ability to carefully examine the relationships and identify individuals and companies that meet the legal threshold so that we can have the greatest impact on Russia's ability to wage war.

We are able to stop or restrict people or companies from:

  • travelling to or from New Zealand, or staying here if they're already here;
  • moving assets to New Zealand or using assets already here;
  • providing or using services like banks, loans, legal services.

This means that we can, for example,

  • stop the purchase or sale of property,
  • stop the movement of marine vessels, ships, yachts, and planes in New Zealand's waters or airspace,
  • stop imports and exports,
  • stop the lending of money, or the movement of money.

In total, we have sanctioned more than 1,200 individuals and entities.

This includes President Putin and key members of his inner circle, oligarchs and other elites, as well as key Russian defence, financial and economic actors.

We have also sanctioned individuals and entities in the nation of Belarus for its assistance to Russia’s invasion.

Our sanctions automatically extend to relatives and associates of listed persons, reflecting the reality that these individuals are often otherwise easy options to avoid and evade sanctions.

Our regulations include asset freezes, prohibitions on dealing with services and securities, prohibitions on travelling to New Zealand, and a ban on entry into New Zealand by certain aircraft and vessels.

While our Act and regulations are broad, our sanctions can be made specific with the prohibitions we decide to apply.

Together with my colleague, the Minister for Trade and Export Growth, we have also joined international partners to impose some of the most significant trade measures against a major economy using our Act.

We have banned the import of Russian oil, gas, coal, and gold, as well as certain luxury goods.

There is a 35% tariff on all other Russian imports above a $1,000 value coming into New Zealand.

We have a growing list of export prohibitions to both Russia and Belarus, including luxury goods, and goods of strategic importance that might be used by or adapted for Russia’s war machine.

Many New Zealand companies, appalled at Russia’s invasion, also made the decision, independent of our sanctions, to cease or suspend business with Russia.

Those are commercial decisions, but they reflect the depth of New Zealanders’ abhorrence with Russia’s actions. 

The role of the Minister of Foreign Affairs

I want to turn now to reflect briefly on my role, and on yours. They are interconnected.

Under the Act, I am the decision maker.

In imposing sanctions on an individual or entity, I have to be satisfied that the sanctions are appropriate to respond to and condemn Russia’s invasion.

They must be designed to exert pressure on Russia, or to complement and reinforce the sanctions imposed by other countries.

I consider these points each time we impose sanctions.

As we chart this new territory, we also have the ability to amend our regulations if we consider that there may be an unintended consequence or if the regulations are not working as intended.

The role of Police, central agencies, banks and other institutions

You play a key role in Aotearoa New Zealand’s sanctions response.

While our sanctions are new for everyone, some of the practices underpinning them are not.

There is overlap between the responsibilities under our sanctions, and the requirements under our money laundering and financing of terrorism laws.

The principles of due diligence are the same.

Your obligations to report suspicious activity to the FIU are the same.

You know your business and customers best.

We rely on you to apply your insight and ensure our sanctions work as intended.

Please continue to think about the Russia sanctions perspective in your work, and continue to report any suspicious activity.

Please also reach out to the Russia Sanctions Taskforce if you have any questions or concerns. You can find their contact details on MFAT’s website.

Thank you for playing your part.

For our sanctions to work – for us to join others and put as much pressure as possible on Russia to end its senseless war – we rely on you. 

To make sure we’re not inadvertently supporting Russia’s war machine, or offering an alternative destination for those seeking to find safe havens from sanctions, we rely on you.

I want to acknowledge you.

I also want to thank those here from across Government agencies supporting this important work, and the FIU for its pivotal role.

Next steps

Looking ahead, there appears to be no signs that Russia is prepared to cease its illegal aggression. It has dug in.

Ukraine’s recent successes in the war and its determination to halt and roll back the Russian incursions is remarkable.

Our contribution to train Ukrainian soldiers, together with our partners, is also having an impact.

Sanctions have not stopped this illegal war. But they are taking a toll.

We know for example that Russia is finding it increasingly hard to source items it previously imported to sustain its forces’ advanced weaponry.

Its economy is shrinking, and foreign investment has significantly decreased.

While Aotearoa New Zealand has less direct exposure and dealings with Russia than some other countries, we are playing our part.

And we do want to see an endpoint, the cessation of war and an enduring peaceful solution.  As dim as that prospect might look right now, we must continue to advocate for upholding the international rule of law, the maintenance of peace and stability at a time where no-one benefits from a protracted war.


To conclude, I wish you well for the rest of your conference.

And as we approach the end of the year, I also wish you and your whānau a safe and restful break.

Please be assured that Aotearoa New Zealand remains committed to continuing our work through the Russia Sanctions Act, and with you, to put pressure on Putin and his cronies.

We aren’t done yet.