New Zealand (MFAT) — Sanctioned Vessels, Guidance & Recent Actions

New Zealand targets vessels linked to Russia’s war against Ukraine under the Russia Sanctions Act 2022 and the Russia Sanctions Regulations 2022. Two levers matter for ships: (1) being designated on the official Russia Sanctions Register (which includes a dedicated “Ships” list), and (2) being treated as a “restricted ship” under the Regulations (for example, where a ship is owned or controlled by a designated person). Together, these powers enable asset freezes, wide prohibitions on services, and transport restrictions that affect port entry and access to New Zealand maritime services. See MFAT’s consolidated guidance and the transport-sector guidance for how this works in practice.

Quick history

• March 2022 — legal framework established. Parliament enacted the Russia Sanctions Act 2022, and the Government issued the Russia Sanctions Regulations 2022, creating the basis for designations, asset freezes, and restrictions on ships and services.
• 2022–present — ongoing vessel designations. The Ministry of Foreign Affairs and Trade (MFAT) maintains the Russia Sanctions Register (Excel), which includes a “Ships” tab with each vessel’s name, IMO number, and “Date of sanction.”
• Operational guidance for ports and carriers. New Zealand transport authorities issued practical guidance on sanctioned and restricted ships, aligning harbourmasters, port companies, agents, pilots, and service providers with the Regulations.

Triggers & patterns New Zealand targets

• Ownership/control links. Ships owned or controlled (directly or indirectly) by designated persons—including state actors—can be treated as restricted ships under the Regulations.
• Explicit vessel listings. Ships may be named on the Russia Sanctions Register with their IMO number and the date of sanction.
• Circumvention and services risk. New Zealand persons must not provide prohibited services (financing, brokering, logistics, insurance, etc.) to designated persons or in ways that would circumvent the Act/Regulations; this captures many shipping-related activities.

What the sanctions entail (consequences)

• Asset freeze / dealing prohibitions. It is generally prohibited for New Zealand persons to deal with the assets or property of designated persons/entities. Where a vessel or an interest in a vessel is covered, it is treated as frozen property and may not be dealt with.
• Transport restrictions for “restricted ships.” Restricted ships can face prohibitions on port entry and on access to maritime services in New Zealand, with frontline instructions issued to port and marine operators.
• Wider services bans and offences. Providing sanctioned or restricted services that breach the Act/Regulations is an offence and exposes firms and individuals to enforcement action.

Who needs to pay attention

• Port ecosystem: harbourmasters, port companies, pilots, tug/STS operators, stevedores, bunker and ship-service providers, shipping agents.
• Commercial actors: shipowners/beneficial owners, operators and managers (technical/crewing), charterers and brokers, classification societies, insurers/P&I clubs, flag registries.
• Trade & finance: commodity traders, freight forwarders, banks and payment firms dealing with freight, insurance, or vessel-related transactions.
• Compliance teams at any New Zealand company touching chartering, port calls, services, or payments involving Russian-linked vessels or designated persons.

Where to check

• MFAT — Russia sanctions overview (how designations work, compliance expectations).
• Russia Sanctions Register (Excel) — includes a Ships tab with “Date of sanction”.
• Russia Sanctions Act 2022 — primary law.
• Russia Sanctions Regulations 2022 — operative rules (including “restricted ships”).
• Guidance for the transport sector on sanctioned ships — practical port/operations instructions.

Note: FleetLeaks mirrors the public Register to surface designated or restricted vessels by IMO. Always verify status against the latest MFAT register and official notices.