Knowingly or recklessly breaching the Russia Sanctions Act, carries a maximum  fine of $1 million for any entity, and seven years imprisonment or a fine of $100,000 for an individual.

For reporting entities under the AML/CFT Act, the supervisors have issued joint guidance and we have summarised the key points below:

• Understanding beneficial ownership of your clients, and ensuring you conduct enhanced customer due diligence where required, are key steps to determining whether you are dealing with persons subject to the Russia Sanctions Act.
• If as a reporting entity you form a suspicion that you are dealing with a sanctioned Russian individual or entity, you will need to submit a suspicious activity report (SAR) in accordance with existing obligations under the AML/CFT Act.
• The supervisors have strongly suggested that legal advice should be sought before proceeding with any further activity that may involve a sanctioned person/entity.
• The list of sanctioned persons includes approximately 350 Russian individuals with military or political connections, although many of these people are subject only to travel bans. Approximately 20 entities are restricted from providing or receiving services from New Zealand persons. The entities listed include militia groups and Russian engineering and technology companies.
• As a reporting entity you should be aware of the list of sanctioned persons. Where there is a prospect of dealing with assets or services in relation to anyone on this list, you should ensure that proper reviews and assessments of your customer base are undertaken and when required be vigilant as to whether there is an obligation to file a SAR.

The link here provides more detailed instruction from the Financial Intelligence Unit of the NZ Police including the growing list of individuals and entities that have been sanctioned.